Innovation for a Better Life
Privacy Policy
This Privacy Policy explains and seeks your agreement on how LG Electronics Inc. (“LGE”, “we” or “our”) collects, uses and shares information that we obtain as a result of your interest in, and your request for information regarding, LGE products and services. You do not have to agree to this Privacy Policy or any parts thereof. However, if you do not agree, we will not be able to provide you with information on our products and services using our electronic system, which will impede the efficiency and timeliness of our response to your inquiries.

For the purpose of this Privacy Policy, “Personal Information” is information that identifies you personally, or information from which you are identifiable, such as your name, address, country of residence, telephone number, email address, or in some cases your IP address and cookie IDs where this information can be combined with other information to identify you.

1. Introduction and Scope
LG Electronics Inc. and its family of companies are committed to protecting the Personal Information of potential partners and customers as well as their employees. This Privacy Policy sets out how we collect, use and share Personal Information that we obtain as a result of your interest in, and your request for information regarding, LGE products and services, and in particular, sets out:

• What information LGE may obtain from you;
• When LGE shares information with others;
• When and why LGE may need to transfer your Personal Information outside your country of residence; and
• How you may control or limit LGE’s use and sharing of your information.
• How LGE uses the information that it obtains;


If you have made an inquiry regarding certain system product, which require installation by a professional installer or system integrator and cannot be installed by ordinary end users, the compatibility of a specific system product with your existing system as well as the lead time and price for purchasing and installing system product may vary depending on the characteristics of your installation site and the local electricity grid. Therefore we may offer such system products through professional installers and system integrators, and your inquiry regarding our system products may be processed through your local installers or system integrators.

Please note that this Privacy Policy is different from our general privacy policy for business to consumer interaction, or privacy policy for various other products and services we offer. We further note that this Privacy Policy does not cover collection of Personal Information from citizens and residents of the Russian Federation and the People’s Republic of China. If your submission of Personal Information would fall outside the scope of this Privacy Policy, please do not consent to this Privacy Policy and do not submit any Personal Information to LGE unless and until you have been provided with the correct privacy policy applicable to your circumstances, you have read and understood such privacy policy and you agree with it.

2. Information Collected
We collect the following information from you:

• Your name, company address, company phone number, company email and any other information as provided on your business card.


3. Use of Information and Grounds for Processing
We may use your information that is collected from your business card for the following purposes:

• To provide a response to your inquiry;
• To analyze, review, and improve the products or services we offer, to understand how customers are using the products and service, and to develop new products and services;
• To notify you about a material change to this privacy policy, if necessary;
• To protect and defend our rights and property, including by way of legal proceedings;
• To ensure compliance with legal obligations and regulatory requirements; and
• For internal record keeping.


In addition, if and to the extent that you have explicitly agreed to receive marketing information, we also use your information for the following purposes:

• To alert you to special offers, updated information and other new products or services from LGE, or other third parties, or to forward promotional materials to you; and
• To help us create and publish content most relevant to you.


We may combine information obtained from your business card, including Personal Information, with information that you provide to us by other means, for the purposes consistent with this Privacy Policy.

We may use your Personal Information based on your explicit consent for marketing purposes beyond the scope of your inquiry (if applicable). We also use your non-personal information for the purposes of our legitimate interests (including our legitimate commercial and related interests, such as understanding our customers and potential customers), and for compliance with legal obligations to which we are subject.

4. Sharing and Disclosure of Information
We may share or disclose your information:

• To professional installers or system integrators in order to respond to your inquiry. Our system products cannot be installed in at your site by ordinary end users and require installation by a professional installer or system integrator, and the compatibility of a specific system products as well as the lead time and price for purchasing and installing system products may vary depending on the characteristics of your installation site and the local electricity grid. Therefore we may offer such system products through professional installers and system integrators, and your inquiry regarding our system products may be processed through your local installers or system integrators.
• To our affiliates and subsidiaries around the world for the purposes described in this Privacy Policy. The term “affiliates” or “subsidiaries” refers to group companies who may be using LG name or who has common ownership or control such as LG CNS, LG Electronics Inc. or LG Electronics U.S.A., Inc.; LGE may have to share your data with these parties in order to provide you with responses that have been requested by you, or so that we can ensure our response is meeting your needs.
• To selected third-parties including:

a) Service providers, agents or independent contractors who help us maintain our electronic system as well as cloud server and provide other administrative services to us (including, but not limited to, data processing, order processing and fulfilment, customer service, maintaining and analyzing data, and sending customer communications on LGE's behalf), such as Salesforce.com, Inc.; and
b) Other third-parties to provide you with promotional or marketing communications, which we feel you are interested in or may be relevant to you. This is only if you have opted in to receiving such communications and you may opt out at any time by writing to us or clicking an opt-out link at the bottom of any third party marketing emails.

We will seek to ensure that these unaffiliated third parties will not use the Personal Information in a way which is outside the scope of this Privacy Policy and where applicable, for any purpose other than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers help us administer our electronic system and cloud server, their access to Personal Information is necessary for the operation of our electronic system and cloud server. If you do not wish for our unaffiliated third-party service providers to have access to your information, please do not submit any Personal Information to us.

• To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property or act in urgent circumstances to protect the personal safety of our end users.


5. Your Rights
You have the right to: (i) request information on and access to all the Personal Information and categories of Personal Information we hold about you; (ii) request the source of your Personal Information, (iii) request the third parties and categories of third parties, with whom we have shared your Personal Information, (iv) request a statement regarding the business purpose of our use of your Personal Information, (v) request that any inaccurate Personal Information we hold be corrected; (vi) to object to certain types of processing of your Personal Information we carry out (including the right to opt-out of any direct marketing or restrict processing of your Personal Information) and withdraw any consent you have granted us; (vii) request that we delete the Personal Information we hold about you; (viii) to request a copy of your Personal Information in a machine readable, commonly used format (or to request we transfer your Personal Information in such a format to a third party service provider); and (ix) to lodge a complaint with a supervisory authority.

When you submit a request for information, correction or deletion of your Personal Information, we will need to verify your identity before addressing and fulfilling your request. Please cooperate with LGE in verifying your identity and/or (if applicable) that your agent has been properly authorized by you in writing to make requests on your behalf.

We endeavor to respond to a verifiable request for information, correction or deletion within 30 days or within the period limit set by law of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

For clarity, LGE expressly states that we do not, and will not in the future, sell your Personal Information under any circumstances. You further have the right not to receive discriminatory treatment because of your requests and exercise of your rights, and LGE does not and will not disadvantage you or discriminate against you because of your requests and exercise of your rights.

6. Contact Information
If you have any questions or comments about this Privacy Policy or LGE’s processing of your Personal Information, or if you have requests based on your rights outlined in section 5 above, please contact LGE via the following method(s):

For United States residents:
[caprivacy@lge.com] or (for California residents) [833-660-0245]

For European Union residents (contact for EU Data Protection Officer):
[dpo-eu@lge.com]

For other international residents outside the Russian Federation and the People’s Republic of China:
[lbcs@lge.com]

7. Overseas Transfers
As a global organization, LGE, our affiliates and our subsidiaries may need to transfer your information (including your Personal Information) outside the country where you reside (overseas), for example to our headquarters in Republic of Korea, as well as to our affiliates and subsidiaries or to data processors and cloud server providers around the world. We may store your Personal Information overseas, and we may also have your Personal Information processed by staff located overseas. We will transfer your Personal Information overseas in a manner consistent with this Privacy Policy and any applicable laws as part of regular operation of our electronic systems and cloud server networks; we will do so in order to respond to your inquiries regarding LGE products or services, in order to respond to your requests when you exercise your rights, and for any other purpose outlined in this Privacy Policy. You should also bear in mind that the data protection laws in many of these countries may not offer the same level of protection as those in your home country. However, before transferring we will take steps to ensure that safeguards are put in place aimed at ensuring the same level of protection as required by applicable data protection laws in the country of your residence.

Please note that for citizens of European Union member states and residents of the European Union, this provision means that your Personal Information will the transferred outside the European Economic Area, stored outside the European Economic Area and/or processed by staff located outside the European Economic Area.

For further information on how we handle and protect your Personal Information when transferring it overseas, please refer to the separate agreement named ‘Overseas Transfers’ below. Please note that because of LGE’s electronic systems and cloud server networks, LGE is only able to electronically store and process your Personal Information if you consent to the ‘Overseas Transfers’ agreement, and refusing consent may result in LGE not being able to provide you with information on our products and services using our electronic system, which will impede the efficiency and timeliness of our response to your inquiries.

8. Marketing
From time to time, we communicate with persons who subscribe to our marketing services via email or text message to alert you to special offers, updated information and other new products or services from LGE, or other third parties, or to forward promotional materials to you. If you wish to subscribe to our marketing services, please consent to the separate agreement named ‘Marketing Services’ below. We also provide you the opportunity to exercise an opt-out choice if you no longer wish to continue receiving these marketing communications from us. The opt-out choice may be exercised by checking or un-checking the appropriate box provided at the points where Personal Information is collected, by using the ‘Unsubscribe’ link provided at the bottom of marketing emails, or by contacting us using the contact details provided at section 6 of this Privacy Policy. If you request discontinuation of marketing information, we will process your unsubscription as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscription is processed, especially on the date of your unsubscription.

9. Retention
Your Personal Information will be retained for as long is reasonably necessary for responding to your inquiry, including any ongoing chain of inquiries and follow-up questions; but once we have confirmation that your last inquiry or follow-up question has been answered, we will endeavor to delete your Personal Information within [thirty (30) days]. Please note that if you purchase LGE’s products or subscribe to LGE’s services related to LGE’s products, we may retain your Personal Information under the terms of use and privacy policy applicable to such additional transaction, which is different from this Privacy Policy. If you have consented to ‘Marketing Services’ below, we will retain your Personal Information as long as you continue to receive marketing information. We will further keep information necessary to protect us from possible legal claims, such as information relating to a contract, for the lifetime of the contract and up to seven years thereafter. Please contact us for further details of applicable retention periods.

We may anonymize your Personal Information and retain this information for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

10. Security
We use reasonable technical and organizational methods to safeguard your information, for example, by using SSL encryption and firewalls to protect against unauthorized access, disclosure, alteration or destruction. However, please note that this is not a guarantee that such information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

Whilst we will use all reasonable efforts to safeguard your information, you acknowledge that data transmissions over the internet cannot be guaranteed to be 100% secure and for this reason we cannot guarantee the security or integrity of any Personal Information that is transferred from you or to you via the internet, and any information you transfer to us is done at your own risk.

If we learn of a security systems breach with a high risk of harm to you, we will notify you with the relevant information; while LGE will implement appropriate protective measures, you may need to take protective measures of your own or cooperate with LGE to ensure the safety of your Personal Information. Please make sure to read the security notification LGE sends you in order to protect your Personal Information.

11. Protecting the Privacy of Minors under the age of majority
LGE does not knowingly collect or solicit Personal Information from children defined in any applicable laws or knowingly allow such persons to submit Personal Information. If you are under the age of majority please do not send us any Personal Information unless you have your parent’s or guardian’s permission. Also, if we become aware we have collected personal information from children defined in any applicable laws, and do not have a parent or guardian’s consent, we will promptly delete such personal information.

12. Your California Privacy Policy
A. Right to Access
As a California resident, you may, subject to verification procedures, request details from us about the information we have collected from and about you over the past 12 months, including:

• The categories of personal information we have collected about you, including Basic Identifiers, Protected Characteristics, Commercial Information and Records, Internet and Other Network Activity, Geolocation Data, Professional and Employment Information, Education Information, and Inferences about Trends and Preferences, as well as any other information you may choose to send us;
• The categories of sources from which the personal information was collected;
• The business or commercial purpose(s) for our collection or sale of your personal information;
• The categories of third parties with whom we have shared your personal information;
• The specific pieces of personal information we have collected about you; and
• The categories of personal information we sell or disclose for a business purpose.


If you wish to request such access to your personal information, please contact us at caprivacy@lge.com (1-833-660-0245).

B. Right to Delete
As a California resident, you may, subject to verification procedures, request that we delete any personal information we have collected about you subject to a number of exceptions, including, but not limited to, if the information is necessary for us or our service provider to:

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Fix our system in the case of a bug;
• Protect the free speech rights of your or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.


If you wish to request such access to your personal information, please contact us at caprivacy@lge.com (1-833-660-0245). You may also delete certain data on your own, for example, by removing data from your online account or deleting comments, reviews, or other postings you have made.

C. Timing and Format of our Response to Access or Deletion Requests
We endeavor to respond to a verifiable request for access or deletion within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

D. Do Not Sell My Personal Information (Right to “Opt-Out”)
As a California resident, you have the right to “opt out,” or to direct us to stop selling or otherwise sharing your personal information with third parties in exchange for monetary or other valuable consideration.

When you opt-out, LGE will cause third-party providers to cease any sale of the personal information they receive from us. Opting out will stop us from selling or sharing your personal information for valuable consideration until you opt back in. If you opt-out, you may still continue to see advertisements that are contextual or not driven by individual device or user data. Opting out will still allow you to access and use features on the Sites.

E. Verification Procedures
When you submit a request to access or delete your information, we will need to verify your identity before addressing and fulfilling your request. We will do so in accordance with applicable law.

F. Freedom from Discrimination
As a California resident, you may appoint an authorized agent to exercise your rights on your behalf. In order for us to honor a request made by your agent, you must submit proof of your written authorization of the agent.

G. Freedom from Discrimination
You have a right not to receive discriminatory treatment by LGE for exercising your California privacy rights.

H. Sharing for Direct Marketing Purposes (“Shine the Light”)
California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. We may share certain “personal information” about you with third parties for those third parties’ direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If applicable, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2019 will receive information about 2018 sharing activities).

To make such a request, please provide sufficient information for us to determine whether this applies to you, attest to the fact that you are a California resident, and provide a current California address for our response. You may make this request by contacting us at caprivacy@lge.com:

Please note that we are only required to respond to one request per California resident each year.

13. Changes to this Privacy Policy
We reserve the right to change this Privacy Policy from time to time in our sole discretion. When we do, we will also revise the "Last Updated" date at the bottom of this Privacy Policy and where appropriate, this may be communicated to you via email. Please check back frequently to see any updates or changes to our Privacy Policy.

[Last updated: [4th of Mar.], 2020]
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