ONE-KEY™ App and Inventory Management Platform Website
Milwaukee Electric Tool Corporation (“we” or “us” or “our”) is committed to protecting and respecting your privacy.
For the purpose of applicable data protection laws (including the General Data Protection Regulation), the Data Controller of any personal data that we may collect, process and hold about you is Milwaukee Electric Tool Corporation, whose registered address is 13135 West Lisbon Road, Brookfield, Wisconsin 53005, United States.
Techtronic Industries UK Ltd
Unit 3 Globeside Business Park
Fieldhouse Lane, Marlow SL7 1HZ
As we are based outside of Europe, we are required to appoint a representative within Europe who you can also contact in addition to us about your personal data. Our European representative is Techtronic Industries UK Ltd who can be contacted in the following ways:
Techtronic Industries UK Ltd
Unit 3 Globeside Business Park
Fieldhouse Lane, Marlow SL7 1HZ
- INFORMATION WE COLLECT ABOUT YOU
The personal data that we collect from or about you includes the following:
- E-mail address
- Phone number
- Personal description and photographs
- Information about how, when and how frequently, you use your ONE-KEY™ Tools
- Information about where your ONE-KEY™ Tools have been used (if you utilize that service in the ONE-KEY™ App)
- If you have used the ONE-KEY™ App on a mobile device, we may collect your mobile device ID if you use certain features (such as Tool Reporting)
- Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, device types, operating system
- Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for or purchased, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse the website
- HOW WE COLLECT INFORMATION ABOUT YOU
We may collect information about you in a variety of ways including when you:
- create an account with us
- access our website or our ONE-KEY™ App
- sign up to our newsletter
- register your ONE-KEY™ Tool with us or register your tools for extended warranty
- contact our customer services team
- enter one of our competitions or promotions or fill in a survey
- engage with us on social media (for example by mentioning/tagging us or by contacting us directly)
In addition, if you use the inventory management functions of the ONE-KEY™ App, the ONE-KEY™ App will automatically collect data from your ONE-KEY™ Tools that are registered to your account which will include:
- tool identification data (e.g. serial ID)
- tool usage data (e.g. date/time of use begin and end)
- tool location data (if you (or anyone else that uses the ONE-KEY™ App) has Bluetooth enabled, if your ONE-KEY™ Tool is in Bluetooth reach of their device, we use this information to help identify the location of your ONE-KEY™ Tool. Please note, any personal data that we collect about you (or any third party) with regards to your location (e.g. if you or an employee is with your ONE-KEY™ Tool) is ancillary to our purpose for collecting this location data to help you identify the location of your ONE-KEY™ Tool. We track your ONE-KEY™ Tools, not you!
- HOW DO WE USE YOUR PERSONAL DATA AND WHAT ARE OUR JUSTIFICATIONS FOR DOING SO?
How and why we use your personal data
What is our legal justification for processing your personal data
To provide you with the information, products and services that you request or purchase from us (i.e. to complete certain tasks, processes, and to communicate with you regarding those products and services that you purchase or request from us and respond to your questions and comments
We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order for products and services or your use of the ONE-KEY™ App.
Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
When you use our ONE-KEY™ App, to help provide you with the services that you have requested from us via the ONE-KEY™ App. This may include location data collected via our ONE-KEY™ Tool inventory management system when you choose to enable Bluetooth and utilize that function.
To measure how satisfied our customers are and provide customer service (including troubleshooting in connection with purchases or your requests for services or when you ask us questions on social media);
We may use your personal data to tell you about relevant products and offers ("marketing").
We can usually only use your personal data to send you marketing messages if we have consent from you to do so or, in some cases, we can rely on a legitimate interest.
To monitor the use of our ONE-KEY™ App and website and ensure that they are presented in the most effective and relevant manner for you and your device.
We have a legitimate interest to ensure that our website and our ONE-KEY™ App work properly and that our products and services are high quality and efficient.
We may record calls you make to us and will use this data for training and quality assurance purposes (where your call is recorded we will tell you in advance).
We use data in this way for a variety of reasons. It may be pursuant to a legal obligation and it is also in our legitimate interests to review call recordings for quality control purposes.
To ensure that the personal and financial information that you provide to us is accurate
In some cases we will use your personal data because it’s necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud or ensuring security of the site) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To detect, investigate, report, and seek to prevent financial crime or other illegal activity
To manage risk for us and our customers.
To fulfil our legal and compliance-related obligations
- HOW DO WE SHARE YOUR PERSONAL DATA?
In order for us to provide our products and services to you, we share your personal data with our trusted third party service providers or our group companies, as detailed below. Whenever we share your personal data, we put safeguards in place which require these other organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes unless you have given us your consent to do so. We will never sell your personal data to a third party.
To fulfil orders for products and services:
We work with a number of trusted service providers who carry out services on our behalf. When you purchase products and services from us, the services provided by these service providers includes website and database hosting and delivery. It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only allowed to use your personal data in order to provide the services to us and for no other purpose.
Other professional services:
We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.
We work with carefully selected third parties, such as our customer database hosting provider, marketing agencies and advertising partners who assist us in providing you with a positive customer experience.
To prevent and detect crime or otherwise comply with laws:
There may be scenarios where we are subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime or fulfil a legal requirement.
International group data processing and group structure:
Our group shares various operations and business processes. We may share your personal data with any member of our group to fulfil our contracted obligations to you, or because it is in our legitimate interests to do so. For example, if you use our services in Europe, your data will be processed by Techtronic Industries ELC GmbH, our group company who host our services in Europe on our behalf.
Similarly, whilst we are based in the USA, we may share your data with a group company of ours local to you in your territory in order to make sure that we only send you marketing about our products and services that are available in your local territory.
We may also share your personal data if the make-up of our group changes in the future, for example:
- We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
- During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private.
- If a change to our group happens, then other parties may use your data in the same way as set out in this notice.
For detailed information on the cookies we use (including Google Analytics) and the purposes for which we use them please see our cookie statement https://www.milwaukeetool.eu/cookies/.
We take the security of your personal data very seriously. We have implemented various strategies, controls, policies and measures to keep your data secure and keep these measures under close review. We use a series of administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft, and unauthorized access, use, and modification.
- TRANSFER OF YOUR DATA OUTSIDE OF EUROPE
We will transfer your personal data outside of the European Economic Area (EEA) in order to process your personal data. We are based in the USA and, although we have European data centres, all of your data may be processed by us in the USA.
We may also need to transfer your personal data outside the EEA where we work with a supplier or third party who processes some of its personal data outside of the EEA.
These countries (including the USA) may not have the same data protection laws as the UK and the EEA and so your personal data may not be subject to the same protections. However, in such cases, we will make sure that any transfer of your personal data to countries outside of the EEA is subject to appropriate safeguards as if it were being processed inside of the EEA and under the guiding principles set out in this privacy notice.
- HOW LONG WILL WE KEEP YOUR PERSONAL DATA
In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this privacy notice. This means that the retention periods will vary according to the type of the data and the reason that we have the data in the first place.
We have a retention policy in place which we keep under review taking into account our reasons for processing your personal data and the legal basis for doing so.
You can deleted your account at any time by contacting our Data Information Manager at either address listed in Section 1 above.
- YOUR RIGHTS
Applicable data protection laws grant you a number of rights in relation to your personal data. You have the right:
- to ask us not to use your personal data for direct marketing purposes;
- to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
- to ask us to correct or update any personal data which is inaccurate;
- to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
- to ask us to temporarily stop using your data if you don't believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
- not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
You also have the right to complain about our use of your personal data. You can contact your local Data Protection Supervisory Authority (a list of local Supervisory Authorities can be accessed here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).