Daikin Europe N.V. is a fully-owned subsidiary of the Japanese company Daikin Industries Ltd. Daikin Group produces, sells, distributes and executes marketing with regard to air-conditioning, heating, ventilation and refrigeration equipment and solution business, along with its Subsidiaries.

Daikin Europe N.V., together with its Subsidiaries (hereinafter, “DENV-G”, “we”, “us”, “our”, etc.) and its mother company Daikin Industries Ltd. (hereinafter “DIL”), is sincerely committed to the protection of Personal Data collected from Data Subjects (hereinafter “User”, “you”, “your”) offline, through e.g. paper forms, contracts, statements (hereinafter “Forms”) or online, through the website www.daikin.eu or www.aht.at (hereinafter jointly referred to as “Website”) and through, for example, but not limited to, DENV-G’s (web) applications, software and digital tools (hereinafter “Applications”).

In accordance with the European General Data Protection Regulation (EU) 679/2016 (GDPR), in order to:

• ensure transparency in the nature of the Personal Data we collect offline through Forms or online through the Website and/or through Applications;
• ensure transparency in the use of Personal Data collected;
• facilitate Data Subjects in the exercise of their rights;
• therefore, hereby we set forth this Data Protection Policy.

 

The protection of your Personal Data matters to us. We aim to process your Personal Data in a lawful, appropriate and transparent manner.

Take your time to read this Data Protection Policy and its main key terms, that you will find hereby in capitalized form.

In this regard, if you have any questions or remarks, please contact us.

 

1. Who we are

AHT Cooling Systems Supermarket (UK) Limited (“AHUK”, “we”, “us”) is a subsidiary of Daikin Europe N.V. (“DENV”), which in turn is a subsidiary of Daikin Industries Ltd. (hereinafter “DIL”).

As part of the Daikin Europe Group (“DENV-G”), AHUK is committed to protecting Personal data of individuals (hereinafter “you”, “your”, “Data Subject”) in accordance with applicable data protection laws.

1.1. Scope and Structure of this Data Protection Policy

This Policy describes how Personal data is processed in the context of AHUK’s activities.

Specifically, this Policy is intended to comply with the UK GDPR (as incorporated into UK law), the Data Protection Act 2018, and where applicable, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) (together referred to as “Data Protection Laws”).

This Data Protection Policy provides a general overview of how Personal data is processed within AHUK and describes the applicable governance framework.

Depending on the context in which Personal data is collected, specific and more detailed privacy notices may apply to particular processing activities such as:

• recruitment,
• employee data,
• customer or partner platforms
• Website and online services:  Daikin website(s) are managed by Daikin Europe N.V. If you are visiting a Daikin website, please refer to the relevant Daikin Europe N.V.’s  Website Privacy Notice.

Where such specific privacy notices are made available, they supplement and take precedence over this AHUK Data Protection Policy in respect of the relevant processing activities.

The protection of your Personal data matters to us. We aim to process your Personal data in a lawful, appropriate and transparent manner. Please take the time to read this Data Protection Policy and its main key terms.

For any questions or remarks, please contact us at dpc@daikineurope.com.

1.2. How to Contact Us

If you have questions about this policy or how we use Personal data, you can contact:

• AHUK (Data Controller): AHT Cooling Systems Supermarket (UK) Limited
• Registered office: 4 Davy Avenue, Knowlhill, Milton Keynes MK5 8PB
• Company number: 05773315
• Email: dpc@daikineurope.com
• Data Protection Officer (DPO): see Section 7.

2. Roles and Responsibilities

2.1. Data Controllers

AHUK generally acts as the primary Data Controller (see key terms) within DENV‑G for the Processing activities described in this Policy, in accordance with the Data Protection Laws, unless stated otherwise.

Depending on the circumstances, where AHUK uses systems or services provided at group level, this does not affect AHUK’s qualification as Data Controller for processing activities for which it determines the purposes and essential means.

2.2. Joint Data Controllers

When AHUK and one or more DENV-G companies jointly determine the purposes and the means of Processing, they act as Joint Controllers within the meaning of Article 26  UK GDPR. In such cases, Data Subjects will be informed in accordance with Data Protection Laws.

2.3. Data Processors

AHUK may engage DENV-G companies or third‑party service providers to process Personal data on its behalf. In such cases, processing is carried out on the basis of documented instructions and subject to a data processing agreement compliant with Article 28 UK GDPR.

3. Personal Data We Collect and Purposes

3.1. Categories of Personal Data

Depending on the purpose, AHUK may process the following categories of Personal Data:

• identification and contact data (e.g., name, address, email, telephone, customer/installer ID);
• professional and employment‑related data (e.g., job title, employer, CV information);
• contractual and transactional data (e.g., orders, service records, invoices, payment status);
• technical and usage data (e.g., device identifiers, log data for portals/platforms, system access data); and,
• special categories of Personal data, where strictly necessary and permitted by law. (e.g., health data in an employment context). Special category data is processed only in accordance with Article 9 of the UK GDPR, including on the basis of explicit consent, legal obligations in employment and social protection law, vital interests, legal claims, or substantial public interest.

3.2. Sources of Personal Data

We may collect Personal data:

• directly from you (e.g., forms, emails, phone, portals), and/or
• indirectly (e.g., via installers, distributors, service providers, group companies, or publicly available sources where appropriate).

3.3. When Providing Data is Required

In some cases, providing Personal data is:

• contractually required (e.g., to supply products/services), and/or
• required to comply with a legal obligation (e.g., invoicing/tax requirements).

If you do not provide certain information, we may not be able to process your request or deliver relevant services. Where this applies, we will explain this at the point of collection or in the applicable notice.

3.4. Purposes and Lawful Bases (UK GDPR Article 6)

For each processing activity, AHUK relies on one or more lawful bases under Article 6 UK GDPR, including:

• Contract (Article 6(1)(b)) – necessary to perform a contract with you or to take steps at your request before entering a contract;
• Legal obligation (Article 6(1)(c)) – necessary for compliance with UK legal obligations;
• Legitimate interests (Article 6(1)(f)) – where our interests are not overridden by your rights and freedoms (we assess and balance this); and/or
• Consent (Article 6(1)(a)) – where required (e.g., certain marketing under PECR).

Where processing is necessary for contract purposes (Article 6(1)(b)), consent is not required. Where we rely on consent, you can withdraw it at any time (see Section 8).

3.5. Personal Data We Collect from You or from Third Parties

Purposes of the Processing

Personal Data may be processed for, among others, the following purposes:

 Business Administration and Customer Management

AHUK has to be able to perform contracts duly and properly and to carry out all the necessary statutory and accounting processes. Accordingly, AHUK will need some Personal data provided by Data Subjects offline through Forms or online through Website and Applications. In accordance with  Data Protection Laws, for the purpose of performing contracts, the consent of the Data Subject that is or is going to be a party to a contract is not required.

With regard to the management of relationship with customers and the provision of consumer services, AHUK uses Personal data (e.g. name, country, nationality, email address, client number, credit card information) in order to:

• assess whether it would be feasible to sell products or provide services to a customer before entering into a contract; or
• process customers’ written requests, customers’ orders of products and services and requests of cash-back; or
• identify and contact customers for a discount; or
• inform customers about consumers’ rights and additional services related to the product or the service purchased; or
• inform customers about Daikin’s promotional campaigns and events and send out related invitations; or
• manage the access to AHUK’s premises; or
• organise and execute service interventions for customers and installers; or
• inform customers of an approaching maintenance deadline.

Product Distribution

AHUK uses Personal data for product distribution, on the basis of performing a contract/ fulfilling a legal obligation, and particularly in order to:

• distributing products and supplying services through authorized agencies, Business partners, the Website and/or through Applications; or
• facilitate distributors in delivering products, spare parts and services (for example, Personal data are included in delivery notes accompanying the transport of a product purchased); or
• optimize sales and services by elaborating offers for customers; or
• improve and fasten the distribution of our products and services; or
• follow up technical data from installations and the status of contracts and projects; or
• organise and provide training to customers, installers, employees and subcontractors.

Supplier Administration

AHUK uses Personal data to keep records of suppliers and service providers, to register and manage purchase orders, business expenses and invoices provided by suppliers or service providers, acting on the basis of performing a contract/ fulfilling legal obligation.

Direct Marketing

AHUK may send direct marketing communications using Personal Data in accordance with the Data Protection Laws.

Where such activities qualify as direct marketing, Processing is carried out in accordance with applicable consent, soft opt‑in or legitimate interest requirements under Data Protection Laws and, where applicable, PECR.

You may object to direct marketing at any time, free of charge, using the opt‑out mechanism provided or by contacting us directly.

 Recruitment and Selection

For the purpose of recruiting talents, AHUK collects Personal data such as, but not limited to, name, email, phone number, curriculum information, URL to social media profile from open applicants and targeted applicants applying for example for job vacancies, international traineeship, student internship. This processing is allowed by the fact that applicants are voluntarily taking steps in order to enter into a contract with AHUK.

The Personal data provided by applicants (through filling in Forms or registering and creating a personal account on the Website or when entering Applications) will be used for Processing applications, contacting applicants for human resources management related activities, managing hiring processes (e.g. inviting applicants for interviews and for conducting written tests) and drafting employment contracts.

Personal data belonging to applicants who were not hired at the end of the selection process are deleted after 1 year from the date of the communication of the negative outcome of the selection, unless the applicants have requested the immediate cancellation of their data following such communication.

Personnel Administration and Salary Benefits

AHUK uses Personal data, on the basis of performing an (employment) contract, for the purpose of managing personnel and particularly:

• managing and keeping records of employment contracts and payroll; and/or
• paying salaries; and/or
• keeping records of employees’ attendance, travelling and training activities; and/or
• communicating with health insurance companies; and/or
• providing employees with insurances, company assets and salary benefits related to performances.

Bookkeeping and Accounting

AHUK uses Personal data, on the basis of performing a contract, for the purpose of bookkeeping and accounting and with the aim of:

• keeping records of transactions; or
• issuing invoices related to sales and services provided; or
• filling in tax declarations and related forms in order to fulfil tax obligations; or
• elaborating statistics on the basis of transactions’ records (for example regarding the number of transactions occurred and in which area); or
• being compliant with Data Protection Laws and with regulatory requirements both at national and international level.

Legal Claims and Disputes

We can use Personal data as evidence and for ascertaining, exercising and safeguarding the rights of AHUK or of those it represents (e.g. in disputes) before any jurisdiction of any country (for example, among others, the right of AHUK to defend itself from acts of unfair competition or the right of AHUK solicit the fulfilment of an unpaid invoice).

Fraud or Crime prevention

We can also use Personal data to prevent, detect and investigate crimes and cyber risks for Legitimate Interest or when a public authority requests to do so.

Corporate Business and Housekeeping

AHUK transmits and/or jointly uses the Personal data collected with DIL and/or other DENV-G companies oand/or its Business Partners only when needed and in view of elaborating periodic reports on the outcome and business-related aspects, business plans and corporate strategies. The processing is based on AHUK Legitimate Interest of doing business.

AHUK processes Personal data of individuals located in the United Kingdom that were lawfully collected by another company of the Daikin Group unless there is no legal impediment (e.g. a duty of confidentiality or a provision in the data protection legislation).

AHUK is committed to put in place all the appropriate measures for the protection of Personal data with regard to intra group communications, in line with applicable Data Protection Laws.

Use of Artificial Intelligence (AI) and Automated Decision‑Making

DENV‑G may use systems incorporating artificial intelligence or machine‑learning techniques for analytics, optimisation, or support functions.

Where such systems involve Personal Data:

• appropriate technical and organisational measures, including human oversight, are applied; and
• no decisions producing legal or similarly significant effects are taken solely on automated processing, unless permitted by law and subject to applicable safeguards under Article 22 of UK GDPR.

Unless expressly stated otherwise, Personal Data is not used to train general‑purpose AI models.

3.6. Personal Data Disclosure to Third Parties

For the above purposes, AHUK may need services, counselling and/or assistance from third parties, including, but not limited to, maintenance of Applications and bug fixing, purchase of Applications, data hosting, counselling on compliance with laws and regulations, development of Applications, human resources services, supply services, Internet providers’ services, production of statistics and others.

In this regard, to the extent necessary, we can transmit or disclose Personal data we collected to any natural person or legal entity, to subcontractors and Business partners that are third parties with respect to AHUK or DENV-G.

Every time we need to transmit or disclose some Personal data we collected to third parties, except in case of Legitimate Interest of the third party, AHUK will make sure to have in place a data processing agreement with this third party under the provisions of the Data Protection Laws, asking the third party to comply with the principles and the provisions of the same Regulation and to align on appropriate security standards.

4. International Data Transfer

Where Personal Data is transferred outside the United Kingdom, AHUK ensures an adequate level of protection by relying on:

• UK adequacy decisions;
• the UK International Data Transfer Agreement (IDTA)
• the UK Addendum, to the EU Standard Contractual Clauses (where applicable); and/or
• other lawful transfer mechanisms permitted under applicable Data Protection Laws.

5. Data Retention

AHUK does not keep your Personal data forever. We use your Personal data to the extent necessary and only with the aim of pursuing the purposes described above. Once the aim no longer exists, we commit to delete the Personal data, unless archiving them is required by law, at international or national level.

The starting point for storing your Personal data is the statutory retention. The period can be longer where needed for the exercise of our rights.

If no retention period is stipulated by law, the retention period can be shorter in accordance to, but not limited to, one of the following criteria: contract length and legal obligations; business and organizational needs; long-term business relationship; pursuit of direct marketing; statistics.

Some insights only get clearer once they are viewed over a longer time span. For this reason, for some types of Personal data a more extended time horizon may be necessary (e.g. for those needed in order to design marketing and risk models).

As has been stated, AHUK commits as much as possible to work with aggregated, anonymized or Pseudo-Anonymized Personal data and in all cases, it will cease the connections to individuals as quickly as possible.

6. Your Rights as Data Subject and how to Exercise Them

If you have any questions about the protection of your Personal data or the exercise of your rights, you can contact us at any time by writing to AHUK, by sending via postal mail a specific Form or by submitting the Form available online under each “contact us” section throughout the Website and/or the Applications.

Once your Personal data are subject to Processing, you have several rights as Data Subject that can be exercised, as listed below.

Be as specific as possible any time you wish to exercise your rights. AHUK can only properly answer queries asked in sufficient detail. AHUK may need to verify your identity in as much detail as possible, in order to avoid that someone else tries to exercise your rights.

You can have access to your Personal data

If you would like to access the Personal data that AHUK processes about you or you want to know more about:

• the purposes of our Processing;
• the categories of Personal data concerned;
• the categories of recipient to whom the Personal data have been or will be disclosed;
• the envisaged period of storage or the criteria used to determine that period;
• the Data Subject’s rights;
• the rights you can exercise with respect to our Processing;
• the existence of Automated Decision-Making, including Profiling, and envisaged consequences;

and any other available information about the Processing of your Personal data, please fill in the following form by clicking here.

We will use the Personal data you provide us through the form only for the purpose of verifying and Processing your request.

If you exercise your right to access, AHUK will give you as complete as possible a list or a copy of your Personal data.

You can complete/rectify/erase/restrict the processing of your Personal data

It can happen that certain Personal data held on you by AHUK are not (or have ceased to be) correct. It can also happen that you want to add something to the Personal data you provided us. You can ask for your Personal data to be rectified or completed at any time, by clicking here.

If you want AHUK to erase your Personal data your request will be processed, unless no impediment or incompatibility arise according to law or Legitimate Interests towards the deletion. If you want to ask for the erasure of your Personal data, please click here.

You can obtain the restriction to the Processing of your Personal data at any time, by clicking here.

You can ask for the portability of your Personal data to yourself or to third parties

If your Personal data were collected through electronic means, you can ask for the portability of the Personal data you provided us to yourself or to third parties, by clicking here.

You can withdraw your consent to Processing of your Personal data

Please remember that every time you provide AHUK with your consent to process your Personal data, you can subsequently withdraw that consent at any time by following the suggested procedure and as easily as you gave it.

If you want to withdraw your consent, you can do it at any time by clicking here.

You can object to Processing or object to Processing by automatized decision-making systems

If you disagree with how AHUK processes certain Personal data, you can object by clicking here. We shall process objections unless there are valid reasons not do so or reasons provided by law (for example, an objection will be declined if the Processing of Personal data has been conducted in view of combating fraud).

6.1. How to Submit a Request

You can exercise your rights by contacting us:

• Email: dpc@daikineurope.com
• Online form

• Post: 4 Davy Avenue, Knowlhill, Milton Keynes MK5 8PB

Please be as specific as possible so we can respond efficiently. We may request information to verify your identity to protect you from unauthorised access.

6.2. Timing and Fees

We normally respond within one month of receipt. This may be extended by up to two further months for complex requests (we will inform you if so). Requests are generally free of charge, but we may charge a reasonable fee or refuse requests that are manifestly unfounded or excessive, as permitted by law.

6.3. Right to Complain to the ICO

If you have concerns, you can contact us first so we can try to resolve them. You also have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner’s Office (ICO)
Website: https://www.ico.org.uk

7. Data Protection Officer

The Data Protection Officer acts independently and may be contacted on all matters relating to the protection of Personal Data. Here follows the contact details of DENV-G’s Data Protection Officer:

• Email address: euprivacy@daikin.co.jp;
• Data Protection Officer, Osaka Umeda Twin Towers South, 1-13-1 Umeda, Kita-ku, Osaka, Japan 530-0001.

8. Minors

Through its Website or Applications DENV-G does not process any Personal data of natural persons aged under 13 years of age under UK GDPR, unless consent has been provided by a holder of parental responsibility where required.

9. Security Measures to Protect Personal Data

AHUK has implemented adequate security measures in order to maintain integrity and security and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal data transmitted, stored or otherwise processed, in line with Data Protection Laws.

10. Privacy By Design

AHUK commits before starting Processing activities using new technologies to carry out data protection impact assessments in accordance with UK GDPR and by undertaking appropriate actions accordingly.

11. Further Changes to This Data Protection Policy

AHUK regularly seeks to improve their efforts in protecting Personal data. This Data Protection Policy can be changed or updated in light of upcoming legislations, both at international and national level.

AHUK will inform you of all substantive changes of this Data Protection Policy via offline or online means (for example, via the Website, during your first visit or with each substantial update of this Data Protection Policy).

You can always find the most recent version of our Data Protection Policy available at https://uk.aht.at/  or for each Application by clicking on the “Data Protection Policy” section.