Privacy Principles

At Positec Group Limited (“Positec”), we are committed to protecting your personal information and respecting your privacy. Our privacy policy applies to all users of Positec websites, mobile applications or apps, and services, including but not limited to eu.worx.com, worx-uk.com, www.landxcape-robotics.com, www.kress-robotik.com, and www.noesisrobotics.com, along with the mobile apps for the Worx Landroid, Landxcape, Mission, Kress robotic mowers and Noesis robotic floor cleaners (collectively, the “Sites”).

Our commitment to respecting your privacy is based on the following principles:

Transparency about the information we collect from you and how we use it.
Using your information only for the purposes described in our Privacy Policy, which include providing you with services you have requested and enhancing your experience with the Positec Group companies and our products.
With your permission, we will use the information to help us understand your preferences so that we can make our offers to you more relevant.
If you tell us you don’t want us to market to you, we will stop sending marketing messages. We will continue to send essential information relating to a product or service you have purchased to keep you informed about your product orders, product safety information and product maintenance.
We will protect your information and keep it secure.

We will respect your privacy rights and allow you control over your personal information.

Our websites, mobile applications or apps are not intended for children, and we do not knowingly collect data relating to children.

You can read our complete Privacy Policy below to get information on how we use your personal information. Our Privacy Policy explains the personal information we collect, how we gather it, how we use it, and who we share it with.

If you have further questions, please get in touch with us by writing to Data Protection Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland or you may email us at [email protected].

Please understand that the Privacy Principles above and our detailed Privacy Policy do not form any part of a contract that you may have with us.

Privacy Policy

This Privacy Policy explains the personal information we collect, how we gather it, how we use it, and who we share it with. If you have questions, please get in touch with us by writing to Data Protection Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland or you may email us at [email protected].

1. Information about Positec

Positec Group Companies and Brands

Positec Group Limited is a Hong Kong company operating worldwide through its subsidiary companies, including, for example, Positec Germany GmbH (Germany), Positec Italia srl (Italy), Positec Power Tools (Europe) Ltd (UK), and Bitec Tools Iberica S.A. (Spain). Positec brands include, for example, Worx, Kress, Landroid, Mission, Landxcape, and Noesis.

Controller of Personal Information

Any personal information processed by Positec in connection with this Privacy Policy is controlled by Positec Germany GmbH, which is considered the “data controller” of your personal information under European Union and UK data protection law. Our address is Data Protection Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland.

The terms “Personal Data,” “Data Controller” and “Processing” have the meanings given to them in the GDPR (which can be accessed at https://gdpr-info.eu/art-4-gdpr/), unless otherwise indicated.

Contacting Us

If you have any questions regarding this notice or complaints about our use of your personal data, please contact us at [email protected] or Data Protection Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland.

2. Application of this Privacy Policy

This Privacy Policy applies to personal information about you that we collect, use and process regarding your relationship with us as a customer or potential customer, including when you purchase our products or use our other services, use our websites or mobile applications, and contact our service agents or call centers.

Please note that this Privacy Policy does not apply to personal information about you that we collect, use and process regarding your relationship with us as an employee, contractor or job applicant. These situations are covered in separate privacy policies. If you are an employee or a contractor and would like to see a copy of the Employee Privacy Policy, please contact your manager. If you are a job applicant and would like to see a copy of the Privacy Policy applicable to you, please contact us at [email protected].

Our Privacy Policy does not cover the data privacy information practices of other companies and organizations that advertise our services and that may use cookies, pixel tags and other technologies to serve and offer relevant ads. It also does not cover any personal data that we may process on behalf of our clients or customers who use our Services, for example, in situations where Positec is serving as a data processor on behalf of a third party. In this situation, Positec does not decide how or why personal data collected through our Services is used — this is decided by the client or customer. If you have questions regarding the personal data your organization has asked you to provide to us as part of our Services, please speak to your organization first. We cannot erase your personal data or provide you with details of the information held about you in our Services without an instruction to do so from our customer so please contact them in the first instance.

3. Collection of your information

We collect personal information about you whenever you interact directly with us, when you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you purchase products from us, when you use our website or mobile applications, when you interact with us via email or use our contact centers, or when you interact with our customer service and after-sales service centers. For example, we collect personal information:

when you download our marketing materials through our website or another party's website;
when you use the Contact Us or similar form on our website;
when you complete any other forms, shopping carts, or product order forms on our website;
through our use of cookies and other IP identification tools;
when you contact us or request information from us regarding our products and services via mail, email, text or telephone, including contacting us for service on a product you have purchased from us.

In addition, we may receive personal information about you from third parties, such as:

Companies contracted by us to provide services to you;
Companies involved in your product purchase, including retail locations and online sellers of our products and delivery and logistics companies;
Companies that provide after-sales service and warranty services for our products; and
Third party referrals.

4. Protection of your information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5. Types of personal information we collect

When you use our services, you may need to provide us with your personal details in order for us to provide the services you have requested.

We collect the following categories of personal information:

Information you provide to us to fulfill a product order or provide a service you have requested from us. For example, if you order a product from one of our websites or call our customer service center for service of a product you have purchased from us, we will collect the information we need to provide you with the product or service such as:
- Identity data: includes first name, last name, username of similar identifier, title.
- Contact data: includes billing address, delivery address, email address and telephone numbers.
- Financial data: includes bank account and payment card details.
If you have purchased an internet-connected product (also known as an Internet of Things, or IoT, product) such as a robotic mower or robotic floor cleaner, an internet-connected power tool or battery, we collect the following categories of personal information:
- Identity data: includes first name, last name, username of similar identifier, title.
- Contact data: includes billing address, delivery address, email address.
- Device(s) data: Internet protocol (IP) address, MAC address, Geolocation data.
If you have purchased a product, such as a robotic mower or robotic floor cleaner with an integrated camera (e.g., vision feature), we collect the following categories of personal information:
- Identity data: includes first name, last name, username of similar identifier, title.
- Contact data: includes billing address, delivery address, email address.
- Device(s) data: Internet protocol (IP) address, MAC address, Geolocation data.
- Visual data: Photographs of the area surrounding your product.
Information about the services we have provided to you in the past. For example, we maintain records of your product purchases and customer service calls to be able to serve you better when you call us or to honor your warranty. For this purpose, we retain the following personal data:
- Identity data: includes first name, last name, title.
- Contact data: includes delivery address, telephone number, email address.
- Technical data: includes telephone logs.
- Product data: includes product serial number, purchase date.
Information about online registration of products you have purchased from us. For example, we keep information you provide to us when you register products on our website about your contact information, product purchase dates and serial numbers in our warranty database. For this purpose, we retain the following personal data:
- Identity data: includes first name, last name, email address, username and password.
Information about your use of our websites, contact centers and mobile applications. For this purpose, we retain the following personal data:
- Identity data: includes first name, last name, title.
- Contact data: includes delivery address, telephone number, email address.
- Technical data: includes telephone logs.
- Product data: includes product serial number and purchase date.
- Device(s) data: Internet protocol (IP) address, MAC address, Geolocation data, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites, IP address or unique device ID.
If you have been browsing on our websites or using our mobile application, we collect the following information about your device(s):
- Device(s) data: Internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites, IP address or unique device ID.

6. Sensitive personal data

Certain types of personal information, for example, information about race, ethnicity, religion, health, sexuality or biometric information, are considered special categories of data requiring additional protection under European Union and UK data protection law. In addition, you may use services (such as product voice commands or website accessibility features) which is not 'sensitive data' but may imply or suggest sensitive personal information.

Generally, we try to minimize the collection and processing of sensitive personal data or data suggestive of sensitive personal data except as necessary to provide products or services you have requested.

7. How we use your personal information and our legal basis for processing it

We have set out below the purposes for which we use your personal information and the specific legal grounds that we rely on when using your information.

A description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so, has been set out in the table below. We have also identified what our legitimate interests are where appropriate.

Purpose of processing/Activity	Type of Data	Our legal basis
To fulfill your product orders and deliver the services you have asked for. To send status updates and service communications to you.	Identity data Contact data Financial data	Contractual necessity — we use your personal information in order to meet our obligations under our contract with you (for example, to deliver a product you have ordered).
To contact you for your opinion, feedback or suggestions for improvements to our products or services. To carry out analysis and market research to improve our communications to you, to improve our products, and to enhance our services provided to you.	Identity data Contact data Technical data Product data	Legitimate interests — the processing is necessary to protect the legitimate interests of the provider or a third party.
To market our products and services to you including online advertising.	Identity data Contact data Technical data	Consent — Users have given their consent for one or more specific purposes. If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time. If you withdraw your consent, it may mean we will not be able to provide all or parts of the services you have requested from us.
To provide you with targeted online advertising. To improve our websites, products and services. For management and administrative purposes.	Device(s) data Identity data Contact data	Legitimate interests — the processing is necessary to protect the legitimate interests of the provider or a third party. Consent — Users have given their consent for one or more specific purposes. If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time. If you withdraw your consent, it may mean we will not be able to provide all or parts of the services you have requested from us.

Purpose of processing/Activity

Type of Data

Our legal basis

To fulfill your product orders and deliver the services you have asked for.

To send status updates and service communications to you.

Identity data

Contact data

Financial data

Contractual necessity — we use your personal information in order to meet our obligations under our contract with you (for example, to deliver a product you have ordered).

To contact you for your opinion, feedback or suggestions for improvements to our products or services.

To carry out analysis and market research to improve our communications to you, to improve our products, and to enhance our services provided to you.

Identity data

Contact data

Technical data

Product data

Legitimate interests — the processing is necessary to protect the legitimate interests of the provider or a third party.

To market our products and services to you including online advertising.

Identity data

Contact data

Technical data

Consent — Users have given their consent for one or more specific purposes.

If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time. If you withdraw your consent, it may mean we will not be able to provide all or parts of the services you have requested from us.

To provide you with targeted online advertising.

To improve our websites, products and services.

For management and administrative purposes.

Device(s) data

Identity data

Contact data

Legitimate interests — the processing is necessary to protect the legitimate interests of the provider or a third party.

Consent — Users have given their consent for one or more specific purposes.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one legal basis has been set out in the table above.

8. Cookies and IP identifiers

We collect information about how you use our websites and the device(s) you use to access these services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet.

We use the IP addresses and device identifiers we collect through our cookies to identify the location of users, for example, to deliver a personalized service, block unacceptable use, or for analysis and research purposes so that we may improve the products and services we offer. Our legal basis for using your personal information in this way is that it is necessary for the purposes of our legitimate interest of improving our services and our website.

9. Marketing Communications

When we have your permission, we will send you marketing communications from our brands such as Worx, Mission, Landxcape, Kress and Noesis. We do sometimes send marketing communications through third party companies who are under contract to provide these services to us.

We will respect your preferences as to what types of communications you wish to receive from us and the channels by which they are sent.

10. Changing marketing preferences and unsubscribing

If you decide you would no longer like us to send you marketing, you can change your preferences at any time by contacting us through one of the following:

If you are a registered user of one of our websites or our mobile applications, you can change your marketing preferences at any time in your account page.
Each marketing communication we send by email will have an unsubscribe option which will allow you to stop receiving further marketing emails to the email address to which the communication was sent.
If you no longer wish to receive marketing materials by text, you may stop any further marketing text messages to that number by replying with the word “STOP”.
You may write us at Data Protection Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland or you may email us at [email protected].

We will respond to requests to stop being sent marketing communications as soon as possible after receiving those requests, but it is possible you will receive some marketing in the period prior to the changes being made to our system.

If you opt out of receiving marketing, you will still receive service communications (as described above) which are necessary, for example, to confirm your order, to provide you with an update on its status, to provide safety and maintenance information on products you have purchased from us, to notify you about your warranty status, or to provide you information on service you have asked us to perform on one of our products.

If you opt out of marketing communications, we will retain your personal information for the purposes of indicating that you do not want to receive marketing communications.

If you wish to change how we use your personal information, including exercising your right to be forgotten, please see the section below, “Your legal rights related to your personal information.”

11. How long we will keep your information

We will keep your information for as long as we need it for the purpose it is being processed for, up to a maximum of 10 years in order to comply with legal record keeping requirements. In limited circumstances, we may keep your personal information for longer than this if we have identified a legal, regulatory or technical reason why this is necessary. For example, where you register your product with us, we will keep the information related to your product purchase so we can fulfill our warranty obligations to you, and after that, we will keep the information for a period which enables us to provide you with information on product maintenance and safety or respond to any complaints, questions or concerns relating to the product. We may also retain your personal information so that we can continue to improve your experience with us.

We will actively review the information we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or customer need for it to be retained.

12. Sharing your information with third parties

Your personal information may be shared with the companies within the Positec Group Limited companies. For a list of the Positec Group Limited companies, please contact us at [email protected] or at Data Protection Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland. We share information with them, so they can assist us in providing services to you and to understand more about you. We have adopted an intercompany agreement, which contains the Standard Contractual Clauses approved by the European Commission and UK, which ensures all Personal Data transferred within the Positec Group Limited companies is protected to the same high standards and in accordance with the data protection laws of the EEA, even if not required by the local data protection legislation.

We may also disclose your personal information to third parties for the purposes described in this Privacy Policy. All third parties with whom we share your personal data are required to protect it strictly in accordance with applicable data protection laws and, where the third party is acting as our data processor, they may only use it for specified purposes and in accordance with our instructions. For example, we may disclose your personal information to the following types of third parties:

Warehouses, logistics companies, shipping carriers and other service providers needed to deliver the products and services you have asked for.
Credit and charge card companies, credit reference agencies and anti-fraud screening service providers to process payments and, where necessary, to carry out fraud screening.
Search engine optimization and website performance analysis companies.
Third party automated email providers to send out marketing communications on our behalf.
In response to a valid, legal request from government and law enforcement agencies such as taxation and customs authorities.
Third party service providers we are using to provide services that involve data processing, for example, to send product usage and maintenance guidance, to carry out marketing initiatives or to run customer surveys on our behalf.
Third parties, such as law firms and law courts, to enforce or apply any contract with you.
Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.
We may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites (see “Cookies and IP identifiers” above).
With your consent, we may provide usage information including your personal details to marketing agencies to deliver online advertising on websites or social networks.
If necessary, to comply with a legal or regulatory obligation in any jurisdiction.

We do not sell personal information to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.

13. Countries in which your information is processed or stored

Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and outside the European Economic Area and the UK.

This may involve sending your data to countries where under their local laws you may have fewer legal rights.

Where your personal information is transferred outside the European Economic Area or the UK because we are using a service provider in a third country, we will ensure that suitable safeguards are in place before personal data is transferred outside the EEA and UK as required by law and we will take all steps reasonably necessary to ensure that your personal information continues to be protected to the standards set out in this privacy policy.

14. Your legal rights related to your personal information

Your rights under the data protection laws in the EEA and the UK include the following:

You may request us to stop sending you marketing. See the section titled “Changing your marketing preferences and unsubscribing” above. If you opt out, we will no longer be able to send you marketing communications. You may request us to stop processing of your personal information for marketing purposes including analytics for the purposes of targeted marketing. Even if you opt out of marketing communications, we may still send you non-marketing communications if you subsequently order product or request service from us.
You may request us to stop using your personal information where we are doing so under legitimate interests. We may, however, continue to process your personal information if we are required to do so to deal with legal claims or if there are other compelling legitimate reasons that override your rights.
You may access the personal information we hold on you. See the section on “Accessing your personal information” below. There may be exceptions to this right that may apply, such as when a request includes the information of another person who has not consented to have their information disclosed.
If the personal information we have is not correct, you have the right to ask us to correct it. You may be able to change the information through your account by logging in directly, or you can contact us to correct the information at [email protected] or write us at Data Privacy Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland.
You may ask us to delete or anonymize the personal data about you that we hold. Upon your request to do so, we will remove the information that identifies you from our active systems.
You may restrict or object to our processing of your personal information.
You may ask to receive a copy of your personal information in a structured, commonly used and machine-readable format so that you may transfer it to another company.
Where you have provided your consent to us processing your personal information, you have the right to withdraw your consent at any time.

When you request us to delete or anonymize the personal information about you that we hold:

We may keep a record of your request including the personal information you supplied as proof of our compliance with your request.
We may keep a copy of the identifying information in a restricted file to meet the obligations we have to law enforcement, national authorities and legal proceedings.
We may need to retain certain elements that relate to a contract between you and us because we need it for our own legal and auditing purposes.
We cannot erase your personal information if we have identified that you either have an open complaint or service request with us.

Some results of your request to delete or anonymize the personal information about you that we hold may include:

We may not be able to provide all or parts of the services you have requested from us in relation to previous purchases or service requests or retain any preferences you have previously shared with us.
You will be required to maintain your own proof of purchase records for warranty purposes.
If you have an account with us, we will close the account.

15. Responding to your data requests

After verification of your request, we will respond to your request to exercise your rights within one month. If your request is especially complicated or time-consuming, we may extend the deadline for responding, but we will let you know if this is the case.

Generally, there is no fee for making these requests. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. If this is the case, we will notify you if we are not able to grant to your request with the specific reason(s) we are unable to do so.

16. Accessing your personal information

If you wish to receive a copy of any of your personal information we hold, please contact us at [email protected] or write us at Data Privacy Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland. Please include the following information with your request:

Your name and address
Details of your request
Your signature and the date of the request

If you are asking for a copy of the personal information on behalf of another person, you will be required to provide us with signed authority from the individual whose information is being requested.

In addition, it will help us to locate the information you are requesting, if you can provide additional information, for example:

Your email address which is associated with the information we have on file
Order number, date of purchase, and product serial number
Date and nature of your service requests, if any
For information regarding telephone calls, information related to the number you call from, the number you dialed, the date and time of your call.

We will acknowledge receipt of your request and ask for information to identify you, which we will use only to process your request. We are required to verify your identity before continuing with your request.

17. Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please inform us if your personal information changes during your relationship with us.

18. Changes to our Privacy Policy

If we change our Privacy Policy, we will publish the updated version on our websites. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Policy.

This Privacy Policy came into effect on the Last Update date shown above, replacing our previous Privacy Policy. This Privacy Policy applies to all information we process about you in connection with your relationship with us as a customer or potential customer.

Please write to the Data Protection Officer if you would like to find out more about any matters to do with this Privacy Policy.

19. Contacting us or our supervisory authority

If you have any questions about this policy, please contact the Data Protection Officer for Positec Group Limited via email at [email protected] or [email protected] or by post at Data Privacy Officer, Positec Germany GmbH, Schanzenstrasse 22, 51063 Köln, Deutschland.

We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact us with any concerns.

In addition to contacting us directly with any concerns, you have the right to complain to the Supervisory Authority in the EU Member State where you are resident or where you work. For further information on your rights, please see the supervisory authority of your country or EU Member State.

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