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1. Background

We, �������ֳ�., are a world leader in cordless technology spanning Power Tools, Outdoor Power Equipment, Floorcare and Cleaning for the professional, industrial, DIY and consumer users in construction, industrial, commercial, infrastructure, power utility, MRO, and consumer home markets. We are committed to accelerating the transformation of these industries through superior environmentally friendly cordless technology. This Policy sets out how we handle personal information.

About �������ֳ� Group

�������ֳ� Group (“�������ֳ�”) is a group of companies under the umbrella of their parent company �������ֳ�., a public limited company incorporated under the laws of Hong Kong SAR. The �������ֳ� brands like MILWAUKEE, RYOBI and HOOVER are recognized worldwide for their deep heritage and cordless product platforms of superior quality, outstanding performance, safety, productivity and compelling innovation. A full list of our brands is available here (.vn/en/brands). 

Our group of companies operate in various countries across continents. This group level Privacy Policy together with region and country level privacy policies, notices and statements form our privacy program for global operations and show our commitment to compliance with privacy and data protection laws around the world, respect for individual privacy and upholding high ethical standards.

This Policy

“Personal information” is any information about identifiable individuals. When we, or our partners, collect and process this information, we must comply with data protection and privacy laws in the countries where we operate. 

This Policy describes the types of personal information that we collect and process, why we collect and process it, who we may share it with, and how we keep it safe.

This Policy applies to all the personal information that we collect and process across our global business and through all our �������ֳ� group companies and for all our brands. This includes the personal information that we collect and process from: 

• people who visit our websites;
• people who subscribe to our marketing initiatives, participate in our marketing events, or join our loyalty programs;
• people who purchase products from us or our authorized distributors, dealers or retail partners, or use our or our authorized service providers’ warranty services;
• people who apply for a position, an internship or job shadowing with us;
• people we work with, including employees, contractors and sub-contractors, partners and third-party service provider representatives, and business contacts. 

We update this Policy from time to time. You can always find the most up-to-date version on our website here (.vn/en/privacy-policy). 

2. What Personal Information Do We Collect and Process?  

When you visit our websites, buy our products or use our services, etc., we may collect and process the information about you to effectively run our business and deliver value to our customers.

The personal information we collect and process about you will depend on our relationship with you. We may collect and process the following types of personal information (which may include sensitive personal information) about you as an individual or as an individual representative of your business:

• Contact Information – this includes your name, email address and telephone number, proof of authority, and other information you submit when communicating with us or interacting with the “contact us” sections of our websites or services, or when you contract or do business with us.
• Transaction Information – this includes credit card details, debit card details and other payment information that you provide when shopping on our websites or in our physical stores.
• �������ֳ� Website Information – this includes data collected when you interact with our websites, applications or electronic advertising. It may include your IP address, device identifiers, advertising ID, browsing history, web logs and information collected using cookies or other technologies. You can read about the cookies that we use and change your settings in the Cookies Preference Center on our websites.
• Professional and Employment Information – this includes information collected from and about employees and job, internship or job shadowing applicants, such as resumes, education and work history, qualifications and certifications, professional interests, identity documents, proof of address, contact details, right-to-work documentation and professional references.
• Information from Third Parties – this includes your information shared with us by third parties, including our authorized distributors, dealers or retail partners and service providers (including the providers of the postal and courier services we use to deliver products you purchase from us).

3. Why Do We Collect, Use and Disclose Personal Information?

We collect, use and disclose your personal information to improve our products and services, deliver products to customers, manage our business and comply with laws, etc.

Purposes of collection

For example, we collect, use and disclose your personal information for the following purposes:

• Communicating with you: To give you information about our products and services and share important updates.
• Tailoring content to you: To identify your preferences and to provide personalized content in the form of advertisements, offers, loyalty membership rewards and products and services that you may be interested in or asked for.
• Maintaining security: To keep our customers, visitors, and staff safe, and to manage security incidents and perform investigations.
• Providing goods and services: To provide you with our goods and services, and manage your account in relation to such goods and services.
• Improving our products, services and customer experience: To analyze performance and improve our products, services, and systems.
• Managing our third-party relationships: To manage our relationships with third parties such as our suppliers, authorized distributors, dealers or retail partners, service providers and other business partners.
• Managing employment relationships: To manage our relationships with employees, applicants and contractors. 
• Complying with laws: To comply with our legal obligations, including licensing, reporting and regulatory obligations, and to assist in law enforcement when required.

We may also use or disclose your personal information for other purposes that are allowed by law.

Legal basis for handling your personal information 

Under many data protection and privacy laws and regulations, including the Hong Kong Personal Data (Privacy) Ordinance (PDPO) and the EU General Data Protection Regulation (GDPR), businesses must identify the legal reason for collecting and handling personal information. These reasons include where the processing of the personal information is:

• needed to comply with a contract or to take steps at the request of the data subject prior to entering into a contract;
• needed to comply with the law (for example, where a business is required to collect personal information for tax reasons);
• needed to act in the public interest (this applies where a business is permitted to carry out this task as outlined in law);
• in a business’s legitimate interests, where that interest is not overridden or does not undermine an individual’s rights or interests; and
• done with the consent of the individual. 

We will always identify an appropriate reason under applicable data protection and privacy laws to handle your personal information. 

In most cases, we collect personal information:

• to comply with a contract – for example, to manage warranty claims;
• where it is in our legitimate interests – for example, to understand how and when people use our websites; or
• with your consent – for example, when you contact us through one of our websites.

Events and promotional materials

We may use photos, video or audio recordings at our events for promotional, internal, and archival purposes, and they may appear on our websites, printed materials, social media, and press releases. 

Our promotion is carried out in accordance with this Policy and the laws of the countries where the promotion takes place. 

We will seek your prior consent to be photographed, filmed or audio recorded if so required by local laws. Otherwise, you can opt out of being photographed, filmed or audio recorded by informing us prior to participating in the event or promptly at the event.

Direct marketing 

We may use your personal information to send you marketing messages when you agree to receive them. This may include contacting you in various ways, including email, SMS, instant messaging apps, notifications on your social media pages, in-app messaging and postal mail. 

Our direct marketing is carried out in accordance with this Policy and the laws of the countries where the direct marketing takes place. 

You can opt out of receiving direct marketing messages at any time by, where applicable, using the unsubscribe options in the message, changing the settings in your account, or contacting us using the details available below.

Retention

We will only retain your personal information for as long as we need it for lawful purposes, or as is required by law. When we no longer require your personal information, we will securely dispose of it.

Third parties

We partner with other organizations to provide our products and services and may share personal information with these third parties as far as allowed under applicable data protection and privacy laws. Third parties may also collect personal information on our behalf and share it with us. These third parties may include:

• our authorized distributors, dealers or retail partners;
• our supply chain partners;
• our information technology and data storage providers;
• our contracted recruitment agencies; and
• financial institutions or payment processors.

We may also disclose personal information when required to do so by applicable laws, including to law enforcement, regulators or courts.

When we work with third parties, we require them to handle your personal information safely and in a way that meets our global legal requirements.

4. Data Transfers

We operate a global business and provide products and services to customers in several countries. In certain situations, your personal information may be transferred to countries outside of where you live, and which may have different data protection and privacy laws and standards. When this happens, we ensure that the transfer of your personal information is allowed by law and take steps to keep your personal information safe.

5. Your Rights

Your rights as a data subject will vary according to the laws of the country you are in. In many countries you will be able to exercise the following rights:

• The right to obtain information about whether or not and the extent to which we process your personal information.
• The right to access information that is held about you and information as to why your information is processed.
• The right to request that we correct any personal information that may be inaccurate or incomplete.
• The right to request that your personal information be deleted in certain circumstances.
• The right to withdraw your consent for personal information processing.
• The right to request that the processing of your personal information be restricted in certain circumstances.
• The right to object to the processing of your personal information in certain circumstances.
• The right to receive a copy of your personal information in a structured, standard and machine-readable format that can be provided to another company if required.

Is there a fee?

We will ordinarily handle your request free of charge. However, if your request is manifestly unfounded or excessive, in particular because of the repetitive character, we may charge a reasonable fee to cover the time we spend finding and compiling the personal information you have requested. If there is a fee, we will let you know how much it will likely be before proceeding with your request.

How long will it take?

We’ll respond to your request within one month of receipt of your request, or a shorter period of time if required by local laws. We will let you know if we think that an extension of time is needed due to the complexity and/or number of requests. 

Before we handle your request, we will need to verify your identity to protect your personal information.

How can you contact us?

See ‘Contact Us’, below.

6. Updates to This Policy

We may update this Policy from time to time to reflect changes in our privacy processes and changes in data protection and privacy laws and regulations. Updates to this Policy will be communicated to you by email and via our website. You can always find a current version of our Policy here (.vn/en/privacy-policy).

7. Complaints

If you are concerned with how your personal information has been handled, please let us know and we will endeavour to resolve your complaint. 

If you’re not satisfied with how we have managed your complaint, you may submit a complaint to a data protection authority. Many countries enable individuals to submit complaints to their data protection authorities under their applicable data protection and privacy laws and regulations. A list of the countries in which we operate can be found here (/contacts/tti-offices). 

How can you make a privacy complaint?

If you’re concerned about your privacy or how we’ve handled your personal information, you can let us know and we’ll try our best to resolve your complaint (see ‘Contact us’, below).

How do we manage privacy complaints?

We will:

• retain a record of your complaint,
• acknowledge your complaint to confirm that it has been safely received,
• investigate your complaint (including, for example, gathering the relevant facts, locating and reviewing relevant documents and speaking to relevant individuals), and
• write to you with our final response, including our view on whether we have complied with this Policy or relevant data protection and privacy laws, and what we will do to fix the issue.

For the majority of requests, we’ll give you a final response within a reasonable time of receiving your complaint. If we can’t respond within that time, we’ll get in touch to tell you why and work out a new timeframe with you.

8. Contact Us

Please contact us if you have any questions or concerns about how we handle your personal information or if you wish to exercise any of your rights.  

Email: privacy@tti.com.hk 

Post: �������ֳ�.

29/F, Tower 2 Kowloon Commerce Centre, 51 Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong, China

Attention: Data Protection Officer