Privacy Policy
Sharp Consumer Electronics Poland sp. z o.o.
Last updated: March 2025
1. Introduction
At Sharp Consumer Electronics Poland sp. z o.o. (“we”, “us”, “Sharp”), we take your privacy seriously. This privacy policy outlines our role as a data controller, the data we collect on our websites, how and why we collect it, and your rights to control that data.
As a responsible organization, we have implemented numerous technical and organizational measures to ensure the highest level of protection for any personal data (e.g., name, address, email, phone number) processed through this website. These measures comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”), as well as the data protection regulations of respective countries. However, internet-based data transmissions may have inherent security gaps, so absolute protection cannot be guaranteed. Therefore, every data subject is free to transfer personal data to us via alternative means, such as by telephone.
2. Name and address of the data controller
The data controller for the purposes of the GDPR and other applicable data protection regulations is:
Sharp Consumer Electronics Poland sp. z o.o.
Ostaszewo 57B
87-148 Łysomice
Poland
Website: www.sharpconsumer.com
As a data controller, we are responsible for how we store and use personal data and ensure its security. We are also responsible for responding to enquiries about the processing of personal data. If you have any questions about how we process your personal data, please contact us at the address as below:
Data Protection Officer
The Data Protection Officer is Mr. Pawel Czapnik
Email: iod.pl@sharpconsumer.eu
You can contact the Data Protection Officer directly at any time whenever you have questions or suggestions about data protection.
3. Collection of personal data and general information
We will collect personal data when you purchase products or services from us, complete forms we provide to you, make a report or notification about our products or services, contact us by phone, email or communicate with us directly in some other way.
Depending on the communication channel used, we collect the following types of personal data from you:
Contact details: information that allows us to contact you such as your name, email address, telephone number and addresses associated with your account, order or query.
Personal data in reports and notifications you submit to us: if you submit information to us about our products and services through our website we will collect any personal data you include, e.g. in scans of purchase documents.
Records of your discussions with us: when you contact us, whether by email or phone, we will keep a record of this. We also record calls with our customer support team so that we can keep up with training and ensure a good quality of service for you as well as safeguarding evidence.
How you use our website: Our website collects a series of general data and information when a user or automated system calls up the website. This general data is stored in the server log files. We may collect (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
We do not draw any conclusions about the user from the website data. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisements, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the controller analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
4. Legal basis for the processing
We limit the collection of personal data to only what is absolutely necessary to fulfill our legal or business obligations. In some cases, the provision of personal data may be partially required by law (e.g., tax regulations), necessary for negotiating or concluding a contract, or essential for providing a service. Failure to provide the required personal data may result in the inability to offer or finalize the contract or service. Therefore, processing certain personal data is considered to be in both the data subject’s and our legitimate interests.
Below, we describe:
- The purposes for which we collect your personal data;
- The categories of personal data we process for each purpose;
- The legal basis that permits us to process your personal data; and
- The duration for which we will retain your personal data.
| Purpose of processing | Categories of data processed | Legal basis for processing | Data retention period |
| Providing you with services, initiating and implementing the partnership | Personal data you have provided to us when purchasing a product or initiating contact, e.g. to start a relationship. | Actions taken to conclude or perform a contract. | During the term of the contract and the limitation period for any claims. |
| Compliance with applicable legislation. | Within legal deadlines, e.g. for tax purposes. | ||
| Providing you with products | Contact details. | Performance of the contract between us, compliance with applicable laws. | During the term of the contract and the limitation period for any claims. |
| Answer to your questions or complaints | Depending on how they were routed: data disclosed in an email in which an enquiry or complaint was made, data provided during a telephone call via a helpline. | Legitimate interest of the controller (business purposes – customer service). | Until the handling of the question/complaint is completed. |
| Fulfilment of concluded contracts and legal obligations. | Within the limitation period for all claims. | ||
| In the case of a helpline, consent to the recording of the call and the data disclosed during the call. | With regard to the hotline – in accordance with the administrator’s internal regulations. | ||
| Fraud investigation and debt recovery | Contact details of contractual parties / service recipients, details of purchases made. | Legitimate interest of the controller (business purposes – customer service). Fulfilment of concluded contracts and legal obligations (retention of accounting records). | Within the limitation period for all claims. |
| Maintaining and improving the quality of our products and services | All personal data that we collect | Legitimate interest of the controller (business purposes – quality management). | Within the limitation period for all claims. |
| Direct marketing | Contact details | User’s consent to receive certain content electronically. Provision of services related to the maintenance and operation of the newsletter mailing service. | Until you withdraw your consent. |
| Implementation of promotional campaigns at SHARP | The data required to register a promotion user in the dedicated registration form. | To carry out a promotional campaign (legitimate interest of the administrator. | For the duration of the promotional action and the assertion of any claims. |
| Implementation of contracts and promotional regulations and related legislation. | Until such time as is required by tax law and the settlement of the promotional campaign. | ||
| Consent to process an additional range of data. | Until you withdraw your consent. |
Before you provide personal data, you can contact our Data Protection Officer who can clarify whether the provision of the personal data is required by law or contract, whether there is any obligation to provide the personal data, and the consequences of non-provision.
5. Your consent
Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make processing which we undertook before you withdrew your consent unlawful.
You can withdraw your consent by contacting our employee who served you when you gave your consent or the Data Protection Officer, whose details are provided in section 2. Any request that concerns your rights will be dealt with within the required timeframe.
6. How we share your information
We share your personal information with the following:
- Our staff: Your personal data will be accessed by our staff but only where this is necessary for their job role.
- Companies within our corporate group: For the purpose of providing services to you.
- Partners and Dealers: For the purpose of answering queries you have about products and services not directly provided by Sharp.
- Delivery companies: To deliver products that you have ordered from us.
- Credit reference agencies: So that we can verify your identity, and to provide information on missed or late payments or other activity which may affect your credit score.
- External service providers and advisors: Such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal or financial advice and help us deliver our services to you.
- Law enforcement and regulatory agencies: If we are required to disclose or share your personal data to comply with any legal obligation or any regulatory requirement.
- The government or our regulators: Where we are required to do so by law or to assist with their investigations or initiatives.
- Police and law enforcement: To assist with investigation and prevention of crime.
7. Changes of business ownership and control
We may transfer or assign any of the information described in this privacy policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
Where we are involved in a merger, acquisition or sales of assets, we will always process your data respecting your rights and freedoms and subject to confidentiality agreements between the parties.
8. Transfer of personal data
We sometimes transfer personal data to third parties, for example, providers of CRM software for sales or service purposes, providers of marketing automation software, and agencies (e.g., marketing and recruitment agencies) based in the USA outside the EU and the European Economic Area (“EEA”).
To ensure that your personal data is secure, we will only transfer your information to any countries outside of the EU or EEA in accordance with the GDPR. This requires that one of the following conditions applies:
- the European Commission has decided that the country provides an adequate level of protection for your personal data;
- the transfer is subject to a legally binding and enforceable commitment on the recipient to protect the personal data;
- the transfer is made subject to binding corporate rules; or
- the transfer is based on a derogation from the GDPR restrictions on transferring personal data outside of the EU.
- Or standard data protection clauses adopted by the EU Commission
9. Cookies
Our webpages use “cookies”. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. These contain a so-called cookie ID, which is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the user from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, we can provide our website users with more relevant services and content that would not be possible without the cookie setting. Find out more information about our Cookie Policy.
10. Profiling
Profiling involves the analysis of personal data (e.g. digital behaviour such as pages visited, links clicked, downloads) in an way, to identify or predict behaviour in website users.
We do not currently use profiling on our website. If we do start profiling, we will notify you.
11. Registration and website enquiry forms
Users can also submit personal information by submitting a general enquiry (e.g. a sales or service enquiry) via a form. In this case, the personal data transmitted is automatically forwarded to the recipient on our side by e-mail. Such personal data is transmitted on a voluntary basis and is stored for the purpose of contacting the data subject to fulfil their enquiry. Additionally, consent can sometimes also be given on the forms for other types of communication e.g. marketing. This consent is freely given via a double opt-in mechanism (please see section 12 below).
This data may also be passed on to Sharp group companies and partners to fulfil the enquiry if it relates to a different area of the business than the one the user selected when submitting the enquiry. It may also be passed to third parties for example Sales CRM systems, Service CRM systems or Marketing Automation platforms, however in this case we remain the data controller.
12. Sales and marketing communications
As a Sharp website user you also have the opportunity to provide personal data to register for specific sales and marketing programs, for example to express interest in a product or service, subscribe to email newsletters, or register for events or allow a customer satisfaction survey to be conducted. We inform our users, customers and business partners regularly about our products, services and promotions through sales and marketing communications. Users are given the option to consent to receiving these communications via various channels, and are given the option to opt-out of these communications at every practical opportunity. Service communications for existing customers (such as billing/ contract information) are considered legitimate interest and as such these communications form part of providing the service. In the case of marketing communications they may only be received by the data subject if (1) they have a valid e-mail address, phone number or postal address and (2) they register to receive marketing communication.
During registration for marketing communications, we store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for a marketing communications program will only be used to send our specific communication and the requested commercial information, unless otherwise stated in the consent form. We use third party platforms such as marketing automation providers and Sales CRM systems to process this data in some cases. All third party providers have GDPR compliant data protection agreements with Sharp Consumer Electronics Poland Sp. z o. o. which allows us to exercise control over data processing. The consent to the marketing communications program or storage may be terminated by the data subject at any time. Each communication we send contains a link to remove consent (in the case of electronic communications), alternatively you can remove consent by contacting the Data Protection Officer, whose details are set out in section 2.
13. Tracking & analytics
Marketing tracking
Our marketing communications can sometimes contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in e-mails, landing pages etc., which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the controller may see if and when a marketing communication and specific content was viewed or downloaded by a data subject, and may use this information to re-target users with more specific/ relevant content the next time they visit their digital properties. You can remove your consent to this either through the consent management link in each electronic communication.
Google Analytics
We use Google Analytics to track, report and optimise our website performance (e.g. number of visitors, where they came from, what pages they visited). This is tracked by us at an aggregate level and not on an individual level.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
We use Google Analytics with the anonymizer function (the application “_gat. _anonymizeIp”). This means the IP address of the user is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
When a user accesses our site from a Google search (whether through an organic search listing or a paid-for digital advertisement), Google Analytics places a cookie on the user’s computer/ device. This enables Google to track what happens after they click on the link and hit our website. In the case of paid-for digital advertising, we pay Google based upon the number of clicks or impressions, so this also ensures accurate reporting and billing, and helps with the prevention of click-fraud. Google gathers personal information from the user, such as the IP address, access time and location. With each visit to our site, such personal data will be transmitted to Google in the United States of America. This personal data may be stored by Google in the United States of America, and they may pass this on to third parties.
14. Your rights in relation to data processing
You have the following rights to control your data according to GDPR principles:
- Right of information – this means the ability to find out from us if we are processing data about you.
- Right of access – this means the ability to see what data is being held about you (also called Subject Access Request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Right of rectification – this means the ability to change or alter any incomplete or inaccurate data we hold about you.
- Right to erasure – this means the ability to be removed from our databases/ systems where: there is no good reason for us continuing to process it, you withdraw your consent, we are unlawfully holding your personal data or we should erase your data to comply with applicable EU law. You have a right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
- Right to restriction of processing – this means the ability to limit or suspend what personal data is processed.
- Right to data portability – this means the ability to move the data to another supplier.
- Right to object – this means the ability to prevent your personal data being processed in a certain way or remove consent.
- Right to lodge a complaint – everyone has the right to lodge a complaint with a supervisory authority about the way their personal data are processed.
To exercise your rights to any of the above, please contact us via email at: iod.pl@sharpconsumer.eu
Alternatively, there are other actions you can take as a user of our websites to limit the amount of personal data we may process:
Do not consent or remove consent:
- Where we capture personal data on forms, we will be introducing double opt-in boxes so that you can tell us if you want to hear from us for marketing purposes. If you don’t consent, you won’t hear from us, unless it’s related to the service we provide you.
- Most marketing communications, especially electronic communications, where practical will provide the ability to opt-out of further marketing communications.
Prevent or remove web tracking:
- Access our website using an anonymous/ incognito browser window
- Deny the setting of cookies by adjusting your web browser settings:
o Cookie settings in Internet Explorer
o Cookie settings in Firefox
o Cookie settings in Chrome
o Cookie settings in Safari web and iOS.
- Object to the collection of data by Google Analytics
Download and install a browser add-on: https://tools.google.com/dlpage/gaoptout
This tells Google Analytics (through JavaScript), that any data may not be transmitted to Google Analytics.
More information: https://www.google.com/intl/en/policies/privacy/ http://www.google.com/analytics/terms/us.html https://www.google.com/analytics/
We will always aim to help you when you wish to exercise your rights but in some instances we may have lawful grounds to reject your request.
We will investigate any request you make without undue delay and in any event within one month of receipt of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
In the event that we decide to not take action on the request, we will inform you of the reasons for not taking action.
Lodging a complaint with the supervisory authority: if you do not agree with a decision we make in relation to a rights request or believe that we are in breach of applicable data protection laws, then you can lodge a complaint with a data protection supervisory authority in the EU. You can contact the Data Protection Supervision Authority for Poland UODO using the contact details on the website https://uodo.gov.pl/
15. Updates to this policy
We may update this privacy policy periodically to reflect changes in how we process personal data (e.g., if we implement new systems or processes that involve new uses of personal data) or to clarify information provided in this notice. Any changes will comply with applicable data protection laws.
We recommend checking this policy for updates from time to time. When legally required, we will notify you directly about changes to this policy or how we use your personal data.