Privacy is always the first priority of KEF in order to protect our customer’s rights and data. This Privacy Policy (“Policy”) explains the processing of Personal Data and Non-Personal Data that relates to each individual in connection to KEF’s environment, which includes but not limited to our products, website, mobile application, store visits, interaction on social media platform, SMS and physical locations, such as an exhibition booth and store (“KEF’s Environment” or “KEF’s Resources”). These environments are managed by GP Acoustics International Limited and/or together with its subsidiaries and affiliated companies (collectively referred to below as “KEF”, “we”, “us” or “our”) as listed under Section 15 of this Policy.

KEF is committed to compliance with the applicable regulatory and legal requirements in which we operate, and when we collect, use, hold and process Personal Data. This Policy sets out the general terms of Personal Data handling while additional terms for access and usage for specific regions are listed in Section 16 of this Policy.

As an on-going practice, we will continuously review our Privacy Policy and monitor our privacy controls to protect the Personal Data with the assurance of data subject right. Therefore, we reserve the right to revise and change the provisions of this Policy at any time. Customers are advised to review this Policy from time to time. We will also provide notification through possible channels to the applicable customers on the changes that have been made on the Policy with the option to withdraw their consent to the Privacy Policy. 

You may exercise your right to know whether we hold your Personal Data, what type of Personal Data is held and request access to, correction of, or deletion of your Personal Data held by us. We will provide you with a response in accordance with applicable data protection law. KEF may refuse to provide such information in limited circumstances under applicable local law. You may send such requests or inquiries to our Data Manager at data@kef.com if you wish to:   

• have access to your Personal Data, for which we may charge a reasonable fee for complying with your request;
• correct any Personal Data relating to you which is inaccurate;
• remove any Personal Data relating to you;
• withdraw your consent to the use of your Personal Data by us (however, withdrawing consent may affect your access and use of our App and/or Website); or
• restrict or object to processing of your Personal Data by us,

You also have the right to lodge a complaint before your local data privacy authority should we violate applicable data privacy laws(s) in our processing of your personal information.

“Personal Data” is any information that can identify a person individually and includes, without limitation, name, e-mail and/or postal address, telephone number, username, password, date of birth, gender, credit card number, billing and/or other contact information. KEF will only process, collect and store your Personal Data under any of the following reasonable justifications:

• Consent: You have given explicit consent for KEF to process, collect and store your Personal Data for the specified purpose.
• Performance of a Contract: KEF process, collect and store your Personal Data for the purpose of entering or performing a contract with you given that you have accepted the contract and willingly provided these Personal Data to us.
• Legitimate Interest: It is necessary for KEF to process, collect and store your Personal Data to reasonably maintain the interest of KEF and any associated third party, under the circumstances that it does not override your fundamental rights and freedoms. 
• Compliance with Legal Obligation: It is necessary for KEF to process, collect and store your Personal Data to fulfil legal/regulatory obligations of countries that KEF operates.

The following are the most common situations when we may collect and store your Personal Data, and by using the Website and/or App and/or visiting KEF Physical Locations, you agree to us collecting your Personal Data through the following means, although these means are not exhaustive: 

•  registration to use the App and/or Website;
• browsing, using, purchasing products, signing-up for KEF’s newsletters through the App and/or Website and/or otherwise using KEF’s services through the App and/or Website
• visiting KEF’s point of sale locations and marketing campaigns;
• visiting KEF’s social media platforms, including but not limited to KEF’s Website, Facebook or Instagram pages and creating user-generated content on those platforms (such as comments, discussions, likes, private messages, etc.);
• visiting KEF’s social media platforms to communicate with us on any enquiries;
• submission of surveys and/or event questionnaires (e.g. via webforms on the Website) and entry into sales promotions;
• registration for product warranties and maintenance services;
• requests for customer service or other assistance on the App and/or Website;
•  contacting us by email, post, fax or any other means of communication. 

For any collection of personal data from a third-party, KEF will endeavour to comply with the privacy policies of the corresponding third-party’s privacy policy and the applicable local regulatory requirement. This includes the personal data collected from social media platforms, and KEF will only collect and store such Personal Data that we are permitted to collect by these social media platforms.

“Non-Personal Data” includes aggregated and/or automatic information collected about use of KEF’s resources or about a group or category of users, which individual identities with its identifiable information have been stored separately, and replaced by an automatically generated ID (“KEF ID”) to create KEF ID profiles for further processing. Reasonable efforts have been committed by KEF to govern the usage and transfer of KEF ID profiles, such as access control, encryption and contractual agreements, to prevent individuals from being identified from these non-Personal Data. KEF commits with the best effort to avoid identifying any individual from the collected non-personal unless at KEF’s legitimate interest or data subject’s benefit to do so. We and/or our data processors (which process non-personally identifiable data on our behalf) may also keep non-Personal Data to form activity logs and diagnostic data may be automatically collected when you are using KEF’s resources and products. It may be mandatory for us to collect some of the non-Personal Data to ensure the proper functioning of these resources and products.

As these are considered as non-Personal Data, to the extent that the laws of certain jurisdictions allow, this Policy should not restrict or limit our collection, use and provision of non-Personal Data. To provide transparent handling and processing of data that may relate to a data subject, the following illustrates the processing of non-Personal Data.

We also intend to use your Personal Data in direct marketing, but we will not do so without obtaining your prior consent. Your explicit consent on direct marketing is mandatory for us to deliver any marketing material to you. 

Our direct marketing activities in general are defined as KEF Updates, which may include communication by post, telephone, email, SMS, App notifications and/or other mobile communication applications (such as WhatsApp, WeChat and/or Line) about KEF’s environment as well as our products, services, newsletters, events, contests, competitions, surveys, offers and promotions connected with the audio and/or electronic goods and services provided by us.

When you first register for an account on the Website and/or the App or when you first provide your personal information to us at KEF Physical Locations or through other means of communication such as email, if you do not want your Personal Data to be used for direct marketing purposes, please do not tick the checkbox which allows you to opt into our newsletters and/or direct marketing activities.

You may also change your mind and request that we stop sending you direct marketing materials/communications or to cease using or providing your Personal Data for any direct marketing purposes at any time by following the opt-out / unsubscribe facility provided in our marketing materials or by emailing us at data@kef.com. We will, at no cost to you, act on your request within 7 working days in order to ensure that you are not included in future direct marketing promotions.

When accessing KEF’s resources, IP address location tracking or other means of technologies might be used to determine and collect information about the current location of your device, given that if the location tracking feature is enabled on the device. This geolocation data is collected anonymously in a form that does not personally identify you. The current location of your device will be stored locally on your device which will be used by the App and/or Website to serve you certain contents tied to the relevant location, and facilitate the initial setup of KEF’s products. The basis of your location is being collected include certain regulatory requirement in specific jurisdiction or consider as mandatory to provide KEF’s services for product usage. 

If you elect to have your location-based searches saved to your history, we will store such information on our servers. In addition, only generic location such as country or region is being collected with the purpose as illustrated below:  

• Customise and provide relevant information that relates to you. 
• Enhance your browsing experience.
• Deliver advertisements according to your region.  
• Address your enquiry and provide customer support through our regional representative. 

A customer may always choose to restrict the sharing of location data by disabling the location tracking feature from the device and/or browser at any time. Disabling the location tracking feature will not affect your access or use of KEF’s resources, but it may deliver information and contents that are less relevant to your location.

Cookies are small text files that are stored on your mobile device when you access the App or Website, and they record your preferences and actions when accessing the same. We use cookies to track the use of and the browsing behavior on the App and/or Website, as well as to monitor traffic, to maintain and improve the App, and to customise, enhance and optimise your browsing experience on the App and/or Website to make it easier and/or more convenient for your use. For details of how we use cookies, please refer to our Cookie Policy. 

We intend to collect your usage behavior for the purpose of automatic processing including but not limited to profiling and automatic decision making. Automatic processing is used to optimise KEF’s service and product offering, and improve your experience as a customer. 

When you use our App and/or Website, we may collect your usage behaviour based on your engagement with various elements, such as subscription to customer services and purchase frequency, and create usage profiles that do not contain any individual identities with its identifiable information. Analysed results of your usage behaviour will help shape the way of us providing you with a more customised online experience.   

KEF values your own preference on how you want your service to be customised. You may request us to cease using your usage behavior for automatic processing by emailing us at data@kef.com. We will, at no cost to you, act on your request within 7 working days.  

KEF is committed to take every measure to keep your Personal Data secure and confidential. KEF does not exchange, nor transfer Personal Data with third parties for any purpose, including direct marketing. Share, sell, transfer, provide, rent or trade of Personal Data is not permitted unless we have obtained your consent or with legal basis in accordance with the requirements under the applicable law, except to carry out contractual obligations, fulfill purchase orders, by our legitimate   interest, under the condition of KEF that all or substantially all of our assets are sold/ transferred to another party, or requested by government agencies.

With the consideration of justified and legal grounds, we may transfer your Personal Data from/to third parties and will only seek your consent to do so if this is required by your local law. These parties will only process your Personal Data for and on our behalf as set out in this Policy or required by the local regulatory requirement and will not process your Personal Data for their own purposes. They owe a duty of confidentiality to us and we require them to contractually agree to hold, process and use your Personal Data in compliance with this Policy and in accordance with our instructions. In any circumstances the third parties act as a controller of the personal data, the user should be aware that respective privacy policy of the third parties should be referred. 

Although the third parties should only process Personal Data as set out in Section 3,  additional processing and collection of Personal Data may take place if the customer  is subscribing or using further services from these third parties where KEF is not responsible or liable for these activities as we have no control over how the third party will use, process or share your Personal Data. Hence, if a user is using the third-party in any means other than the purpose as stated in Section 3, it is highly suggested to read and agree their respective privacy policies before connecting with any Third Party Services from KEF. 

We do not knowingly collect personal information from children aged under 15 or individuals under the age of majority in the country that they live. If you believe that we have inadvertently collected such information, please contact us at data@kef.com so that we can promptly obtain parental consent or remove the information.

We take reasonable administrative, physical and electronic measures designed to safeguard and protect your information from loss, destruction, misuse, unauthorised access, disclosure and alteration. Physical records of your Personal Data will be stored in locked cabinets in a secure location with restricted access. Electronic copies of your Personal Data will be stored on servers maintained by us and/or our third party service providers, which are situated in secure locations and protected by adequate data security measures. Your Personal Data will be stored in an encrypted form behind a firewall designed to block access from outside our network.

While we try our best to safeguard your Personal Data once we receive it, no security or encryption method can be guaranteed to protect information from hackers or human error, and no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

Our Website and/or App may contain links to third party websites. These links are provided solely as a convenience. KEF does not endorse any third party websites. Access to any other website through any links provided on our Website and/or App is at your own risk. KEF is not responsible for the content of any such websites or the accuracy or reliability of any information, data or other contents of those websites. We encourage you to consult the privacy policies of any third party websites that you visit.

We will not keep your Personal Data for longer than necessary to fulfil the purposes and any directly-related purposes for which such Personal Data is collected. We will take into account any financial regulations and legal obligations that require us to retain the Personal Data for a certain period of time as well as the duration of your use of our Website and App. We will also keep your Personal Data as long as necessary for the purpose of KEF’s membership and at your own interest.  If you wish to de-register from our Website and/or App, amend, update, remove your Personal Data, or request that we no longer use your Personal Data to provide you with the information or services you have requested, please contact us at data@kef.com.

The information that we collect may be processed globally and transferred internationally. The countries involved in Personal Data transfer, usually in a form of information processing facilities, includes EEA (including an EU Member State), the United Kingdom, the United States, Hong Kong, Singapore, Taiwan, Japan and Dubai as well as any country where we and KEF’s affiliates or subsidiaries. In addition, the processing location also include the service providers and other third parties with whom KEF may share information (as described in Section 9) may be based outside of the country of your location. Unless stated by the regional terms in this Policy, if you are accessing the KEF’s resources or by providing us with your Personal Data, you consent to the transfer of your Personal Data to our facilities outside of the country in which you have provided your Personal Data to us. 

The Personal Data protection laws of those countries where your Personal Data are stored might not be as stringent or comprehensive as those in your country, but we will take all reasonable steps to ensure the protection of your privacy and will only collect and use your Personal Data for the purposes which are set out in this Policy. In any case, KEF will implement appropriate contractual measures, such as standard data protection clauses and data transfer agreement, to ensure that the relevant KEF entities and third parties provide an adequate level of protection to your Personal Data as set out in this Policy and as required by applicable local law.

If you register an account on our Website and/or App, you are entirely responsible for ensuring and protecting the security and confidentiality of your password and account. You are also entirely responsible for any and all activities that occur under your account and we shall not be held liable for any claims, loss or damage resulting from a breach of the foregoing or any unauthorised use of your account.

This Policy applies to the collection, use, holding and processing of your Personal Data by us, which includes the following entities:

• GP Acoustics International Limited
• GP Acoustics GmbH 
• GP Acoustics (China) Limited
• GP Acoustics (HK) Limited 
• GP Acoustics (Taiwan) Limited 
• GP Acoustics (UK) Limited 
• GP Acoustics (US) Inc. 
• KEF Japan Inc.

If you have any questions or complaints, or if you wish to access or correct your Personal Data or withdraw your consent to the use of your Personal Data held by us, or exercise any of your other rights, please contact our Data Manager at data@kef.com. You may also contact us by post via any one of the following addresses closest to you:-

GP Acoustics International Limited
9/F, Building 12W, Hong Kong Science Park, New Territories, Hong Kong

GP Acoustics GmbH
Kruppstraße 82-100, 45145 Essen, Germany

GP Acoustics (UK) Limited
Eccleston Road, Tovil, Maidstone, Kent ME15 6QP, England, United Kingdom

Please refer to this Section of the Policy which applies in conjunction with the remaining Sections of the Policy if you are accessing and using KEF’s Environment within the following listed regions:

• the European Economic Area (“EEA”) and the United Kingdom; 
• the Republic of Korea;