We, Ecovacs Europe GmbH (hereinafter referred to as “we”, “our” or “Ecovacs”) fully understand the importance to protect your privacy and are committed to safeguard your privacy. To fully safeguard your data subject rights, we will use this Privacy Protection Statement (hereinafter referred to as “Statement”) to fully disclose and keep you informed of the categories, purposes, and protection of your personal data.

Please read this Statement carefully before you submit your information. In particular, those terms in bold require your special attention and meticulous reading. Once you click to submit your data, you will be deemed as giving consent to provide your data to us and authorize us processing your data as per this Statement. 

This Statement is a supplementary to the ECOVACS HOME Privacy Policy. Any issue not set out in this Statement will be dealt with according to the Privacy Policy. In the event of any conflict or inconsistency between the Statement and Privacy Policy, this Statement shall prevail as to the applicable “
T20 Product Potential Incident
”(hereinafter referred to as “Program”).
 
  1. Categories and usage of your personal data that we may collect
As indicated in the Program notification, in order to provide you with more satisfactory and suitable services, we may collect some of your data as described in below table. Processing this data is necessary to offer you the product functionality and services as promised pursuant to our existing contractual arrangements. The legal basis is Art. 6 (1) b) GDPR. We ensure you that such data will not be used for any purposes other than those disclosed to you in this Statement or otherwise permitted by the applicable laws and regulations.
 
Categories of data Purposes/scenarios for data use
Name We collect such data in order to identify target users and ship mopping plate to your address.
Address
Country
Serial number We collect such data in order to identify target device
E-Mail Address We collect such data in order to get in touch with you to verify the device information
Phone number We collect such data in order to identify target users and ship mopping plate to your address
 
  1. Special provision on privacy of minors

We would like to remind you that, minors under the age of 18 (or if you are a minor pursuant to the laws and regulations where you reside) are not included as the targeted group of this Program. In case we occasionally collected data related to minors, such data will be deleted immediately. If you find that we have collected data of minors, please feel free to contact us under the contact information listed in Section 5 of this Statement. Upon recipient, we will delete the relevant data in time after we have reviewed and confirmed the collection.
 
  1. How we store and protect your personal data
  1. Storage location and cross-border transfer of personal data

Data collected in this Program will be stored in servers located in European Union. However, since the research and development team, maintenance and customer service team who support in this Program are based in our headquarters located in the People’s Republic of China (P.R.C), your personal data we have collected in this Program will be transferred and stored in P.R.C.

You understand and agree that when you click to submit the data, you will be deemed to have fully understood and agree that your personal data will be transferred outside your jurisdiction and stored in China. If you refuse such transfer, you should immediately stop submitting relevant data.
We will take necessary and reasonable data security protection measures when transferring your personal data outside your jurisdiction on the premise of providing appropriate safeguards in accordance with the data security requirements in your jurisdiction. These measures include but are not limited to signing standard contractual clauses approved by the European Commission in accordance with the General Data Protection Regulation (the GDPR) and / or the applicable laws in your jurisdiction, data encryption or de-identification methods, etc. You may contact us through the contact channel disclosed in this Statement to know more about the protection measures related to the international transfer of your personal data.
 
  1. Period of storing personal data

We will store the data submitted by you for the period necessary to fulfill the purposes outlined in this Statement or required or permitted by the applicable laws and regulations. If the data you provided become unnecessary to achieve the above purpose, we will delete or anonymize the data provided without delay. 
 
  1. Protection for personal data
We undertake to maintain data security to the level as specified by the applicable laws and regulations. In order to keep your data safe, we commit to apply various security technologies and associated management systems to protect your data from being disclosed. We have established our personal data protection department. We have also developed relevant internal policy to strictly control data access procedures and approval mechanisms. We seek to only give employees who may access to your data the least authority and limited data access sufficient for fulfilling their duties.

Please understand that due to the limitation of technologies or potential malicious attacks, personal
data security incidents may unfortunately occur due to factors beyond our control. If an incident
occurs, we will, in accordance with laws and regulations, immediately notify you of: general facts
and potential influences of the incident, measures we have adopted or will adopt, advice for you to
protect your data and reduce risks, our remedial measures for you, etc. We will inform you by email,
letter, telephone or by pushing notifications. If we cannot contact you individually, we will publish
notifications in a reasonable and effective manner. We will also report the result of personal data
security incident to regulatory departments if required.
 
  1. How we entrust, share, transfer and disclose your personal data

For the purposes of this Program, below listed the third parties who we may disclose your personal data to, and who can obtain and/or process your personal data. We undertake to prompt such service providers to abide by the applicable laws and process your personal data only for the purposes listed in this Statement.
 
  1. Customer Service Support by our affiliate
  1. Company name, location: 苏州科沃斯机器人电子商务有限公司located in  mainland China
  2. Processing activities: based on the customer service resources maintained by the headquarter, this Ecovacs affiliate will use the data collected to arrange the authorized customer service partner in your jurisdiction to handle the order of parts and send it to you in a most efficient manner.
  3. What type of data is accessed: name, address, country, serial number, E-mail address, , phone number
  4. How the third party process the data:. According to your authorization in this Statement and our instructions.
  5. Contacts of third party: https://www.ecovacs.cn/policy/contactus; http://www.ecovacs.cn/policy/privacy
 
  1. The authorized customer service provider entrusted will involve the handling of your data necessary to provide the delivery services to you.  In this condition, we take steps to prohibit the third party from using your data except for the specific purpose for which we supply it to that third party.
 
  1. How we safeguard your rights and interests regarding your personal data

You are entitled to the following rights as a data subject in accordance with Articles 15 to 21 GDPR:
1. Right of access, rectification, erasure or restriction of processing – Art. 15, 16, 17, 18 GDPR: You may request access to your personal data, correction of incorrect or incomplete personal data, or deletion of your personal data.
2. Right of withdrawal Art. 7 (3) GDPR. Insofar as the processing of your personal data takes place on the basis of consent, you have the right to withdraw your consent at any time with the effect for the future. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
3. Right to object - Art. 21 GDPR. If the processing is based on our legitimate interests or the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, you may, on grounds relating to your particular situation, also be entitled to object to the processing of data at any time. This can be done via contacting us under the contact information listed in this Statement.
4. Right to data portability - Art. 20 GDPR. Insofar as the processing of your personal data is based on your consent or on a contract with you or the processing is carried out by automated means and you have supplied us with your personal data, we will, upon request, provide you with your personal data in a machine-readable form in order for you to use such data with other service providers.
5. Right to complain - Art. 77 GDPR. You may at any time refer your complaint to the relevant regulator in your jurisdiction if you believe that our processing of personal data violates the applicable laws on personal data protection. For us, the Landesbeauftragte für den Datenschutz und Datasfreiheit Nordrhein-Westfalen is our competent supervisory authority.

If you have any questions, complaints or comments related to this Statement, our implementation of the applicable laws on personal data protection, or would like to exercise your rights as specified herein and by the applicable laws, please contact us under the contact information listed below:

Contact Information:

Controller of Personal Data:
Name: Ecovacs Europe GmbH
Address: Holzstraße 2, 40221 Dusseldorf, Germany
Phone+49 (0)211 5380 4300
Email: data-privacy@ecovacs.com
Website: www.ecovacs.com/de

Data Protection Officer:
Name: DataCo GmbH
Address: Dachauer Str. 65, 80335, Munich, Germany 
Phone: +49 (0) 89 7400 458 40
Email: datenschutz@dataguard.de
Website: www.dataguard.de