Asia Pacific Dell Privacy Statement

Information we directly collect from you: The types of information we collect about you depend on your use of our products, services, and the ways that you interact with us. This includes personal information you provide when you:

• Apply for, purchase and/or use our products or services, including financial services to commercial customers.
• Create an account on our websites.
• Access our websites.
• Subscribe to our services or publications.
• Request marketing to be sent to you.
• Enter a competition, promotion, or survey.
• Give us feedback, provide a testimonial or contact us.

Information we collect from third-party sources: Subject to the services we provide, we also obtain information from third-party sources, including the following sources:

• Analytics providers, advertising networks, and communication services providers, including email providers and social networks, when you allow access to your information available on third-party services or networks. This may include data collected through cookies, pixels, and similar tracking technologies used in the AdTech ecosystem, which help us understand your interactions with our advertisements and improve our marketing efforts.
• Partners with which we offer co-branded products or services or engage in joint marketing activities.
• Publicly available sources, such as open government databases.
• Credit and fraud prevention agencies.
• Insurance companies, brokers and administrators.
• Auditors, regulators and supervisory bodies.
• Public authorities and law enforcement agencies.

The data we collect from the sources mentioned above includes:

• Contact data, identity data, first name, last name, title, job title, date of birth, gender, address, email address, telephone number, or similar identifier, proof of identity which may include photographic ID.
• Payment data, bank account details payment card details, transaction details, finance application details and records, details about payments to and from you, and the results of any checks (for financial services) we carry out about you.
• Transaction data, details of products and services you have purchased from us.
• Cookies and tracking information, such as internet protocol (IP) address, your login data, access times, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, the Uniform Resource Locator (URL), and other technology on the devices you use to access this website.
• Account data, including identity data, your username, password, password hints, and similar security information, used for authentication and MyAccount access. 
  Preferences data, such as purchases or orders made by you, your interests, feedback, and survey responses.
• Usage data, information about how you use, interact, and access our website, products, and services, and information relating to operation of Dell products and services. This includes system information related to your device, system, or network (such as your Dell Service Tag, IP address, hardware model, operating system version, hardware settings, installed Dell Solution, system and application configuration data, and MAC address) and how your device, system, network interacts with Dell Solution (such as statistical information, network connection indicators, system crashes, data logs, and routing).
• Troubleshooting information, error reports and product performance information, and any problems you experience when you contact Dell for technical support or customer support services, phone conversations, or chat sessions with our representatives, which may be monitored and recorded.
• Marketing and communications data, your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated data, statistical or demographic data. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. 

We describe below ways we may use the various categories of your personal information and the legal bases we rely on to do so.

Purpose/Use	Type of data	Legal basis
To provide and improve our products and services, including: (a) register you as a new customer and maintain your account (b) process and deliver your order or service, (c) facilitate and manage payments and fees, (d) process any contract or business arrangement, (e) collect and recover money owed to us;  (f) undertake analytics;  (g) provide artificial intelligence technology in our products; and (h) develop and test product and service improvements to see if a product or service is working; troubleshoot and fix it when it’s not; test out new products and services; and conduct surveys about what you like about our products and services and what we can do better.	Contact data Payment data Transaction data Account data Cookies and Tracking Information Usage data Preference Marketing and Communications data Troubleshooting information	Performance of a contract with you For our legitimate interests (e.g., to develop and improve our products) To comply with a legal obligation
To manage our relationship with you, including: (a) Non-marketing communications with you like notifying you about changes to our terms or privacy policy, changes to the products and services, or other important notices. (b) Responding to your requests, complaints and queries	Identity data Contact data Transaction data Account data Troubleshooting information	Performance of a contract with you For our legitimate interests (e.g., to keep our records updated and manage our relationship with you) To comply with a legal obligation
To conduct checks (for financial service offerings) to help detect and prevent against fraud: (a)    Identify you, verify your identity, your organisation’s identity, officers, directors, signatories, Ultimate Beneficial Owners and/or other related parties; (b)    To assess applications for credit or financing that we may receive; and (c)    To conduct sanctions screening checks as may be required by law.	Identity data Contact data Account data Payment data	For our legitimate interests To comply with a legal obligation Performance of a contract with you
To protect the security of our systems and data	Identity data Contact data Cookies and Tracking Information Account data	To comply with a legal obligation For our legitimate interests in other cases (e.g., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and us)
To deliver website content, online advertisements, and marketing communications and measure the effectiveness of the advertising we serve to you	Identity data Contact data Preferences data Usage data Marketing and Communications data Cookies and Tracking Information	Consent For our legitimate interests (e.g., to understand how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy).
To comply with applicable law and to enforce legal rights or defend or undertake legal proceedings	Identity data Contact data Payment data  Transaction data	To comply with a legal obligation. For our legitimate interests (e.g., to protect our business and interests).
To monitor and audit quality and compliance with our own policies and procedures.	Call and/or communication recordings or records	For our legitimate interests To comply with a legal obligation Performance of a contract with you

We may share personal information with:

• Third parties we use to help deliver our products and services to you or otherwise run our business, e.g., payment service providers, warehouses, delivery companies, marketing agencies, website hosts, website analytics providers, etc.
• External auditors or professional advisors, e.g., lawyers and other advisors, in which case confidentiality obligations will bind the recipient of the information.
• Law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations.
• Such third parties to whom we may sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.
• We may disclose your personal data to a third party where you direct and/or authorise us to do so.

We require all third parties to respect the security of your personal information and treat it in accordance with the law. Unless otherwise expressly notified, we do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process it for specified purposes and in accordance with our instructions. 

You may have the following data subject rights if granted under applicable laws, which may also be subject restrictions and exemptions:

• Right to Know: you may have the right to request information about the personal information we have collected about you and for what purpose.
• Right to Access: you may have the right to access your personal information and obtain a copy.
• Right to rectification: you may have the right to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide.
• Right to erasure (‘right to be forgotten’): you may have the right to request the deletion of the personal information that we hold on you.
• Right to restriction of processing: you may have the right to request the restriction of processing of your personal data.
• Right to Portability: you may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to have that information transmitted to another organization in certain circumstances.
• Right to object to processing: you may have right to object to processing of your personal information where we rely on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data.
• Right to withdraw Consent: You may have the right to withdraw consent, where we process your personal information based on your consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

If you wish to exercise your rights, please visit our Privacy Center and submit a request via our Privacy Request Portal Dell-PMC. To help protect the security of your personal information, we may request specific information from you to verify your identity. There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and Dell is legally obligated to keep a record of that.

You have choices about how we reach you with marketing offers and other uses of your information. To update your preferences, you can:

• Click “unsubscribe” in any email marketing communications we send you.
• Go to your MyAccount or visit our Preference Management Center to select your marketing communication choices.
• Go to our List Removal Page to be removed from receiving marketing-related communications.

Please be aware that your email preferences may take up to 10 business days to take effect. Further, even if you opt out of receiving marketing communications, you will still receive transactional communications that are essential for administrative or customer service purposes, such as order confirmations for a product/service warranty registration, updates to our Terms and Conditions, etc.

For more information about the cookies we use and how to change your cookie preferences, please see cookie statement. 

We may transfer your personal information to other companies within the Dell group and to its business partners as permitted by law if required for the purposes described in this Privacy Statement. This may involve the transfer of your personal information to countries outside your home country or region, which may have a different level of data protection from your home country. Such countries may include, without limitation, the United States and other countries in which Dell or its subsidiaries, affiliates or business partners maintain facilities. In order to provide adequate protection for the transfer of your personal information, we have in place contractual arrangements (as appropriate) with our subsidiaries, affiliates and business partners in respect of such transfers. We will take all reasonable technical and organizational measures to safeguard personal information we transfer. 

We use appropriate mechanisms for international data transfers. For example, we rely on Standard Contractual Clauses, approved by the European Commission (and the equivalent standard contractual clauses for the UK or Switzerland, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country. 

We use appropriate technical, organizational, and physical data security safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. We encourage you to keep any passwords you use confidential and to avoid “phishing” scams where someone may send you an email that appears to be from Dell asking for your personal information. Dell will not request your ID or password through email. 

We retain personal information for as long as necessary for us to accomplish the purposes for which the personal information was collected and for any retention periods specified by applicable law. Such legally prescribed retention periods may vary by area. We may retain certain personal information for a longer period to comply with applicable law and respond to or otherwise participate in legal claims. The specific retention period for any piece of personal information will be appropriately calculated to meet the relevant obligations and take into account any specific business needs or uses.

If you are a child/minor as understood by laws of your country, please do not submit any Personal Information through our websites without the express consent and participation of a parent or guardian.

We may sometimes provide links to other websites, which, if you click on them, may collect personal information about you and direct you to those websites. The information practices of those third-party websites linked to our website are covered by the third party’s privacy statements, and we encourage you to read those.

The Dell entity that controls your personal information may differ depending on where you live and the specific Dell products and services you use.

You can email: privacy@dell.com to contact us and our Data Protection Officer if you have any questions about this privacy statement or the information we hold about you, to exercise a right under data protection law, or to make a complaint. 

We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Information, we will revise this Privacy Statement to reflect such changes and revise this Privacy Statement's effective date, included at the end of this section. We encourage you to periodically review this Privacy Statement to be informed of how we are using and protecting your Personal Information.

Last update: February 2025