Last Updated: October 6, 2021

Zenith Electronics LLC and its parent, affiliates and subsidiaries (collectively “we,” “us,” or “LGEUS”) care about your privacy. LGEUS provides many products and services. This privacy policy only applies to (i) the LG NOVA Proto Challenge and (ii) the LG Mission for the Future grand challenge (collectively, the “Programs”), including information we collect in connection with the Programs both online and offline. This privacy policy does not apply to any other LGEUS branded products or services. The purpose of this privacy policy is to explain how we collect personal information for the Programs, what we collect, how we use it, how we share it, and what controls and rights you have. By participating in the Programs, you consent to the terms of this privacy policy.

European Economic Area - Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679: References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. Essentially, it means information about an individual, from which that individual is either directly identified or can be identified. It does not include “anonymous data” (i.e., information where the identity of individual has been permanently removed). LGEUS is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. See the Contact Us section below for contact details.

A. How We Collect Information

When you participate in the Programs, personal information about you may be collected directly from you, automatically from your device, or from third parties.

Direct Collection. You may directly provide us with personal information in connection with the Programs. For example, you may provide personal information in your Program submissions, in your communications with us, or in presentations you provide. You may also direct information to be provided to us from other websites (e.g., TechConnect or F6S). You may provide personal information to us in offline and online settings.

Automatic Collection. We may automatically collect personal information from your device as part of your participation in the Programs, such as when you open an email.

Third Parties. LGEUS may also obtain information about you from third parties, including from third-party marketing and analytics partners or other service providers.

B. The Information We Collect

As a general matter, LGEUS collects information that may help us administer the Programs and provide future products and services. We may collect information in the following categories:

Identifiers. We may collect basic identifying information, including information about contest participants. For example, we may collect information about (a) a person (e.g., first name, last name, date of birth), (b) business (e.g., business name, address, phone number, web address), and (c) contact details (e.g., e-mail address, phone number, postal address). Identifiers may be collected directly, automatically, or via third parties. Note that your mailing address may also be considered geolocation information and your business name may be considered employment information.

Commercial Information. We may collect information about your payment information (e.g., bank account) directly from you.

Internet or Network Activity. We may collect information about your Internet and other network activity. We may collect this information directly or automatically.

Personal Characteristics. We may collect characteristics about you (e.g., age, gender) directly from you, such as when you include it in submissions, presentations or in other communications with us, or from third parties.

Audio or Visual Information. You may provide audio or visual information in connection with your participation in the Programs, such as in photos or videos you submit. We may also record phone calls. We collect this information directly or automatically.

Inferences about Trends and Preferences. In connection with the Programs, we may create or collect inferences about you, such as your basic preferences, predispositions, behavior, attitudes, aptitudes, or other characteristics. We may collect this information directly or via third parties.

Any of the foregoing may also constitute California Customer Records (as defined in California Civil Code §1798.80).

C. How We Use Information and legal bases for processing

European Economic Area - Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679: We use your personal information only as permitted by law for the purposes for which we collected it, as listed below. In respect of each of the purposes for which we use your personal information, the European data protection legislation requires us to ensure we have one of the following “legal basis”:

  • Where we need to perform a contract that we are about to enter into, or have entered into, with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”). Generally, we do not rely on your Consent as a legal basis for using your personal information other than in the context of direct marketing communications.

Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Purpose Category (ies) of personal information involved Why do we do this Our legal basis for this use of data
Administer the Programs and complete a transaction
  • Identifiers
  • Commercial information
  • Personal Characteristics
  • Audio or Visual Information
  • Inferences
  • To operate, maintain, administer and improve the Programs
  • To complete a financial transaction, such as the deposit of an award.

Contractual necessity

Legitimate Interests

We have a legitimate interest in providing you a good service.

Communicate with you
  • Identifiers
  • Internet or Network Activity
  • Audio or Visual Information
  • Inferences about Trends and Preferences
  • Personal Characteristics
  • To better understand your needs and interests, and personalize your experience with the Programs
  • To respond to your service-related requests, questions and feedback

Legitimate Interests

We have a legitimate interest in providing you a good service, including communicating with you about the Programs and about current and future products that may be of interest to you.

Compliance, Fraud Prevention and safety
  • Identifiers
  • Commercial Information
  • To keep the Programs and associated systems operational and secure
  • To enforce the terms and conditions that govern the Programs

Legitimate Interests

We have a legitimate interest in ensuring the ongoing security and proper operation of our Programs and transactions.

Direct marketing
  • Identifiers
  • Internet or Network Activity
  • Inferences about Trends and Preferences
  • Personal Characteristics
  • To form a view on what we think you may want or need, or what may be of interest to you.

Consent

You may opt-out of our marketing communications as described in the Opt-out of marketing section above.

Compile Statistics

  • Identifiers
  • Internet or Network Activity.
  • Inferences about Trends and Preferences
  • Personal Characteristics
  • We may use your collected information to compile statistics and other analytics about the Programs or other products and services

Legitimate Interests

We have a legitimate interest in compiling statistics about your use of the Programs.

 

D. Sharing Your Information

In general, LGEUS may share all of the categories of personal information we collect with: (i) entities within our corporate umbrella (e.g., with our corporate parent, subsidiaries, or partners in joint partnerships), (ii) our external service providers in order to administer and improve the Programs and provide future products and services, (iii) successor, or potential successor organizations, (iv) entities to which you direct us to share your information, (v) law enforcement in response to valid legal process, or (vi) other participants in the Programs and the public. For example, LGEUS may share your personal information:

To Administer the Programs. We may share all of the above categories of information with our service providers, who help us administer the Programs, provide future products and services, or provide other services or functions. Such service providers include customer management vendors, payment processors, and marketing vendors. We may also share with our parent company, subsidiaries, and affiliates in order to better serve you or maintain our business.

For Legal Reasons. We may share all of the above categories of information with service partners or other outside entities as necessary to comply with our legal obligations, including compliance with any applicable law, legal process, or court order. We may also share information in order to protect and defend the rights of LGE, our users, or any other individual, to protect against fraudulent or malicious activity, to protect the safety of persons or property, to enforce our Terms & Conditions, or to cooperate with law enforcement agencies.

For Other Internal Reasons. We may share all of the above categories of information with service partners and other entities that provide LGE with certain services or assist with internal functions, such as analyzing data, maintaining the security of our systems, or ensuring our compliance with the law, including by sharing with governmental authorities to comply with any applicable law, legal process, or court order. For example, we may share information with auditing firms, outside attorneys in order to obtain legal advice, or with other professional advisors. Other entities that may receive information for these purposes include information security vendors, data analytics firms, quality assurance assessors, and similar types of entities. We may also share with our parent company, subsidiaries, and affiliates in order to better serve you or maintain our business.

In Connection with a Sale or Merger. If we directly or indirectly undergo a business transition (including proposed transactions), such as a merger, acquisition by another company, or sale of all or part of our assets, we may share all of the above categories of information to the successor or potential successor organization, as well as their professional advisors during the transition.

When you otherwise consent to such disclosure. We may share certain information with service partners or other entities when you direct us to share or otherwise consent to our sharing such information.

E. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

F. Your control and choices

The information you submit. You are in control of the information that you choose to directly provide LGEUS. This privacy policy explains how LGEUS will treat any information LGEUS collects in connection with the Programs.

Email communications. From time to time, we communicate with you with functional or marketing emails. For example, we may send you functional emails to confirm your request, to send you notice of payments, to send you information about the Programs, and to send notices and other disclosures as required by law. Generally, you cannot opt-out of these types of necessary or informational communications.

Should you no longer wish to receive marketing emails, you may unsubscribe by clicking on the “unsubscribe” link within the text of the email. Alternatively, you may email USprivacy@lge.com and request to be unsubscribed from such marketing emails.

G. Sensitive personal information

We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Programs, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Programs, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Programs.

H. Your Rights

California – California Consumer Privacy Act (“CCPA”): This section provides information regarding rights of California residents and how to exercise them. The sections above – “How We Collect Information,” “The Information We Collect,” “How We Use Information and legal bases for processing” and “Sharing Your Information” – describe the personal information we collect by reference to the categories of personal information specified in the CCPA.

You have the right to (a) know what personal information LGEUS has collected about you (including the specific pieces of that information), the categories of sources from which the personal information is collected, the business or commercial purpose for collecting that information, the categories of third parties with whom LGEUS shares personal information, and whether it sells that information to third parties, (b) to have LGEUS delete your personal information, (c) to opt out of any sale of your personal information, and (d) not be discriminated against for exercising any of these rights.

LGEUS does not sell your personal information in connection with the Programs.

As a California resident, you may appoint an authorized agent to exercise your rights on your behalf. In order for us to honor a request made by your agent, you must submit proof of your written authorization of the agent to CAprivacy@lge.com prior to submitting a request.

California - How to exercise your data privacy rights: LGEUS takes your privacy seriously. LGEUS provides a webform that you can use to exercise your privacy rights, which can be accessed here: https://www.LG.com/us/caprivacy or by calling LGEUS customer service at 833-660-0245 for assistance.

In submitting a request, LGEUS may ask you to verify your identity so that we can protect you against fraudulent requests for your information. Thus, LGEUS may ask you to provide information about your participation in the Programs, or other confirming information.

California – Shine the Light. You have the right to be provided with a description of any categories of information that LGEUS disclosed to third parties for their direct marketing purposes and to know the identity of those third parties. To make such a request please contact us at CAprivacy@lge.com.

California – Eraser Law. If you are a California resident under the age of 18, then you may request that we remove any submission you publicly posted on or in the LGEUS Websites. To request removal of a submission, please email a detailed description of the submission to CAprivacy@lge.com. You may also be able to log into your account and delete your own submission. LGEUS reserves the right to ask you to provide information that enables us to confirm that the submission in question was created and posted by you.

European Economic Area - Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679: This document – the LGEUS privacy policy – provides notice to European Economic Area consumers regarding the personal information collected, the sources of the personal information, the use of the personal information and the grounds for such use, a description of how LGEUS shares that personal information, and your privacy rights.

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold. You have the right to:

  1. Rectification - Where any of the personal information we hold about you is incorrect, you have the right to request rectification of this.
  2. Erasure and restriction of processing - You have the right to request erasure of your personal information or to request a restriction on how we use it, these rights are not absolute and we may need to retain your personal information, for example to comply with a legal obligation, or to exercise or defend a legal claim
  3. Object - You have the right to object to your personal information being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
  4. Access - You have the right to request information concerning the personal information we hold that relates to you.
  5. Data Portability – You have the right to receive a copy of your personal information in a machine readable, commonly used format (or to request we transfer your Personal Information in such a format to a third-party service provider).

European Economic Area - How to exercise your data privacy rights: You can contact our EEA Data Protection Officer at dpo-eu@lge.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

You may also have the right to lodge a complaint about our use of your personal information or our response to your requests regarding your personal information. For any complaints, we request that you contact us first to try and resolve any issue, but of course you are also entitled to make a complaint with the data protection regulator in your jurisdiction. If you are based in Europe, you can find your data protection regulator here. If you are based in the UK, you can make a complaint directly to the Information Commissioner’s Office.

I. Where is your Information - International Transfer of Information

LGEUS is based in the United States. However, in connection with the Programs, LGEUS may share or transfer your information within its corporate umbrella (e.g., with its parent company headquartered in South Korea) or with external service providers that are outside of the United States.

If we transfer your personal information out of Europe or the UK to a country, like the United States of America, that it is not considered by the European Commission and the UK Government respectively to offer an equivalent level of protection of privacy to the one applicable in the EEA and the UK, the transfer will be performed:

  • Pursuant to the recipient’s compliance with standard contractual clauses, or Binding Corporate Rules
  • Pursuant to the consent of the individual to whom the personal information pertains
  • As otherwise permitted by applicable European requirements.

J. Collection and Use of Information from Children Under the Age of 18

LGEUS does not knowingly collect or solicit information from anyone under the age of 18 in connection with the Programs or knowingly allow such persons to participate in the Programs. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.

K. Third-Party Web Sites and Cookies

This privacy policy applies solely to information collected in connection with the Programs. Program materials may contain links to other web sites or services. Any information you provide to these third parties is subject to that third party’s privacy policy. We are not responsible for the privacy practices or the content of these other websites or third-party cookies.

L. Do Not Track

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities.

M. Changes to this Privacy Policy

We reserve the right to change this privacy policy from time to time in our sole discretion. When we do, we will also revise the "last update" date at the top of this privacy policy. If material changes are made to the privacy policy, we will notify you.

N. Security

We make reasonable efforts to ensure security on our systems, however, no data transmissions over the Internet or via postal mail can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to LGEUS is done at your own risk.

O. Contacting LGEUS

If you have any questions about this privacy policy or our privacy practices, please contact us at USprivacy@lge.com. All information you provide in any written communication will also be covered by this policy.