PRIVACY POLICY
Introduction
Welcome to Chauvet’s Privacy Policy. References in this Privacy Policy to “we,” “us,” “our” or“Chauvet” are references to Chauvet & Sons, LLC, a Delaware limited liability company, each of its
affiliated Chauvet companies listed in the “Contact Us” section of our websites, and representativesof the foregoing who are responsible for collecting and processing information or data about you,also known as data controllers.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy will
inform you as to how we look after your personal data when:(a) you visit our websites, use our downloadable software applications or otherwise contact orcommunicate with us;(b) you enter into a contract with us for the purchase of products or services;(c) you contact us for the repair or other service of products; or(d) your employer, or other business you are engaged by or have a commercial relationship with,enters into a contract with us for the purchase of products or services or contacts us for the repair orother service of products and provides us with your contact details.
It also tells you about your privacy rights and how the law protects you. Please refer to the Glossary
below to understand the meaning of certain terms used in this Privacy Policy.
1.

Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your personal data
through:(a) your use of our websites and downloadable software applications or when you otherwise contactus;(b) your entering into a contract with us for the purchase of products and services; and(c) your employer, or other business you are engaged by, entering into a contract with us for thepurchase of products or services and providing us with your contact details.
Our websites and downloadable software applications are not intended for children and we do notknowingly collect data relating to children.
It is important that you read this Privacy Policy, together with any other Privacy Policy or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you, so that you are fully aware of how and why we are using your data. This
Privacy Policy supplements the other notices and is not intended to override them.
Controller
1For data collected in the United Kingdom (UK), Europe, Middle East and Africa, Chauvet Europe
Ltd. is the controller and responsible for your personal data.
For data collected in other territories, Chauvet & Sons, LLC is the controller and responsible for yourpersonal data.
If you have any questions about this Privacy Policy, including any requests to exercise your legal
rights:-If you reside in the UK, Europe, Middle East or Africa, please contact us at
privacy@chauvetlighting.eu or by mail at: Chauvet Europe Ltd., Unit 1C, Brookhill Road
Industrial Estate, Pinxton, Nottingham NG16 6NT United Kingdom (Attention: Data Privacy).

-

If you reside in any other territory, please contact us at privacy@chauvetlighting.com or by mailat: Chauvet & Sons, LLC, 5200 NW 108th Avenue, Sunrise, Florida, 33351 USA (Attention: Data
Privacy).

For data collected where Chauvet Europe Ltd. is the controller, you have the right to make acomplaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority
for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal withyour concerns before you approach the ICO, so please contact us in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on April 18, 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
Third-party links
If you are using our websites, please be aware that it may include links to third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties tocollect or share data about you. We do not control these third-party websites and are notresponsible for their privacy statements. When you leave our website, we encourage you to readthe privacy policy of every website you visit.
2.

The data we collect about you
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymousdata).
We may collect, use, store and transfer different kinds of personal data about you, such as thefollowing:•

Identity Data includes your first, last and maiden name, username and similar identifier.

•Contact Data includes your billing address, trading address, email address and telephone
numbers.

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•Transaction Data includes details about payments to and from you and other details of
products and services you have purchased from us.

•

Technical Data includes your internet protocol (IP) address, login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operating systemand platform and other technology on the devices you use to access our websites.

•

Profile Data includes your username and password, purchases or orders made by you, yourinterests, preferences, feedback and survey responses.

•

Usage Data includes information about how you use our websites, products and services.

•

Marketing and Communications Data includes your preferences in receiving marketing fromus and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website page.
However, if we combine or connect Aggregated Data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as personal data which will be used inaccordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,trade union membership, information about your health and genetic and biometric data). Nor do wecollect any information about criminal convictions and offenses.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you
and you fail to provide that data when requested, we may not be able to perform the contract wehave or are trying to enter into with you (for example, to provide you with products or services). In
this case, we may have to cancel a product or service you have with us, but we will notify you if thisis the case at the time.
3.

How is your personal data collected?
We use different methods to collect data from and about you including through:•Direct interactions. You may give us your Identity and Contact Data by filling in forms on our
websites or by corresponding with us by mail, telephone, email or otherwise. This includes
personal data you provide when you:•request information regarding Chauvet or our products or services;•complete a warranty registration form;•

complete a service request form;•

submit a contract or order form;•

subscribe to newsletters;•

enter a competition, promotion or survey; or3•send us some feedback.

•Automated technologies or interactions. As you interact with our websites or use ourdownloadable software applications, we may automatically collect Technical Data about yourequipment, browsing actions and patterns. We collect this personal data by using cookies,
server logs and other similar technologies. We may also receive Technical Data about you if you
visit other websites employing our cookies. Please see our cookie policy for further details.

•

Third parties or publicly available sources. We may receive personal data about you fromvarious third parties and public sources inside or outside the EU as set out below:•

Technical Data from the following parties:(a) analytics providers;(b) advertising networks; and(c) search information providers;

4.

•

Contact, Financial and Transaction Data from providers of technical, payment and delivery
services;•

Identity and Contact Data from your employer, or the business you are engaged by, to whom
we are providing products or services;•

Identity and Contact Data from data brokers or aggregators; or•

Identity and Contact Data from publicly availably sources, such as State Departments ofCorporations and Companies House.

How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use yourpersonal data in the following circumstances:•

Where we need to perform the contract we are about to enter into, or have entered into, with youor your employer (or other organization you are engaged by);•Where it is necessary for our legitimate interests (or those of a third party) and your interestsand fundamental rights do not override those interests (for example, to send suggestions andrecommendations to you about products or services that may be of interest to you, youremployer or the business you are engaged by); or•

Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process yourpersonal data.
Sometimes we rely on consent as a legal basis for processing your personal data. You have theright to withdraw consent at any time by contacting our data privacy manager using his contact
details above.

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Purposes for which we will use your personal data
Set forth below is a description of the ways we plan to use your personal data and the legal bases
we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful basis depending on thespecific purpose for which we are using your data. Please contact us using the contact details
above if you need details about the specific legal basis we are relying on to process your personal
data where more than one ground has been set out in the table below.
Purpose/Activity

Type of data

Lawful basis for processing including
basis of legitimate interest

To register you, your employer, or
the business you are engaged by,
as a new customer(a) Identity

Necessary for our legitimate interests (toperform a contract with you, youremployer or the business you areengaged by)

To process and deliver an orderby you, your employer or thebusiness you are engaged by,including:(a) Identity(a) Manage payments, fees andcharges(d) Transaction(b) Conduct a credit reference
searchtodeterminecreditworthiness(b) Contact(a) Performance of a contract with you,your employer or the business you areengaged by(b) Contact(c) Financial(e) Marketing andCommunications(b) Necessary for our legitimate interests(to limit the credit available to an amountfor which you, your employer or thebusiness you are engaged by arecreditworthy; and to recover debts due tous)(c) Collect and recover money
owed to us
To manage our relationship withyou, your employer or thebusiness you are engaged bywhich will include:(a) Identity(a) Performance of a contract with you,your employer or the business you areengaged by(a) Notifying about changes to ourterms or Privacy Policy(d) Marketing andCommunications(b) Contact(c) Profile(b) Asking you to leave a review
or take a survey
Toregistertheproductspurchased by you, your employer,or the business you are engagedby, for warranty purposes(a) Identity

To administer and protect ourbusiness and our websites(including troubleshooting, data
analysis,
testing,systemmaintenance, support, reporting(a) Identity(b) Necessary to comply with a legal
obligation(c) Necessary for our legitimate interests(to keep our customer records updated
and to obtain feedback about our products
and services)
Necessary for our legitimate interests (toperform a contract with you, youremployer or the business you areengaged by)(b) Contact(c) Transaction(a) Necessary for our legitimate interests(for running our business, provision ofadministration and IT services, network
security, to prevent fraud and in thecontext of a business reorganisation or(b) Contact(c) Technical5and hosting of data)group restructuring exercise)(b) Necessary to comply with a legal
obligation

To deliver relevant content on our
websitesandemail
advertisements and measure orunderstand the effectiveness of
the advertising we serve(a) Identity

Necessary for our legitimate interests (to
study
how
customers
use
our
products/services, websites and related
content, to develop our marketing strategy
and content and to grow our business)(b) Contact(c) Profile(d) Usage(e) Marketing andCommunications(f) Technical

To use data analytics to improve
our websites, products/services,marketing, customer relationships
and experiences(a) TechnicalTo
makesuggestions
andrecommendations to you about
products, services and events that
may be of interest to you, youremployer or the business you areengaged by(a) Identity

Necessary for our legitimate interests (todefine types of customers for our products
and services, to keep our websites
updated and relevant, to develop ourmarketing strategy and content and togrow our business)(b) Usage(a) Necessary for our legitimate interests(to develop our products/services andgrow our business)(b) Contact(c) Technical(b) Consent(d) Usage(e) Profile(f) Marketing andCommunications

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Marketing
We strive to provide you with choices regarding certain personal data uses, particularly aroundmarketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have:(a) requested information from us;(b) purchased products or services from us (in which case such marketing communications will only
be by email or text and about similar products and services to those you have already purchasedfrom us); or(c) consented;
and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company
for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following
the opt-out links on any marketing message sent to you or by contacting us at any time using thecontact information set out above.
CookiesIf you are visiting our websites, you can set your browser to refuse all or some browser cookies, orto alert you when websites set or access cookies. If you disable or refuse cookies, please note thatsome parts of our websites may become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose iscompatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so.

7Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.
5.

Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out inthe table in paragraph 4 above.
•

External Third Parties as set out in the Glossary•

Third parties to whom we may choose to sell, transfer, or merge parts of our business or ourassets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordancewith the law. We do not allow our third-party service providers to use your personal data for theirown purposes and only permit them to process your personal data for specified purposes and inaccordance with our instructions.
6.

International transfers

6.1

We may share your personal data with companies within the Chauvet Group. This may involve
transferring data collected from users within the UK and Europe outside the European Economic
Area (EEA).

6.2

Whenever we transfer personal data collected from users within the UK and Europe out of the EEA,
we ensure a similar degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:(a)

we will only transfer your personal data to countries that have been deemed to provide anadequate level of protection for personal data by the European Commission; or(b)

by using specific contracts approved by the European Commission which give personal
data the same protection it has in Europe.

6.3

Please contact us if you want further information on the specific mechanism used by us whentransferring your personal data out of the EEA.

7.

Data security
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we use
encryption and limit access to your personal data to those employees, agents, contractors and otherthird parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.

88.

Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature,and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure ofyour personal data, the purposes for which we process your personal data and whether we canachieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further
information.
In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this informationindefinitely without further notice to you.

9.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. See the following sections below to find out more about these rights.
•

Request access to your personal data•

Request correction of your personal data•

Request erasure of your personal data•

Object to processing of your personal data•

Request restriction of processing your personal data•

Request transfer of your personal data•

Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us by telephone, mail or email
using the contact information set out above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive orexcessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up
our response.
9Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In thiscase, we will notify you and keep you updated.
10.

Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our businessto enable us to give you the best service/product and the best and most secure experience. We
make sure we consider and balance any potential impact on you (both positive and negative) andyour rights before we process your personal data for our legitimate interests. We do not use yourpersonal data for activities where our interests are overridden by the impact on you (unless we haveyour consent or are otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on you in respect ofspecific activities by contacting us by telephone, mail or email using the contact information set out
above.
Performance of Contract means processing your data where it is necessary for the performance ofa contract to which you are a party or to take steps at your request before entering into such acontract.
Comply with a legal or regulatory obligation means processing your personal data where it isnecessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means processing your personal data where you have given your unambiguous consent
to our processing of your personal data.
THIRD PARTIES
External Third Parties•

Service providers acting as processors based in the EU and US who provide IT and systemadministration services.

•

Professional advisers acting as joint controllers, including lawyers, bankers, auditors andinsurers based in the UK, EU and US who provide consultancy, banking, legal, insurance andaccounting services.

•

HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the UK, EU and US who require reporting of processing activities in certain
circumstances.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal data we hold about you and to check that we arelawfully processing it.
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Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify theaccuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised your right to object
to processing (see below), where we may have processed your information unlawfully or where weare required to erase your personal data to comply with local law. Note, however, that we may notalways be able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or thoseof a third party) and there is something about your particular situation which makes you want toobject to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate grounds toprocess your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios: (a) if you want us to establish the
data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or (d) you have objected to our use of your data but we need toverify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or athird party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided
consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw yourconsent. If you withdraw your consent, we may not be able to provide certain products or services toyou. We will advise you if this is the case at the time you withdraw your consent.

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