This policy details how Kärcher Ltd (Kärcher) manages personal information, sets out some of your privacy rights in relation to personal information, and advises how you can contact us with privacy queries.
Your privacy is important to us
At Kärcher, we recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us. When we handle your personal information, we will comply with the Information Privacy Principles,(“IPPs”) as contained in the Privacy Act 2020, which detail how personal information is collected, used, disclosed, stored and destroyed and how an individual may gain access to personal information held about them.
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
Collecting Personal Information about you
We collect personal information from you when you complete an online registration or database purchase. Kärcher also collects personal information from contact lists for marketing purposes and through our call centre.
We aim only to collect personal information for the purpose for which it was provided, for a related secondary purpose, any other purpose you have consented to, and any purpose permitted under the law. The type of personal information collected will depend on the nature of your dealings with Kärcher (e.g., the type of goods or services you have asked us to provide) and may include your name, address, telephone number, fax number, e-mail address, and your employment details.
Kärcher Programme and Kärcher Home & Garden applications
We may otherwise collect or have access to your personal information through your use of the “Kärcher Programme” application or “Kärcher Home & Garden” application (each, an App). Unless otherwise stated, the Apps are made available by our affiliate company, Alfred Kärcher SE & Co.
KG, Alfred-Kärcher-Str. 28–40, 71364 Winnenden, Germany. You can reach the responsible data protection officer at: email@example.com. Other details about the manner in which your personal information is handled can be viewed at any time under the menu item “Settings” within the App.
To enable your use of the App, your personal information will be collected and used as follows:
1. When you download the App – specific personal information will be transmitted to the app store of your choice (e.g., Google Play or Apple App Store). In particular, this may involve processing the username, e-mail address, and customer number of your account, the time of the download, payment information and the individual device identification number. This personal information is exclusively processed by the respective app store and is beyond our control.
1. Setting up and using the App – when you create a user account, we will ask you for your email address. You have the alternative option of registering or logging into the App using your data using the functions “Register with Facebook”, “Register with Apple” and “Register with Google” (hereinafter referred to as Social Login). If you register using Social Login, the following information is transmitted to Kärcher each time you login:
a. When logging in using Facebook: Facebook ID, first and surnames stored in Facebook, email address (if you log in via Facebook).
b. When logging in using Google: When logging in using Google: Google ID, first and surname, email address.
c. When logging in using Apple: Apple ID, first and surnames stored in Apple, email address.
By registering via the Social Login, you give us your consent to process the above- mentioned data for registration and future logins. This information is transmitted to Kärcher by the respective provider without Kärcher requesting it. Kärcher only stores your Facebook ID, Apple ID or Google ID and the email address that the user has entered there.
2. To enable your use of the App - your device will provide us with:
a. Your device identification (e.g., model name, device category, brand);
b. Your unique device ID recorded (UUID (Universal Unique Identifier) for Android devices, IDFV (identifier for vendor) for iOS devices);
c. Date and time of device;
d. Screen tracking (tracks how movements are made in the App);
e. Access status/HTTP status code;
f. Device IP address;
g. Volume of data transmitted;
h. App version;
j. Country and language of the device;
k. Crash reports;
l. SSID of the home network and RSSID;
m. Kärcher device list;
n. Type and version of the operating system of your end device; and
o. Your user behaviour (e.g., searching for or calling up content).
This information is used to enable the technical functionality and operation of the App, as well as for optimisation purposes as part of product improvement.
When you use the Kärcher Home & Garden App to manage your Kärcher smart home devices, the following data is collected, depending on the type and scope of application of the device concerned:
a. General data for device management (e.g., device ID, device name, floor plans of the property concerned, voluntary information on your living environment;
b. Control information as entered by you (e.g., schedules, device settings);
c. Voluntary location-related information as entered by you (street and house number as well as GPS coordinates accurate to the nearest metre when you use the “use my location” function); and
d. Use of device functions (e.g., time and frequency of individual actions, period of use).
1. To enable us to provide our services within the App - we are reliant on contractually affiliated companies of the Kärcher group of companies, as well as the following third-party companies and external service providers:
a. Firebase Analytics
b. AWS services: S3, Elasticsearch Service, Elasticache, Lambda, API Gateway, Cloudfront.
We may disclose your personal information to these third-party companies for our administrative purposes and to enable your use of the App.
2. Newsletter - You can subscribe to the Kärcher email newsletter by ticking the checkbox.
Once you have subscribed to our email newsletter, we will regularly send you information on our promotions, offers and services. We use the double opt-in procedure to send the newsletter. This means that we will only send you an email newsletter once you have expressly given your consent to be sent it. We will then send you a confirmation email in which you will be requested to confirm that you wish to receive the newsletter in future by clicking on a corresponding link.
Should you register for the newsletter by clicking the newsletter checkbox within the app or if you subscribed to the newsletter in the past, the user profile information and the devices added within the app will be either added to your existing profile or used to create a new profile in our newsletter system. This information is aimed at personalising newsletter contents, to provide you with information as relevant as possible concerning our products, services and offers. When you subscribe to the newsletter, we store your IP address as provided by your Internet service provider (ISP) as well as the date and time of subscription in order to trace any potential abuse of your email address at a later point in time. We also store the date and time upon which the confirmation link was clicked in the confirmation mail which is sent for control purposes (double opt-in procedure), and the IP address provided by the Internet service provider (ISP). This data is processed on the basis of your consent.
You can revoke your consent and unsubscribe from the newsletter at any time.
The data you provide us with in order to receive the newsletter and which we store to demonstrate your consent are stored until you are removed from the newsletter mailing list and then erased once you unsubscribe from the newsletter. Your email address is erased from our newsletter mailing list once you have unsubscribed, unless you have expressly consented to the further use of your data or if we reserve the right to use your data beyond this scope in a manner which is permitted by law and about which we have informed you in this declaration.
The email address which you provide to register for the newsletter will not be passed on to third parties. Kärcher only uses Adobe Systems Software Ireland Limited (ADIR), Citywest Business Campus, Saggart, Dublin, Ireland to process data on its behalf. Should you no longer wish to receive the newsletter (Section 14), your email address will be erased from the mailing list.
For the purpose of analysis, the emails sent with Adobe Campaign contain a so-called “tracking pixel” which connects with the Adobe Campaign servers when the email is opened. In this way, it is possible to assess whether a newsletter message has been opened.
1. Cookies - Cookies are stored on your end device when you use the App. Cookies are small text files stored on your end device which provide Kärcher with certain information. Cookies cannot execute programs or transmit viruses to your computer. This information is required for the technical functionality and operation of the App.
2. Local Storage - Kärcher uses local storage technology for temporary local storage of information from your Smart Home device. Local storage uses the storage capacity of your web browser. In other words, data is stored in your web browser. This data is stored on your browser for an unlimited period of time and updated each time you connect to the Kärcher Cloud. You can use your browser settings to check which data is stored in your browser's local storage and also clear the local storage.
2. Kärcher Cloud - The Kärcher Cloud stores the data on a storage location of Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109. Data is stored and processed on servers of Amazon Web Services in the European Union. For this purpose, Kärcher has concluded a commissioned data processing agreement with Amazon with standard contractual clauses.
3. Kärcher Skill for Amazon Alexa - Kärcher Skill for Amazon Alexa can be accessed via the Online service “Alexa” (“Alexa”) of Amazon Europe Core S.à r.l., 5 Rue Plaetis, L-2338 Luxembourg (“Amazon”). Kärcher has no influence on possible further processing of your personal data by Amazon. You can obtain information on the handling of your personal data by Amazon via the Amazon Data Privacy Statement:
For technical reasons it is necessary to forward certain data to Amazon for the installation and use of Kärcher Skill for Amazon Alexa.
· Logging into your Kärcher account;
· Tokens are still used for identification and authentication (Access, Refresh);
· Information for use of Kärcher Skill for Amazon Alexa (log file, date, duration, command);
· Device address of valve and gateway used.
Once you have activated Kärcher Skill for Amazon Alexa in the Alexa App, you can give voice commands to Alexa. In the case of demands on the valve, the requested functions are activated (e.g., start watering, pause watering, pre-book watering). As part of Alexa, you will then hear an acoustic voice output on the status (e.g., watering started, watering paused, watering pre-booked) via your Alexa-compliant device. Kärcher is responsible for the processing of your personal data upon receipt of your personal data after it has been transmitted from Amazon to Kärcher; Kärcher’s responsibility ends as soon as Kärcher has submitted a reply in text form to Amazon for transmission to you.
To execute commands, Amazon forwards the following data to Kärcher:
· The individual “User ID” assigned to you by Amazon for activating Kärcher Skills;
· The questions or requests addressed to Kärcher Skill for Amazon Alexa.
Analyse your use of Kärcher Skill for Amazon Alexa: General use of Kärcher Skill for Amazon Alexa is evaluated in aggregated form using a dashboard provided by Amazon Alexa. There is no individual personal or user-based evaluation. The general evaluation (e.g., number of visits, times of visits, errors in visits) is carried out for the purpose of optimising Kärcher Skill for Amazon Alexa for a better user experience.
The transfer of your personal data in the course of using Kärcher Skill for Amazon Alexa is encrypted using the industry standard Secure Socket Layer (“SSL”) technology. The Encryption Protocol TLS is used for the encryption between Kärcher Skill for Amazon Alexa and the cloud solution used for the valve.
1. Integration of third-party services –
The Kärcher Home & Garden App uses Google’s Firebase technology LLC, 1600
Amphitheatre Parkway, Mountain View, CA 94043, USA (“Firebase”).
Google Firebase generally uses servers located in the European Economic Area for its services. If data are transferred to the USA, Kärcher has concluded a commissioned data processing agreement with Amazon with standard contractual clauses for this purpose, in which Google is required to process users’ data only in accordance with our instructions and to comply with the European level of data protection.
The legal basis for use of the cloud service is a legitimate interest in the analysis, optimisation and user-friendly design of the Kärcher Home & Garden App.
You can find more information on Google Firebase and data protection at: https://firebase.google.com/terms/data-processing-terms; https://firebase.google.com/terms/; https://firebase.google.com/support/privacy/
Kärcher Home & Garden App uses the following Firebase services:
Google Analytics for Firebase makes it possible to analyse the use of the Kärcher Home & Garden App. Information on the use of the Kärcher Home & Garden App is recorded, transferred to Google and stored there. Google uses the advertising ID of the end device. The above information is used to evaluate the use of the Kärcher Home & Garden App anonymously. In the device settings, use of the advertising ID can be restricted (iOS: Privacy/Advertising/ Limit Ad Tracking; Android: Account/ Google/ Ads).
Firebase Crashlytics is used for stability and improvement of the Kärcher Home & Garden App. Information is gathered on the end device used and on the use of the Kärcher Home & Garden App. This includes, for example, the times when the Kärcher Home & Garden App is started and when a crash occurs. This information enables Kärcher to diagnose and solve problems.
Kärcher accepts no responsibility for the proper processing of data by Google, Apple or any other App store provider. Please refer to the data privacy statements of these providers.
There is no further exchange of data with these companies.
If you have further questions regarding the processing of your personal information through your use of the App, please contact our Privacy Officer for assistance by sending an email to firstname.lastname@example.org
How do we use and disclose personal information?
Kärcher will primarily use or disclose your personal information for the purpose for which it was provided to us. For instance, we may use and disclose your personal information:
· to complete the services we provide or in order to supply you or your organisation with goods ordered;
· to provide, operate and improve our various Apps and other technological platforms;
· to perform our administration and other operations including accounting, risk management, record keeping and archiving;
· to better understand our customers’ interests and requirements;
· to assess the suitability of a candidate for an employment position within our business and complete our recruitment and screening processes;
· for complaints handling purposes;
· to improve our products and services;
· online customer reviews;
· for product and recall purposes; and
· to contact customers for market research purposes.
We may also use your personal information (including your business name and address) for related secondary purposes which you would reasonably expect, such as providing you with details about other goods or services offered by us, as well as any promotions or sales relating to our business that may be of interest to you. You can opt out of receiving this information at any time by contacting us on 0800 527 2437 or email@example.com
In some cases, we may disclose your personal information to third parties, such as contractors and service providers engaged by Kärcher, but only if it is required to complete the transaction you have entered into. Additionally, we may disclose your personal information to third parties engaged by Kärcher to provide functions on our behalf, such as mail-outs, marketing research, advertising and the conduct of trade promotions and other competitions.
We may also disclose your personal information where we have sought your consent or as is otherwise allowed by law.
Transfer of Information outside of New Zealand
We may disclose your personal information to a person or organisation outside of New Zealand. Kärcher takes reasonable steps to ensure that any overseas recipient complies with the IPPs.
We will not send your personal information outside of New Zealand unless:
· It is necessary to complete your transaction; or
· You have provided your consent; or
· We believed on reasonable grounds that the organisation would only deal with your personal information in a similar manner to the requirements under the IPPs; or
· Where otherwise allowed by the Privacy Act 2020.
Some of the Apps and other services that you obtain from us may be hosted overseas or operated by affiliates within the Karcher group of companies. Accordingly, when you provide your personal information directly to our affiliates offshore, we may not be involved in this collection of personal information or its subsequent disclosure (if any). If you provide your personal information directly to our affiliates offshore, they may operate in accordance with their own privacy statement that you should make yourself aware of. Further detail regarding our disclosure of your personal information will be provided in each of the apps or platforms.
Storage and Security
We are committed to ensuring that your personal information is secure, accurate and up to date. In order to prevent unauthorised access or disclosure, we have taken all reasonable steps to protect the personal information that we hold from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
Personal information is stored electronically, on paper, or both. Kärcher has physical, electronic and procedural safeguards for personal information and takes reasonable steps to ensure that your information is protected. Data stored electronically is protected by both internal and external firewalls, and access to electronic records is limited by passwords. Only staff with a password have access to all information on the system and files can be designated read-only or no access.
Your personal information is stored within secure premises. Externally, the premises has several barriers to unauthorised entry including secured entry and alarms. Internally, steps are taken to ensure access to personal information is limited including filing in a locked cabinet within a secured office.
Please be aware that personal information provided by e-mail may not be secure. If you have any concerns regarding the security of your personal information, when sending e-mails, please provide information in an alternate form, such as facsimile. We may record your e-mail address if you send us an e-mail.
Kärcher uses secure methods to destroy or permanently de-identify your personal information when it is no longer needed. Kärcher will retain personal information while it is required for any of its functions, or for any other lawful purpose.
In the event that a privacy breach be suffered by Kärcher that is likely to cause anyone serious harm, we will notify the NZ Office of the Privacy Commissioner and any affected persons as soon as practicable in accordance with Privacy Act 2020.
From time to time it may be necessary to amend this policy. Kärcher reserves the right to make amendments to this policy at any time. We will notify you in relation to any change to the policy by posting an updated version of the policy on our website.
Access & Correction
You can request access to your personal information held by us or request corrections to your personal information held by us by sending an email to firstname.lastname@example.org
In most cases, you will be able to gain access to your personal information held by Kärcher. We may provide you with this information verbally or in writing, as may be appropriate. Where we do not agree to provide you with details of personal information we will give you reasons why.
Privacy Concerns or Complaints
If you have any queries or concerns about your personal information, or would like to make a complaint, please contact our Privacy Officer for assistance by sending an email to email@example.com
How to Contact Us
You can contact us at the following address:
Privacy Officer Kärcher Ltd
66 Allens Road
East Tamaki, Auckland 2163 Tel: 0800 527 2437