Elite Home Theater Seating Inc. Privacy Notice

Background

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.

This privacy notice applies to personal information processed by or on behalf of Elite Home Theater Seating Inc. (Elite HTS).

Use the links below to find out more about how we use your personal information:

• Who are we and how do you contact us and our Data Protection Officer?
• What kinds of personal information about you do we process?
• What is the source of your personal information?
• What are the legal grounds for our processing of your personal information (including when we share it with others)?
• What should you do if your personal information changes?
• For how long is your personal information retained by us?
• What are your rights under data protection laws?
• How can you opt out of marketing communications?

1. Elite HTS and our Data Protection Officer

Elite HTS is based at Unit 406, 17665 66A Avenue, Surrey, BC V3S 2A7. We are a data controller of your personal data. We have a dedicated data protection officer (“DPO”). You can contact the DPO using the details below or by writing to the above address, marking it for the attention of the DPO or going to Contact Us.

2. What kinds of personal information about you do we process?

‍Personal information that we’ll process in connection with all of our products and services, if relevant, includes:

• Personal and contact details, such as title, full name, contact details and contact details history
• Your nationality, if needed for the product or service
• Family members (if relevant to the product or service)
• Records of your contact with us such as via the phone number and social media
• Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
• The usage of our products and services
• Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you.
• Purchase history and product information, such as make and model, faults, repairs and repair costs.
• Information about your employment status, if relevant
• Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK
• Information we buy or rent from third parties, including demographic information, product details, marketing lists, publicly available information, and information to help improve the relevance of our products and services
• Insights about you and our customers gained from analysis or profiling of customers
• Where relevant, information about any guarantor which you provide in any application
• Tax information, if relevant (for example, for savings accounts)

3. What is the source of your personal information?

We’ll collect personal information from the following general sources:

• From you directly
• Information generated about you when you use our products and services
• From a broker or other intermediary (for example, an installer or interior decorator) who we work with to provide products or services or quote to you
• We buy or rent information about you or customers generally from third parties including demographic information, marketing lists, publicly available information and other information to help improve our products and services or our business

4. What do we use your personal data for?

We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:

• Assessing a purchase order, including considering whether or not to offer you the product or service, the price, the risk of doing so, availability of payment method and the terms
• Managing the product or service you have with us
• Updating your records, tracing your whereabouts and recovering debt
• Managing any aspect of the product or service
• To make automated decisions on whether to offer you a product or service, or the price, payment method, risk or terms of it
• To perform and/or test the performance of, our products, services and internal processes
• To improve the operation of our business and that of our business partners
• To follow guidance and best practice under the change to rules of governmental and regulatory bodies
• For management and auditing of our business operations including accounting
• To carry out checks at Credit Reference and Fraud Prevention Agencies pre-application, at application, and periodically after that
• To monitor and to keep records of our communications with you and our staff (see below)
• To administer our good governance requirements, such as internal reporting and compliance obligations
• For market research and analysis and developing statistics
• For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We may send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). Offers may relate to any of our products and services as well as to any other offers and advice we think may be of interest
• To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
• To develop new products and services and to review and improve current products and services
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
• To facilitate the sale of one or more parts of our business

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

6. When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

• Elite HTS service providers and sub-contractors
• Business partners (for example, installers and/or interior designers) or others who are a part of providing your products and services or operating our business
• Governmental and regulatory bodies
• Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
• Credit Reference and Fraud Prevention Agencies (see below)
• Market research organisations who help us to develop and improve our products and services

7. How and when can you withdraw your consent?

Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

8. Is your personal information transferred outside the UK or the EEA?

Elite HTS is based in Canada which means that your personal information will be transferred outside the European Economic Area. In doing so, we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

9. What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update any records that we have on file.

10. Do you have to provide your personal information to us?

We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

11. Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor, where permitted by law, and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

12. For how long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
• For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
• Retention periods in line with legal and regulatory requirements or guidance.

13. What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

• The right to be informed about the processing of your personal information
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the “right to be forgotten”)
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information (“data portability”)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
• You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.

14. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.

15. What are your marketing preferences and what do they mean?

We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences.

You can opt out of any email or text marketing by following the unsubscribe links. If you receive a marketing call from us, you can ask the person who called you to opt you out. You can also write to us at Elite HTS, Unit 406, 17665 66A Avenue, Surrey BC Canada V3S 2A7, marking it for the attention of the DPO. Or send us an email on our Contact Us page and stating in the subject line ‘I want to opt out of marketing messaging’.

16. Hotjar & Mouseflow

We use Hotjar and Mouseflow in order to better understand our users’ needs and to optimize this service and experience. Hotjar and Mouseflow are a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. These tools use cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar and Mouseflow store this information in a pseudonymized user profile. Neither Hotjar, Mouseflow, nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link or Mouseflow’s privacy policy by clicking on this link.

Contact Us

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website. Alternatively, you can write to Elite HTS, Unit 406, 17665 66A Avenue, Surrey BC Canada V3S 2A7, marking it for the attention of the DPO.