Data protection policy

Kärcher Pty Ltd

Datenschutz

About

This policy provides detail on how Kärcher Pty Ltd ("the Company") manages personal information.

The Company recognises the importance of your privacy and understands your concerns about the security of any personal information that you have provided to us. When we handle such information, we will ensure strict compliance with the Privacy Act 1988 (Cth) ("the Act"). For point of reference, the Act details how personal information is collected, used, disclosed, stored and destroyed and provides how individualsmay be able to gain accessto any personal information held about them.

Collecting Personal Information About You

Personal information isinformation 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.

We collect personal information from you when you complete an online registration or database purchase. The Company also collects personal information from contact lists for marketing purposes through our contact 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 law. The type of personal information collected will depend on the nature of your dealings with the Company and may include your name, address, phone number, email address and your employment details.

Kärcher Programme and Kärcher Home & Garden Applications

We may otherwise collect or have accessto your personal information through your use ofthe “Kärcher Programme” application or “Kärcher Home & Garden” application ("Apps"). 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: data.privacy@de.kaercher.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 user name, 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.

2) 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 the Company each time you login:

  1. When logging in using Facebook: Facebook ID, first and surnames stored in Facebook, email address (if you log in via Facebook).
  2. When logging in using Google: Google ID, first and surnames stored in Google+,
    email address.
  3. 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 the Company by the respective provider without the Company requesting it. The Company only stores your Facebook ID, Apple ID or Google ID and the email address that the user has entered there.

3) To enable your use of the App - your device will provide us with:

  1. Your device identification (e.g. model name, device category, brand);
  2. Your unique device ID recorded (UUID (UniversalUnique Identifier) for Android devices, IDFV (identifier for vendor) for iOS devices);
  3. Date and time of device;
  4. Screen tracking (tracks how movements are made in the App);
  5. Access status/HTTP status code;
  6. Device IP address;
  7. Volume of data transmitted;
  8. App version;
  9. Browser;
  10. Country and language of the device;
  11. Crash reports;
  12. SSID of the home network and RSSID;
  13. Kärcher device list;
  14. Type and version of the operating system of your end device; and
  15. 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 Kärchersmart 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).

4) 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.

5) Newsletter

You can subscribe to the Kärcher email newsletter by ticking the checkbox.

Description and scope of data processing

Subscribing to our newsletter

On our website you have the option to subscribe to a free newsletter. When you register for the newsletter, the data you enter on the input screen (title, first and last name, email address, newsletter preferences) are transmitted to us and stored. In addition, the following data are collected when registering: Date and time of the registration

As part of the registration process, your consent is obtained for the processing of the data and reference is made to this Privacy Policy. Once you have subscribed to our newsletter, we will regularly send you information on our promotions, offers and services by email. 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 receive 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. Unconfirmed profiles are deleted in the system after 3 months.

If you subscribe to the newsletter on certain forms (e.g. the product registration form "Register & Win", warranty extensions, checkout from the online shop) or if you have subscribed the newsletter in the past, the information from this form as well as your online shop purchase history will be added to your existing newsletter profile or used as a basis for creating a new newsletter profile. This information is used to personalise newsletters in order to provide you with the most suitable information on our promotions, offers and services.

Newsletter for existing commercial customers

If you are an existing customer and were informed of your right of objection when your email address was collected and upon each use, we may process any of your data (first and last name, email address) that are available to us in order to send you regular information about our promotions, offers and services by email. If you wish, you can object to the relevant notices at any time.

Measuring opening and click rates

To improve our newsletters, we measure opening and click rates. To do this, the newsletters contain a pixel-sized file (a so-called tracking pixel), which is retrieved from our server or that of our mailing service provider when the newsletter is opened. As part of the retreival process, technical information, such as information about the browser you are using and your system as well as the time of retrieval, will first be collected.

This information is used to improve our newsletter from a technical perspective based on the technical data or the target groups and their reading behaviour. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked on. This information is assigned to the respective recipient and stored in their profile. We use these analyses to identify the reading habits of our visitors and adapt our content to suit them or to send different content that aligns with our visitors’ interests.

Unless otherwise stated, no data will be passed on to third parties outside the Kärcher Group in connection with the data processing for sending the newsletters. The data are used solely to send the newsletter.


Legal basis for data processing

The legal basis for the processing of data after subscribing to the newsletter is the user granting their consent under Art. 6 (1) lit. a GDPR. The legal basis for processing the data of existing customers or for adding form or product data as from chapter 1.a) is our legitimate advertising interests (Art. 6 (1) lit. f GDPR in conjunction with § 7 (3) of the Act against Unfair Competition (UWG)) in sending interest-based advertising.

Purpose of the data processing

The visitor's email address is collected in order to deliver the newsletter. The other personal data collected as part of the registration process is used to prevent misuse of the services or of the email address used.

Duration of storage

The data will be erased as soon as they are no longer required to achieve the purpose for which they were collected. Therefore, the visitor's email address will be stored for as long as the subscription to the newsletter remains active. Your email address will be blocked and erased from our newsletter mailing list after four weeks 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 Policy.

Possibility of revocation (if consent has previously been granted) and objection (in the case of § 7 (3) of the Act against Unfair Competition (UWG)

The data subject can revoke consent to the sending of the newsletter at any time. To this end, a corresponding unsubscribe link can be found in each newsletter. Otherwise, the data subject may object to processing based on legitimate interests (Art. 6 para.1 lit.f GDPR) at any time by sending an email to privacy@au.karcher.com

6) 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 the Company 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.

7) Local Storage – The Company 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.

8) 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.

9) 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:

https://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=201909010

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.

10) Google Firebase – If you use the App on your tablet, we also use the technology of Google Firebase which allows us to analyse the use of the App. Anonymous usage information is collected by the App and forwarded to Google. For this purpose, Google uses the advertising ID of your end device and uses thisinformation to analyse the use of our App and to provide us with additional services associated with the use of App. You can limit the use of the advertising ID in the settings of your end device.

The Kärcher Home & Garden App uses the following Google Firebase services:

  • Google Analytics for Firebase makes it possible to analyse the use of the Kärcher Home
    & Garden App.
  • Firebase Crashlyticsis used forstability and improvement of the KärcherHome & 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/;
  • and https://firebase.google.com/support/privacy

The Company accepts no responsibility forthe 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 privacy@au.karcher.com.

 

How do we use and disclose personal information?

The Company 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 orservices offered by us, as well as any promotions orsales 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 1800-675-714 or marketing@au.karcher.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 is otherwise allowed by law.

Transfer of Information Outside of Australia

We may disclose your personal information to a person or organisation outside of Australia. The Company takesreasonable stepsto ensure that any overseas recipient complies with the APPs. We will not send your personal information outside of Australia unless:

  • it is necessary to complete your transaction; or
  • you have provided your consent; or
  • we believed on reasonable grounds that the organisation involved would only deal with your personal information in a similar manner to the requirements under the APPs; or
  • where otherwise allowed by the Privacy Act 1988 (Cth).

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. The Company 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.

The Company uses secure methods to destroy or permanently de-identify your personal information when it is no longer needed. The Company will retain personal information while it is required for any of its functions, or for any other lawful purpose.

Changes to this Privacy Policy

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 and Correction

You can request accessto your personal information held by us or request corrections to your personal information held by us by sending an email to marketing@au.karcher.com. In most cases, you will be able to gain access to your personal information held by the Company. 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 privacy@au.karcher.com.


How to Contact Us

You can contact us at the following address:

Privacy Officer
Kärcher Pty Ltd
385 Ferntree Gully Road
Mount Waverley VIC 3149
Tel: 1800 675 714