Privacy Statement

If you have questions, please contact our Data protection officer: eu.privacy@napoleon.com

Wolf Steel Europe B.V., hereafter “Wolf Steel Europe” or “WSE”, processes privacy sensitive or personal information. We respect the privacy of our visitors and users. We ensure the personal information you provide is treated confidentially. Personal data will be carefully processed and secured. Our processing of personal data conforms to the requirements posed by EU privacy legislation. This privacy statement applies to the use Wolf Steel Europe makes of the data and its websites.
Our privacy statement in short

When processing personal data, we comply with EU privacy legislation. This means, amongst other things, that we:
• clearly state for what purpose we process personal data. We do this by means of this privacy and cookie statement;
• limit the personal data we collect is to those personal data needed for the specified purposes;
• explicitly ask you for permission to process your personal data, in those cases in which permission is required;
• take appropriate security measures to protect your personal data and demand the same from parties processing personal data on our behalf;
• respect your right, on your request, to give access to, modify or remove your personal data.

Processing purposes
Your personal data is processed for the following purposes; to:

use our contact form
find a dealer near you
register your product
help you with a techsupport request
create a wish list
chat with us
evaluate and improve our website
subscribe to our newsletter
follow/like/share us on social media
request your help as one of our suppliers
process your job application
become a Napoleon dealer

ELECTRIC FIREPLACES ONLY (https://premiumfire.napoleon.com)

sell you an electric fireplace
answer questions regarding electric fireplaces
We will not use your personal data for any other purpose than those listed above, unless you give permission beforehand, or if we are required to do so by law.

Types of personal data
We process the following personal data for the abovementioned purposes:

name;
e-mail address;
telephone number;
IP-address
further information you share with Wolf Steel Europe
in case of warranty claims for which you need spare parts, your address for example
if you follow/like us through social media, the name of your profile, information you choose to share through those social media

ELECTRIC FIREPLACES ONLY

• The above and

• IBAN number

• Other account names and – numbers related to different methods of payment through the Shopify & Mollie platforms

• Shipping address (in case of shipping an electric fireplace)

Data retention

We will not keep your data longer than necessary for the purposes listed above and the actions following from the same necessity. The personal data will be erased once the listed purposes have been fulfilled, unless there is a supererogatory legal requirement. Taking into account the product lifecycle, length of our warranty periods and the mandatory 7 years we are required to keep records of goods (mainly spare parts, accessories, grills, fireplaces, marketing materials) delivered under warranty, we fixed the general duration of personal data retention on 7 years. If you did not receive any goods, you may request erasure or anonymisation of your data. To do so, please send an e-mail to eu.privacy@napoleon.com

Sharing of personal data

Wolf Steel Europe may share your data with 3rd parties, when it follows from the purposes listed above and there is a legal ground to do so. Wolf Steel Europe may share data with those responsible for processing your data and/or request, within the company, with a legitimate interest (administrative purposes, among which finance, legal, quality monitoring).

Third parties processing personal data on our behalf or yours:

Napoleon Grills dealers
IT suppliers and service providers
Hosting party
Resource suppliers
Telecom suppliers
Cookie service providers
Payment service providers and collections agencies
Mail order companies
Marketing companies
Review companies
Partner companies
External advisors and intermediaries
Government agencies (e.g., tax authorities, municipalities)

Wolf Steel Europe may provide your personal data to other entities within our corporate group, based on our legitimate interest (administrative purposes, among which finance, legal and quality monitoring).
In case of a warranty claim, we may share your personal data with your dealer, to deliver the best possible customer service. If you do not wish us to do so, please state so in writing, for example through the contact form, and we will only share the product type and serial number with your dealer.
Wolf Steel Europe may provide your personal data to parties located outside the European Economic Area (EEA) to provide our services. Wolf Steel Europe will only do so if there is an appropriate level of protection for the processing of personal data, for example if there is an adequacy decision by the European Commission, or if we have concluded the Standard Contractual Clauses (‘SCCs’) with the receiving party. For the United States a self-certification under the EU/US Data Privacy Framework.

When can we share your personal data with third parties?

Wolf Steel Europe will only share your data with third parties to the extent permitted by current legislation. We may provide your personal data to third parties when:

We have engaged them to process certain data;
We have a legal basis to do so;
We are legally obligated to do so (e.g., if the police demand this in case of a suspicion of a crime).

This privacy statement applies only to the services of Wolf Steel Europe. We are not responsible for the privacy practices of other websites, which can be accessed through a link on our website.”

3rd party websites

This privacy and cookie statement does not apply to websites belonging to 3rd parties, which are, through the medium of hyperlinks, connected to this website. We cannot guarantee these 3rd parties treat your personal data in a secure and reliable manner. We advise you to consult the privacy statements of these websites, before using/visiting them.
3rd party plugins

LECTRIC FIREPLACES ONLY

Shopify
https://www.shopify.com/legal/privacy
https://www.shopify.com/legal/cookies
Mollie payments
https://www.mollie.com/en/privacy
Tido
https://www.tidio.com/privacy-policy/

Cookies - Usage and Purpose

Wolf Steel Europe uses cookies. A cookie is a small text file, which accompanies the Wolf Steel Europe website and is stored locally on your computer. In these cookies, information is stored, which will, during a later visit, be recalled and used by our websites.
Functional cookies

Session cookie

Napoleon uses so-called ‘session cookies’ in order to provide a user-friendly experience. They store your settings and log-in data (if any). They enable you to generate a wish list and remain logged in. You can disable these cookies in your web browser.
Analytical cookies

Our websites use analytical cookies. They may, under necessary legal obligation, provide data to 3rd parties, or if those 3rd parties process data on their behalf. The data obtained in the fashion described, including your computer’s anonymised IP-address, is stored by the parties mentioned and may be stored in the United States. Wolf Steel Europe has not allowed Google to use the analytics data received to be used for other Google services. All data gathered by Google from our website is anonymised. Please read Google’s privacy statement here: https://policies.google.com/privacy

Google (analytics) - generates statistical data on how the visitor uses the website.
HotJar - generates statistical data on how the visitor uses the website.
Vimeo - collects usage data from videos (hosted by Vimeo) that are on the website.
Shopify - generates statistical data on purchases and shopping within website (N. America only).

Marketing cookies

Marketing cookies are used to help Napoleon and our partners serve marketing ads that are more relevant to your interests. The following is a summary of the 3rd party marketing cookies used on Napoleon.com:

SharpSpring - to assess visitor behaviour and to determine how the visitor accessed the website
Google DoubleClick (YouTube) – determines visitor actions after viewing a video or ad with the purpose of measuring the efficacy of the video/ad and to present targeted ads to the user.
YouTube - determines geographical location for video playback, usage history, video player preferences,
Facebook - Collects information on visitor behaviour. This information helps to optimize the relevance of targeted advertisements.
HotJar - Determines if the user's navigation should be registered in a certain statistical place holder.
Tidio - Live agent chat integration (Austria region only)
Shopify - Used to process online orders which are fulfilled by local Napoleon dealers (N. America only).

Other cookies

ELECTRIC FIREPLACES ONLY

Google analytics
https://policies.google.com/privacy?hl=en-US
Facebook pixel
https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
Pinterest pixel
https://policy.pinterest.com/en/privacy-policy-2018

Rights of access and rectification

For questions about our privacy policy and/or rights with regard to access, rectification, erasure or other rights, please contact us through the channels outlined below.
With regard to your personal data, you have got, amongst others, the following rights:

the right to be informed: which personal information we collect, what we do with it;
the right to access: which of your personal data do we have;
the right to rectification: correct any errors in your personal data we have in our possession;
the right to erasure: we remove your personal data and forget you. The main reservation to this is the mandatory 7 year term which the Belastingdienst (Dutch inland revenue) imposes on us for parts shipments;
the right to retract permissions given;
the right to object to certain kinds of (automated) processing and decision making

If you wish to exercise one of these rights, please clearly demonstrate your identity, so we may accurately identify you and not delete someone else’s data. If your request concerns personal data connected to a cookie, we ask that you supply us with a copy of the cookie in question. This cookie you may find in your internet browser’s settings.

Right to lodge a complaint with a supervisory authority

If you have a complaint about the way in which we treat your personal data, we will of course gladly help you. Alternatively, you have the right to lodge a privacy complaint with your supervisory authority. Hereto please contact your local privacy authority.

Changes to this privacy and cookie statement

Over time, changes may occur. The changes will be listed here, on this website. We advise you to regularly check this statement for updates, so you will be fully informed.

Security

We prevent unauthorised access to our data by both physical access control and software policies.

Contact us

For further questions with regard to our privacy and cookie statement, please contact our data protection officer:
Name Wolf Steel Europe BV
Address De Riemsdijk 22, 4004 LC, Tiel, Netherlands
Phone 0031 (0)345 588 655
E-Mail eu.privacy@napoleon.com
CoC nr 51509970

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