This Privacy Notice is intended to tell you how we use any information we collect about you (called Personal Data as defined below) and what your rights and our obligations are in relation to the processing of your Personal Data, in accordance with the European data protection legislation and, as from 25 May 2018, the General Data Protection Regulation (the “GDPR”).
This Privacy Notice applies to the use of our websites (collectively, our “Services”) and will apply whether you access our Services using a computer, mobile phone, tablet, TV or other devices.
Please click on the links below for further information on our privacy practices:
4. On which legal basis do we process Personal Data?
5. Why do we use your Personal Data?
6. To whom and where do we disclose your Personal Data?
7. What do we do to keep your Personal Data secure?
8. What are your rights and how can you exercise them?
9. How long do we store your Personal Data?
10. Third-party links and products on our Services
12. Your choices (opting out of marketing related emails)
13. Children’s Personal Data
14. Changes to this Privacy Notice
I. [Name, address and registration number of the entity operating the website] is responsible for the processing of your Personal Data acting as controller (“Panasonic”, “we”, “us” or “our”);
II. We are part of the Panasonic Corporation, headquartered in Kadoma, Osaka Prefecture, Japan;
III. We have a number of Affiliates who can be found here
For the purposes of this Privacy Notice, "Personal Data" consists of any information that relates to an identified or identifiable individual (such as you). For example, information which identifies you may consist of your name, address, telephone number, photographs, payment details, a specific Panasonic product/device identification number that you purchased, location data, an online identifier (e.g. cookies and your IP address). Information which does not identify you on its own but that we link to you also qualifies as Personal Data.
Some Services we offer enable/require you to directly provide us with Personal Data relating to you.
I. When you create a Panasonic account or profile on our websites, applications or eShops
When you create an account or profile on a Panasonic website or application (such as a 'My Panasonic' Profile or eShop account), we ask you to provide certain Personal Data, including your name, email address, your mailing address [■, billing address and payment details]. You will use your email address and your password to login to your account/profile.
II. When you buy Panasonic products or devices on a Panasonic website
If you purchase a product or device on a Panasonic website, then we will collect Personal Data from you, such as your name, mailing address and telephone number, so that we can process and fulfil your order.
III. When you register a product or device with Panasonic
If you choose to register the relevant product or device with us in order to benefit from certain features (such as product/device warranty), we may collect Personal Data about you such as your name, address, phone number, email address and information about the Panasonic product or device you purchased, such as its serial numbers (or other product/device identifier) and the date of purchase.
IV. When you communicate with Panasonic
When you contact us or interact with our customer support representatives via email, telephone or in person, we may collect Personal Data about you, such as your name, mailing address, phone number, email address and contact preferences, as well as information about the Panasonic products or devices you purchased, such as their serial numbers and date of purchase. We may also create logs/reports that are useful in diagnosing product or application performance related issues to capture information relating to such issues. We may access your 'My Panasonic' Profile, or other relevant Panasonic profile/account. We may also record and review your conversations with our customer support representatives (e.g. when you contact us by telephone) and also review any information you have provided in response to a voluntary customer survey(s). We will only record and/or review your conversations with us where we are permitted to do so by applicable laws and we will tell you that we are doing so at the latest at the start of the conversations.
V. Message boards and forums
Some Panasonic websites and applications have message boards, forums, bulletin boards, chat functionality, blogs, and similar features ("Community Postings") through which you can post information, messages and other materials. When you disclose any Personal Data through such services we recommend you to be very careful as this may become public information and be available to visitors to our websites and to the general public.
In order to participate in Community Postings we collect Personal Data, which includes your name, username, password, email address, telephone number and any other information that you decide to communicate on such Community Postings).
VI. Promotions, games, prize draws and competitions
If you enter into sweepstakes, contests, online games, prize draws, competitions or similar promotions ("Activities"), we will use the Personal Data you provide to administer the Activities which includes your name, username, password, email address, date of birth and telephone number.
To the extent that the terms and conditions of any such promotion regarding the treatment of Personal Data about you would conflict with this Privacy Notice, the terms and conditions of the promotion will prevail. We therefore advise you to review any Activity specific terms and conditions carefully.
VII. Subscriptions and newsletters
Where you subscribe to our promotional communications and newsletters we will collect Personal Data including your email address and postal address. We will only provide such subscription services to you in accordance with applicable laws and where you have expressly requested us to do so.
VIII. When you upload Personal Data to a Panasonic website or online application
In addition to the above, we collect such other Personal Data that you provide by uploading content (e.g. video or photos) onto our websites or online applications. In such cases, we collect the following Personal Data: your name, email address and the content that you choose to upload. Where we collect such content we will only do so in accordance with applicable laws.
We collect information about your use of our Services through software on your Panasonic product/device and other means, or your use of our online applications. For example, we collect:
I. Product/device information - such as your hardware model, product/device IMEI number, the MAC address of your device’s wireless network interface and the mobile phone number used by such device, your mobile network information, your mobile operating system, the type of mobile browser you use, your time zone setting, and other unique device identifiers, IP address, operating system details, and settings of the device you use to access the Services.
II. Log information - such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your product/device or our application.
III. Location information - such as your product or device’s GPS signal or information about nearby WiFi access points and cell towers that is transmitted to us when you use certain Services. Some of our location-enabled Services require your Personal Data for the feature to work.
IV. Voice information - such as recordings of your voice that we store on our servers when you use voice commands.
V. Other information - about your use of the Services, such as the online applications you use, the websites you visit and how you interact with content offered through our Services.
We may receive Personal Data relating to you from third parties, and described below.
I. Information from publicly available sources
We may receive Personal Data about you from publicly available sources, such as [cookie information], such receipt and the combination with other Personal Data we hold about you taking place of in compliance with applicable laws.
II. When you login to any Panasonic account with your social media credentials
We also receive information about you from social networks when you choose to connect with those networks. [Panasonic Account] allows you to sign up and log in using your Facebook account. If you do so, you allow Facebook to share certain Personal Data from your Facebook account with us. This Personal Data includes your name, gender, general location, a link to your Facebook profile, your time zone, your date of birth, your profile picture, your “likes” and your list of “friends”. This Personal Data is collected by Facebook, as controller, is provided to us and become subject to this Privacy Notice.
We recommend that you become familiar with Facebook functioning so as to know how you can control your Personal Data and its sharing by Facebook with us using any privacy setting in your Facebook account.
We are not allowed to process Personal Data if we cannot rely on a valid legal ground. Therefore, we will only process your Personal Data when:
I. we have obtained your prior unambiguous consent;
II. the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
III. the processing is necessary to comply with our legal or regulatory obligations;
IV. the processing is necessary to protect your vital interests or those of another natural person; or
V. the processing is necessary for our legitimate interests except where they are overridden by your interests or fundamental rights and freedoms. Examples of such ‘legitimate interests’ include:
I. to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers);
II. to protect the security of our IT systems, architecture and networks; and
III. to meet our corporate and social responsibility objectives.
We may use the Personal Data we collect for the following purposes:
I. Create an Account/Log in on our Websites, Applications or eShops – to enable you to create a profile on our websites, applications or eShops, and to enable you to log in to such websites, applications or eShops;
II. Online Purchases – to enable online purchases of our Services through our eShop website or other application, to deliver the purchased products/devices, and to provide any checkout assistance that you may need, for example, to complete your purchase if you have technical difficulties;
III. Provide our Services – to provide our Services or any specific feature that you may request, including to enable us to fulfil our obligations under any contract with you (such as any product or device warranty);
IV. Registering products/devices – to register your devices or products or any of our Services (product or device warranty);
V. Surveys – to ask for your opinions or comments on our Services and to conduct other surveys;
VI. Customised, Targeting Content, Advertising and Newsletters – to provide customised content, make recommendations based on your past activities regarding our Services and advertising (directly or via our partners such as social media networks), as well as to provide you with newsletters and other communications by post, telephone, emails and/or other electronic communication means;
VII. Profiling – to make predictions about your interests and provide you with direct marketing on that basis;
VIII. Analysis Purposes for Services improvements – for assessment and analysis of our market, customers, products, devices and other Services and your use thereof, in order to develop and improve new and existing Panasonic products and Services;
IX. Statistics – to create anonymous, aggregated statistics about the use of our Services. This anonymised data may be shared with third parties;
X. Customer Support Services – to provide customer support services for our Services, or to deal with any other support queries you may have (such as complaint handling);
XI. Business Purposes – for business monitoring and internal record keeping;
XII. Publish your comments and Upload your Content – where you upload product or device reviews, comments or content to our websites, applications or Community Postings, or where you have responded to a voluntary survey pursuant to section V above, we may link to, publish your comments including in our own advertisements;
XIII. Legal Obligations – to comply with our legal obligations under European Member States laws or under European Union law;
XIV. Security – to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of Panasonic, including enforcing any terms or agreements governing the use of our Services;
XV. Competitions and Promotions – to conduct Activities and record your participation thereto, as permitted by law as well as to provide your Personal Data to our partners and sponsors of such Activities;
XVI. Training – for staff training and quality assurance purposes, particularly in relation to our customer support representatives;
XVII. Updates – to communicate with you, including communicating with you about your account, profiles or transactions with us, giving you important information about your products, devices, application or other Services, sending you notices about any material changes to our Privacy Notice;
XVIII. Combining Personal Data – to combine Personal Data we collect from you, for example to allow us to provide better support services and more personalised content;
XIX. Corporate Transaction – to manage corporate transactions involving our company, including reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of Panasonic's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
XX. Web site analysis
A. Third parties recipient of the Personal Data
We may disclose your information to the following entities:
I. Panasonic Affiliates
We may need to transfer your Personal Data to other Panasonic Affiliates to provide the Services you require or any other services/assistance. All Panasonic Affiliates are required to follow the privacy practices set forth in this Privacy Notice.
II. Selected Partners
We may share your Personal Data with our business partners, including wireless carriers. These partners may use your Personal Data to provide you with Panasonic Services you request (such as, video content), make predictions about your interests and may provide you with promotional materials, advertisements and other materials.
III. Service Providers
We use third party service providers to help us to administer certain activities and services on our behalf, such as fulfilling your purchases and delivering products, processing credit card payments, sending postal mail and emails, sending text messages (such as SMS), providing advertisements, analysing usage of our Services, tracking effectiveness of our marketing campaigns, allowing users to connect to their social network and providing customer support services. We share Personal Data about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:
a. Email Service Providers – Cloud services from [■e.g. Adobe] are used to assist us in sending emails to you in accordance with your marketing preferences;
b. Analytics Service Providers – analytics providers are used to assist us in understanding the usage of our products/devices and other Services, to enable us to improve our Services. The analytics providers we currently use are [■e.g. Google Analytics]. For further information see the Cookie section of this Privacy Notice.
IV. Social Networks
We may provide your Personal Data, such as your email address, to certain social networks.
We will only share your Personal Data with social networks in accordance with your marketing preferences and any applicable laws.
V. Third parties when required by Law or to Protect our Services
We will disclose your Personal Data to comply with applicable Member State or European Union law or respond to valid legal process, including from law enforcement or other government agencies.
VI. Other Parties in Connection With Corporate Transactions
We may disclose your Personal Data to a third party (or other Panasonic Affiliate) as part of a reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of Panasonic's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
VII. Third party competition providers
We may disclose your Personal Data to third party sponsors of Activities. These third party providers will be identified to you prior to any Activities to which you may decide to participate.
VIII.[Panasonic Information Systems Co., Ltd. ]
A number of Panasonic's Services give you the option and ability to upload and share certain Personal Data, such as, messages, photos, videos and other content. Any Personal Data that you choose to upload and share on a publicly accessible website, application or Community Postings may be viewed and accessed by others. As such, you should always exercise caution when using such Panasonic Services.
B. International Transfer of Personal Data
The Personal Data that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to Japan, USA or in any other country which do not offer an adequate level of data protection as recognised by the European Commission and where Panasonic or its Affiliates, subsidiaries or service providers maintain facilities.
Where we transfer your Personal Data outside the EEA, we will ensure that suitable safeguards such as appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Data. You may request additional information in this respect and obtain a copy of the relevant safeguards upon request through sending a request to the contact indicated in section 8 below.
Panasonic have put in place appropriate technical and organisational measures to safeguard the Personal Data we collect in connection with our Services. These measures take into account:
I. the state of the art of the technology;
II. the costs of its implementation;
III. the nature of the data; and
IV. the risk of the processing.
The purpose thereof is to protect against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Data.
[■All Personal Data you provide to us is stored on our secure servers. Any payment transactions [■carried out by us or our chosen third-party provider of payment processing services, will be encrypted [■using Secured Sockets Layer technology]. Where we have given you (or where you have chosen) a password that enables you to access certain Services, such as your ‘My Panasonic Profile’ or your eShop account, you are responsible for keeping this password confidential and we ask you not to share your password with anyone.
C. Other security measures
Information security, including the protection of Personal Data is organized in a global Panasonic Program called “Information Security Management” (ISM). The related aim, standards and implementation measures are organized in globally valid policy, standards and guidelines. All central European IT systems are externally assessed and fall under the information security management rules applicable under the ISO 27001 certification. The program in all its parts follow a strong yearly PDCA (Plan-Do-Check-Act) approach to secure the confidentiality, integrity and availability of all data (including your Personal Data) for the whole information lifecycle from collection to destruction of such data.
D. Using social media and forum features
Certain Services include social networking, chat room or forum features. You should ensure that when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by other users.
A. What are your rights?
Panasonic will collect, store and process your Personal Data in accordance with your rights under any applicable data protection laws.
Your rights under the GDPR include, the right to access a copy of your Personal Data, the right to request the correction or the update of any inaccurate Personal Data and the right to object to the processing of your Personal Data under the conditions set out in the GDPR.
You also have the right to request the erasure of your Personal Data and, where you have consented to the processing of your Personal Data, you have the right to withdraw such consent at any time (without this withdrawal affecting the lawfulness of the processing prior to such withdrawal). In addition, you also have the right to data portability in certain cases. This is the right to request the return of the Personal Data you have provided to us in a structured, commonly used and machine-readable format and to request the transmission of such Personal Data to a third party, without hindrance from us and subject to your own confidentiality obligations.
B. Exercising your rights
If you wish to exercise any of the above rights, please contact us by using any of the communication means below. When doing so, please provide us with a proof of your identity for identification purpose. *
I. By mail:
II. By telephone:
+1-855-772-2891 (toll-free call)
If you are not satisfied with how we process your Personal Data, you may also file a complaint with the competent supervisory authority, in addition to your rights outlined above.
We will retain your Personal Data for the period necessary to fulfil the purposes for which your Personal Data has been collected as outlined in this Privacy Notice unless a longer retention period is required by law. When your Personal Data is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
A. What are cookies?
B. Further information on cookies
We and other Panasonic Affiliates may use your Personal Data (such as your contact details (e.g. name, address, email address, telephone number)) to send you marketing-related correspondence by mail, email, telephone and/or text message (such as SMS) related to Panasonic products, devices and other Services in accordance with your email and contact preferences in your [■My Panasonic Profile] or as you otherwise agree to.
When you purchase Panasonic products or device, contact our customer support representatives, create an account or profile for one of our Services (such as a ‘My Panasonic Profile’ or eShop account), or subscribe to one of our Services, you may be given the opportunity to opt-in to (or where permitted by applicable law, opt-out of) the receiving of such marketing-related correspondence.
We do not share Personal Data with third parties for the third parties’ marketing purposes.
To opt out of receiving marketing-related correspondence from Panasonic, please update your email and contact preferences in your My Panasonic Profile or click "Unsubscribe" from any marketing or promotional email or text message (such as SMS) you receive from us.
I. Who is a child?
Panasonic considers a child to by anyone under the age of 16, or such younger age as may be specified by applicable data protection laws.
II. Do we collect Personal Data from children?
We do not knowingly collect or try to collect Personal Data from or about children without the consent of a parent or guardian. Where we do collect Personal Data from children, we will always use reasonable efforts to verify that consent has been given or authorised by the child's parent or guardian.
III. What do we do when children submit Personal Data to us?
If we become aware that Personal Data submitted to us relates to a child without the consent of a parent or guardian, we will use reasonable efforts to:
- delete that Personal Data as soon as possible; or
- if deletion is not possible, we will ensure that this Personal Data is not used for any purpose, nor disclosed to any third party.
IV. Parent or guardian queries
If you are a parent or guardian and you have queries regarding Panasonic's processing of your child's Personal Data, please contact us using the details provided in Section 8.
Panasonic may change this Privacy Notice from time to time. The “Date last updated” mention at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
Where required by applicable law, we will request your consent to any such changes. We will provide this notice by email or by posting notice of the changes on the Panasonic website or through any relevant Services.
You may access, amend, update, or correct your information at any time by logging into your account or emailing us at firstname.lastname@example.org. You may also call us at (855) 772-2891. In some circumstances, you may have the right to object to Panasonic’s use of your information. If you wish to delete or deactivate your account, please email us at email@example.com or call us at (855) 772-2891, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
You must be at least 18 years of age to use our website or Services. Panasonic does not knowingly collect or maintain any personal information from children under the age of 13 and no part of our website is designed with the purpose of attracting such children.
You may opt out of receiving promotional emails from Panasonic by following the instructions in those emails or by emailing firstname.lastname@example.org. You may also call us at (855) 772-2891.If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Date last updated: [Dec.] 2019