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DAUK DATA PROTECTION POLICY

Last modified:  01 September 2026

1. Who we are

Daikin Air-conditioning UK Ltd with registered office at The Heights Brooklands Weybridge KT13 and company number 04616794 (“DAUK”, “we”, “us”) is a subsidiary of Daikin Europe N.V. (“DENV”), which in turn is a wholly owned subsidiary of Daikin Industries Ltd. (hereinafter “DIL”). For the purposes of this policy, the “DAUK” comprises DAUK and the following UK entities: Ionize Limited, Robert Heath Heating Ltd, and Saltire Facilities Management Ltd.

As part of the Daikin Europe Group (“DENV-G”), DAUK 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 DAUK’s activities.

Specifically, this Policy is intended to comply with the UK GDPR (as incorporated into UK law), the Data Protection Act 2018, as amended by subsequent legislation including the Data (Use and Access) Act 2025 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 DAUK and describes the applicable governance framework.

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.

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:

  • DAUK (Data Controller): Daikin Air-conditioning UK Ltd
  • Registered office: The Heights Brooklands Weybridge KT13
  • Company number: 04616794
  • Email: dpc@daikineurope.com
  • Data Protection Officer (DPO): see Section 7.

2. Roles And Responsibilities

2.1 Data Controllers

DAUK generally acts as the primary Data Controller 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 DAUK uses systems or services provided at group level, this does not affect DAUK’s qualification as Data Controller for processing activities for which it determines the purposes and essential means.

2.2 Joint Data Controllers

When DAUK 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

DAUK 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, DAUK 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 of Personal Data is processed only in accordance with Article 9 of the UK GDPR. 

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 Personal 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, DAUK 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 6).

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

For DAUK to perform contracts duly and properly and to carry out all the necessary statutory and accounting processes, DAUK requires some Personal Data provided by Data Subjects offline through Forms or online through Website and Applications. In accordance with Data Protection Laws, DAUK may use Personal Data for the purpose of performing contracts

With regard to the management of relationship with customers and the provision of consumer services, DAUK 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 DAUK’s premises; or
  • organise and execute service interventions for customers and installers; or
  • inform customers of an approaching maintenance deadline.

Product Distribution

DAUK 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 is included in delivery notes accompanying the transport of a product purchased); or
  • optimise 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

DAUK 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

DAUK 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.

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

Bookkeeping and Accounting

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

Fraud or Crime prevention

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

Corporate Business and Housekeeping

DAUK transmits and/or jointly uses the Personal Data collected with DIL and/or other DENV-G companies and/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 DAUK Legitimate Interest of doing business.

Use of Artificial Intelligence (AI) and automated decision‑making

DENV‑G or DAUK 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, DAUK 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 may transmit or disclose Personal Data to any natural person or legal entity, to subcontractors and business partners that are third parties with respect to DAUK or DENV-G.

When we transmit or disclose Personal Data to third parties, DAUK will make sure to have in place a data processing agreement with this third party under the provisions of the Data Protection Laws, requiring 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, DAUK implements appropriate safeguards, including the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, adequacy regulations where available, and other transfer mechanisms permitted under applicable Data Protection Laws.

5. Data Retention

We retain your Personal Data for the period required for the purposes of processing described above. When Personal Data is no longer required for these processing purposes, we commit to the deletion of Personal Data, unless archiving 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 with, but not limited to, one of the following criteria: contract length and legal obligations; business and organisational needs; long-term business relationship; pursuit of direct marketing; statistics.

DAUK commits to work with aggregated, anonymized or pseudonymized Personal Data to the extent possible and in all cases, it will de-identify personal Data as quickly as possible.

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

Once your Personal Data is subject to Processing, you have a number of rights as Data Subject that can be exercised under applicable Data Protection Laws, as described below.

DAUK may need to verify your identity

You can have access to your Personal Data

If you would like to access the Personal Data that DAUK 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 has 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, DAUK 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

You can ask for your Personal Data to be rectified or completed at any time, by clicking here.

If you want DAUK to erase your Personal Data, your request will be processed, provided that 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 was 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 DAUK 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 automated decision-making systems. If you disagree with how DAUK 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:

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

You have the right to complain to DAUK if you believe that our Processing of your Personal Data does not comply with Data Protection Laws. You can submit a complaint by email to dpc@daikineurope.com  or using the contact details set out under 'How to submit a request' above. We will acknowledge your complaint within 30 days of receipt, take appropriate steps to investigate and address it, and inform you of the outcome without undue delay. We encourage you to contact us first so that we can try to resolve your concerns. If you are not satisfied with our resolution of your complaint once you have exhausted our complaints process, you 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:

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

DAUK implements security measures in order to maintain integrity and security and prevent accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed, in line with Data Protection Laws.

10. Privacy By Design

DAUK commits to carrying out data protection impact assessments before commencing Processing activities involving new technologies, in accordance with UK GDPR.

11. Further Changes to This Data Protection Policy

DAUK 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.

DAUK 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 www.daikin.uk or for each Application by clicking on the “Data Protection Policy” section.

 

 

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