Lelit Consumer Privacy Notice

Effective July 2023

This Privacy Notice explains how information about you is collected, used and disclosed by BRG Appliances Limited and our various affiliates and brands including Lelit, beanz, ChefSteps, ControlFreak, FoodThinker, Baratza, Sage Commercial and others; (collectively “Sage,” “we,” “our” or “us”) when you access or use our website and mobile applications, our connected appliances, and our other products and services (collectively, the “Services”), or when you otherwise interact with us.

We may change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the notice and, in some cases, we may provide you with additional notice such as adding a statement to our homepage or sending you a notification through our Services. We encourage you to review the Privacy Notice whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us. We collect information that you provide directly to us. For example, we collect information when you create an account, make a purchase, enroll in our classes, participate in the interactive areas of our Services, communicate with us via third-party social media sites, participate in our contests, marketing campaigns, sweepstakes and surveys, request customer support, or otherwise communicate with us. The types of information we collect may include:

First and last name
Your postal address(es) for billing and shipping
Your telephone number
Your email address
Purchase information, including lifestyle and food preferences, and grocery lists
Personal details (e.g., date of birth, gender)
Your IP address
Photographs, social media usernames and account ID’s
Feedback and reviews of Sage’s products and any other information you choose to provide.

Whether or not to provide such information is your choice but if you choose not to provide the information we request, you may be unable to purchase products, use our mobile applications or other services, or access certain services, offers and content on our web sites. Also, we may need to contact you via phone, email or mail to address transactional questions or issues such as those specific to your order, even if you have opted to not receive marketing communications from us. In general, you can visit many of our web pages without telling us who you are or revealing any contact information about yourself.

When you make a purchase or a return, we collect information about the transaction, such as the class or product details, the transaction amount and the date of the purchase/return. Note that we do not store or share payment card information, such as credit card numbers. Financial transactions are processed through a variety of third-party processors. The applicable financial processor depends on the type of transaction. To identify a particular processor, please contact us at [email protected]

Information We Collect Automatically. When you access or use our Services or connect your Sage appliance to our Services, we automatically collect information about you and associate it with information that you provide directly to us. For example, we may collect:

Website Log Information: We log information about your use of our website, such as your computer’s operating system, the type of browser you use, access times, pages viewed, your IP address and the web page that referred you to our site.
Using pixel tags and other similar technologies: We also use pixel tags (also known as web beacons and clear GIFs) – tiny graphic images – to tell us what parts of our website you have visited or to measure the effectiveness of any searches you may do on our website. Pixel tags also enable us to send your email in a format you can read and let us know when you have opened an email message from us. Some of our third-party vendors may also use cookies or other online tools including pixel tags on our website. Pixels and cookies may also collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

We may contract with third-party advertising companies to serve ads on our behalf across the internet. To do this, they will collect information about your visits to our website and your interaction with our products and services. They may also use information about your visits to this and other websites to target advertisements. These targeted advertisements may appear on other sites that you visit. This information is collected using a cookie or pixel tag – industry standard technology used by most websites. For more information, see the Advertising and Analytics Services Provided by Others section below

Information Collected related to Your Use of Sage connected appliances. When you first pair your connected appliance to our mobile application, it will automatically link to your Sage account. For information about de-linking your appliance from your Sage account, please see “Your Choices” below. When you connect your appliance to a Wi-Fi network, we collect information about:

the model itself and the network (such as name and connection strength);
your use of the appliance, such as what you are cooking and how you cook, as well as your cooking and recipe preferences;
data from the appliance’s sensors and components;
technical and usage information.
Please see “Use of Information” below to understand how we use this data.
Device Information: When you access or use our mobile sites or apps or connect your Sage connected appliance to our services, we collect information about the mobile phone, tablet or other device you are using, including the hardware model, operating system and version, device identifiers, mobile network information and information about your use of our Services.
Location Information: With your consent, we collect information about your location when you access or use one of our mobile applications or connect your Sage connected appliance to our services. For more details about the collection of location information and the choices you have, please see “Your Choices” below.

By linking information: We may combine personal information with information about your online and in-store transactions and other interactions with us, including your purchases. We may also combine your personal information with information we receive from other sources, such as joint marketing partners, public databases, publicly available pages on social media platforms and other third parties. We use this information for market research purposes and to improve the quality of the Services we offer.

Your Social Sharing: If you choose to engage in social sharing, such as by connecting your social media account to your customer account or by logging into your customer account from your social media account, the social media site may share information with us about your use of their services, including profile information, information about your contacts and content you have viewed or liked. Please refer to the social media site’s privacy settings to control how your information is shared. If you submit any personal information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various tracking technologies, including cookies and web beacons, to collect information about you when you interact with our Services or emails, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve our website and your experience, see which areas and features of our website are popular, and count visits. Web beacons are electronic images that we use on our website and in our emails that help us deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them , please see our Cookie Notice and visit www.aboutcookies.org .

Information we receive from other sources: Sage may receive additional data (e.g., demographic or statistical information) from third parties. This includes business partners, marketing agencies, research or analytics companies, and other third parties that we may assign to you based on your association with certain statistical groups. We use this information in addition to the data we have collected directly about you to derive possible interests, provide you with more relevant Sage brand experiences, and improve Sage products, analytics, and advertising.

Use of Information

We use your information as necessary to provide for various purposes related to the Services , including to:

Provide and deliver the Services you request, manage your accounts, process transactions (such as shipping products and out-of-stock notices), administer warranties, facilitate repairs, and send you related information, including confirmations and receipts, which may also contain information about other Sage offerings;
Send you technical Policies, updates, security alerts, and support and administrative messages;
Respond to your comments, questions and requests, and provide customer service;
Facilitate contests, sweepstakes and promotions, and process and deliver entries and rewards;
Enforce our Terms of Use and Sale or other legal rights;
Detect, investigate and prevent fraudulent transactions and other illegal activities, and protect the rights, property and safety of Sage, its affiliates, you and others;

Likewise, we may use your personal information to allow and facilitate providing you with better care

Maintain, protect and improve our Services;
Communicate with you about products, services, classes, recipes, offers, promotions, events and other news and information we think will be of interest to you (for information about opting out of these communications, see “Your Choices” below);
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve our Services and provide tailored advertisements, content or features to you;
To upload and post your feedbacks and reviews (including your photos and social media usernames);
Further our business purposes and those of our third party service providers, such as, without limitation, troubleshooting, data analysis, audits, security, fraud monitoring and prevention; developing new products, enhancing, improving or modifying products or services; identifying usage trends, determining the effectiveness of promotions; collaborating with our partners; responding to customer service inquiries; and operating and expanding current or future business activities;
Link or combine with information we collect via other sources in accordance with applicable law to help understand your needs and provide you with better service.

Sharing of Information

We may share information on legal basis about you as follows or as otherwise described in this Privacy Notice including, but not limited to, the following circumstances:

With Sage affiliates, which are companies controlled by or under common control with Sage including its parent company, Breville Pty. Ltd in Australia;
With our third-party vendors, consultants and other service providers who need access to such information to carry out work on our behalf, for instance to ship products to you (e.g. DHL), process and administer your payments (e.g. Klarna), sweepstakes/contests (e.g. Stellar), or trouble shooting as well as website hosting, data analysis (e.g. Google), order fulfillment and customer service (e.g. Salesforce), Live Chat or Live Product demonstrations (e.g. Stellar or Concentrix), customer/prescription reviews (e.g. Bazaarvoice), online-meetings (e.g. Teams or Zoom), email delivery and other services;
When you purchase third-party products through us, we share information with the suppliers of such products in order to fulfill your order;
If you connect third-party devices and services to your Sage account or our Services, such as when you choose to interface an appliance or our mobile application with other devices (e.g. with the Amazon Alexa device), your information will be shared with such third parties per your direction and with your consent;
When you sign up for and participate in the interactive areas of our Services, certain information about you will be displayed publicly, such as your name, photos, recipes, and any other information you choose to provide;
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process, safeguarding our legal rights or enforcing our terms of use;
If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Sage or others;
In connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing or acquisition of all or a portion of our business by another company, including in bankruptcy or similar proceedings;
To respond to requests from public and government authorities, including public and government authorities outside your country of residence, or
With your consent or at your instruction.

Anonymized Information

We may share anonymized information that is summarized or derived from information you provide to us. Anonymous information is information that does not include any personally identifiable information.

Social Sharing Features

Our services use plug-ins of social networks ("plugins"). If you use a service that includes plug-ins, information can be transferred directly from your device to the social network provider. We have no influence on the data collected by the plugin. If you are logged in to the social network, a connection can be established between your user account and the use of our service. If you interact with the plugins, for example by clicking on "Like", "Follow" or "Share" or by writing a comment, this information may automatically appear in your profile on the social network. Even if you are not logged in, the plugins may still send your IP address to social networking providers.

When you connect to a social network service on a device that is also used by other people, these other users may be able to see information that is stored or displayed in connection with your profile on the Social Network Service page.

For more information about the social networking providers whose plugins are used in our services ("providers"), see below:

Facebook

Controller: Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, 2 Dublin, Ireland ("Facebook"). For more information, see Facebook's data usage guidelines at https://www.facebook.com/about/privacy/

YouTube

Controller: YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA ("YouTube"). For more information see YouTube's privacy guidelines at https://policies.google.com/privacy

Instagram

Controller: Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram“). For more information see Instagram's privacy policies at https://help.instagram.com/155833707900388

Pinterest

Controller: Pinterest Inc. at 651 Brannan Street, San Francisco, CA 94107, USA. For more information see Pinterest's privacy guidelines at https://policy.pinterest.com/en-gb/privacy-policy

Advertising and Analytics Services Provided by Others

We allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information is used by Sage and our third-party marketing, advertising and analytics vendors on Sage’s behalf to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit https://optout.aboutads.info/.

We also work with third-party social platforms, such as Facebook, to serve ads to you as part of a customized campaign. We also work with third-party social platforms, such as Facebook, to serve ads to you as part of a customized campaign.

Transaction Information

When you make a purchase or a return, we collect information about the transaction, such as the class or product details, the transaction amount and the date of the purchase/return. Note that we do not store payment card information, such as complete credit card or debit card account numbers. Financial transactions are processed through a variety of third party transaction partners, as for example Klarna or Paypal. The applicable financial partner depends on the type of transaction and the identification of that financial partner can be requested by contacting Sage by emailing us at [email protected]

Your Choices

Account Information

You have the ability to access information we hold about you and to update, correct or erase (the extent allowed by applicable law) your account information at any time by logging into your Sage account. Alternatively, you may complete and submit a Data Subject Request Form. If you are a EEA resident, please see “Your Data Subject Rights” below.

De-linking Connected Appliances

Once your connected appliance is paired with your Sage account, you can de-link it at any time by disconnecting it via the settings on your mobile device. Note, however, that certain appliances must be paired with a Sage account in order to have full capabilities. If your appliance has been de-linked from an account, you will need to re-link it to enjoy its features fully.

Location Information

When you first launch some of our mobile applications, access certain features in those mobile applications, or visit one of the pages on our website that collects location information, you may be asked to consent to the collection of location information in order to enable certain features. If you initially consent to our collection of location information, you can later stop this collection by changing the settings on your device. If you do so, certain features of our Services will no longer function.

Promotional Communications from Sage

You may opt out of receiving promotional communications from Sage at any time by following the instructions in those communications. Even if you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we will send promotional and non-promotional push notifications or alerts to your mobile device. You can elect to stop receiving these messages at any time by changing the notification settings on your mobile device.

Do Not Track

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. For information about Do Not Track, visit https://allaboutdnt.com/. At this time, Sage does not respond to Do Not Track browser settings or signals. In addition, Sage may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to Sage’s website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

Data Retention

We store the information we collect about you as necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, tax, bookkeeping or other compliance obligations.

Security

We seek to use reasonable organizational, technical, and administrative measures to protect information within our organization. Unfortunately, no data transmission over the internet or storage system can be guaranteed to be 100% secure. If you have reason to believe the security of your account has been compromised, please immediately notify us in accordance with the “Contact Us” section below.

Use Of Services By Minors

Sage is committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information of Minors under the age of 16 and if you are located in Austria under 14 or in UK, Ireland or Spain under 13.

Except as noted below: (i) our products and services are marketed for and directed towards purchase by adults or with the consent of adults; (ii) Individuals under the age of 18 ("Minors") are not permitted to use Sage Websites or Apps without the supervision of a parent or legal guardian; (iii) we do not knowingly collect or solicit personal information from children under the age of 13 or knowingly allow such persons to register for an online account or to post personal information on the Sage Websites; and (iv) should we learn that someone under the age of 13 has provided any personal information to or on any of the Sage Websites, we will remove that information as soon as possible.

If you are a parent or guardian who believes that your Minor under the age of 13 has submitted personal information or other information to us without your consent, please contact [email protected]. Once we verify that you are the parent or legal guardian, at your request, we will promptly provide to you information regarding what, if any, personal information we have collected about your child and how it has been used or shared. We will, at your request, remove personal information about your child from its database and instruct our affiliates and third party partners to do the same.

If you are a Minor under the age of 18, you may request and obtain removal of certain content or information posted on Sage Websites and Apps by sending an email to [email protected] with “Privacy Rights for Minors” in the subject line. Please be advised that our removal of your post(s) does not ensure complete or comprehensive removal of the content or information you have posted on Sage Websites or Apps.

Cross-Border Transfer

If we process data from EEA or UK in a third country (i.e., outside the European Economic Area (EEA)) where we have facilities or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with legal requirements.

Personal Information you submit on the Websites or through the Services may be sent to the United States and processed by us there or in other countries, on our service providers’ cloud servers. We will always protect your information in accordance with this Privacy Notice wherever it is processed.

Subject to your express consent or to contractually or legally required transfer, we process or allow the processing of data only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Additional Privacy Data Protection Notice for Users in the EEA

If you reside in California you have certain rights and protections under the California Consumer Privacy Act (“CCPA”) as amended from time to time. Please refer to our US Privacy Policy https://www.breville.com/us/en/home/index.html for detailed information applicable to our users and customers located in the US.

Your Data Subject Requests

You have the right to access personal data we hold about you and to ask that it be corrected, erased (to the extent allowed by applicable law), or transferred. You may also object to or request that we restrict certain processing. If our processing of your personal data is based on your consent, you have the right to withdraw your consent for future processing at any time. If you would like to exercise any of these rights, you can log into your account and edit certain account information or you may complete and submit a Data Subject Request form.

The UK GDPR requires that personal data from the EU/EEA must be especially protected. In addition, all EU-based individuals, irrespective of their nationality (“data subjects”) have certain individual rights under the UK GDPR, such as:

1. The right to be informed about the collection and use of their personal data.

2. The right of access to find out that is stored about them.

3. The right to rectification of their personal data if it is inaccurate or incomplete.

4. The right to erasure to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing.

5. The right to restrict processing to ‘block’ or suppress processing of personal data.

6. The right to data portability allowing individuals to obtain and reuse their personal data for their own purposes across different services.

7. The right to object to the processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing and/or for purposes of scientific/historical research and statistics.

8. Various rights in relation to automated decision making (making a decision solely by automated means without any human involvement) and profiling (automated processing of personal data to evaluate certain things about an individual).

If you would like to exercise any of these rights, you can log into your account and edit certain account information or contact us as described below.

Disclosures under Art. 13 and 14 UK GDPR

(a) The identity and the contact details of the controller(s)

BRG Appliances Limited, Studio 3.2 Power Road Studios, 114 Power Road, London W4 5PY, UK Telephone: +44 (0) 203 764 170

(b) Contact details of the data protection officer

Data Protection Officer email: [email protected]; Savannah Dirsa at BRG Appliances Limited, Studio 3.2 Power Road Studios, 114 Power Road, London W4 5PY, UK

To provide service with respect to your connected appliance, to respond to your requests, to market Sage’s products and services, to fulfill and process your requests for payment, for developing new products, to notify you of changes to service, fraud prevention, postings etc. See section “Use of Information” in the posted Privacy Policy.

(d) The recipients or categories of recipients of the personal data

Employees of Sage who respond to inquiries as well as external service providers who need to know the data for purposes of providing the products and services you have requested.

(e) Storage Limitations

The personal data will be stored by Sage for a period necessary for the purposes listed under (c) above, unless applicable law mandates a longer storage (e.g. 8 years for tax records in the UK), up to a potential maximum of 10 years subject to relevant exceptions.

(f) Withdrawal of Consent

The data subject has right to withdraw his/her consent at any time, without affecting the lawfulness of processing based on consent before the withdrawal, by sending an email to the Data Protection Officer listed under (b).

(g) Legal Basis for processing

The data subject provides his/her personal data to Sage (such as name and contact information) so that Sage can provide requested services, process the payment or respond to the inquiry (Art. 6 (1) (b) UK GDPR. In all other cases, the processing is necessary for the purposes of legitimate interests pursued by Sage, as balanced against the interests and fundamental rights and freedoms of the EU customer which require protection of personal data (Art. 6 (1) (f) UK GDPR). A legitimate interest is, in particular, the continued need of Sage to serve the EU customers of Sage with products and services.

Your Questions Or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected].

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Contact Us

This notice may be revised from time to time. Please revisit it regularly to stay informed about our use of cookies. If you have any questions or comments regarding this notice, you can email us [email protected] or write to us at the following address:

BRG Appliance Limited

3rd Floor, 86 - 90 Paul Street, London, EC2A 4NE, United Kingdom

Attn: Data Protection Officer/ Legal Department

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.