Data notice

DATA NOTICE: HANDLING OF PRODUCT / RELATED SERVICE DATA FOR EBL CLOUD SERVICE

Panasonic is committed to ensuring that any Product Data/Relevant Service Data (as explained below) is used fairly, lawfully, and securely. We place high importance on compliance with the EU Data Act (Regulation (EU) of 13 December 2023 on harmonised rules on fair access to and use of data and amending Regulation (EU) 2017/2394 and Directive (EU) 2020/1828 (Data Act.

This Notice is intended to tell Users how we handle any Product Data/Relevant Service Data generated by the use of the Panasonic Products or Relevant Services, what rights and obligations Users have for such Data, how Users can get access to such Data and where to go in case of complaints.

GENERAL

Panasonic Fire & Security Europe AB, Jungmansgatan 12, 211 11, Malmö, Sweden is responsible for the handling of Product Data/Relevant Service Data as the “Data Holder” under the EU Data Act (“we”, “us” or “our” in the following)                 

The present notice covers the EBLCloud Service that falls under the EU Data Act.

WHAT PRODUCT / RELATED SERVICE DATA IS BEING GENERATED THROUGH THE USE OF OUR PRODUCT / RELATED SERVICE?

The following Data is being generated through your use of our Product and / or Related Service. Some Data are subject to additional or special provisions:

  • Personal Data, we refer to the Privacy Notice
  • Trade Secrets and Cyber Security, please see the Terms and Conditions for the Related Service
Product Data Special regime Collection Frequency Storage Duration of retention Access
“Identity Data”: Including your first name, last name, title, e-mail address and username or similar identifier. Personal Data/ Cyber Security At set up of the service and any changes initiated by user Cloud server For the duration of your use of the Service Directly from Service and on request
“Location Data”: Address, time zone,   At set up of the service and any changes initiated by user Cloud Server For the duration of your use of the Service Directly from Service/On request
“Product/Device/Application Log Data”:  Mac address, EBL System components, Event log   Real time Cloud Server For the duration of your use of the Service Directly from Service/On request
“Usage Data”: user log, event log   Real time Cloud Server For the duration of your use of the Service Directly from Service/On request

Metrics: Data for analytics

   Real time   For the duration of your use of the Service On request

 

WHAT DO WE USE THE DATA FOR?

We undertake to use the Data that are non-personal Data only for the purposes as follows

  • performing an agreement with the User or activities related to such agreement (e.g. issuing invoices, generating and providing reports or analysis, financial projections, impact assessments, );
  • providing support, warranty, guarantee or similar activities or to assess User’s, Data Holder’s or third party’s claims (e.g. regarding malfunctions of the Product) related to the Product or Related Service;
  • monitoring and maintaining the functioning, safety and security of the Product or Related Service and ensuring quality control.
  • improving the functioning of any product or related service offered by the Data Holder;
  • developing new products or services by the Data Holder, by third parties acting on behalf of the Data Holder (i.e. where the Data Holder decides which tasks will be entrusted to such parties and benefits therefrom), in collaboration with other parties or through special purpose companies (such as joint ventures);
  • aggregating these Data with other data or creating derived data, for any lawful purpose, including with the aim of making available such aggregated or derived data to third parties, provided such data do not allow specific data transmitted to the Data Holder from the connected product to be identified or allow a third party to derive those data from the dataset.

We undertake not to use the Data to derive insights about the economic situation, assets and production methods of the User, or about the use of the Product or Related Service by the User in any other manner that could undermine the commercial position of the User on the markets in which the User is active.

WHO WILL WE SHARE THE DATA WITH?

We may have to disclose the Data to the following categories of recipients for the purposes set out above: 

  1. Panasonic Holdings Corporation and Affiliates
    We may need to transfer your Personal Data within the Panasonic Group of Companies. All companies within the Panasonic Group are required to follow strict information security regulations and can only process the Data in line with this Notice and the contract with the User.
    Service Providers
    We use external service providers to provide us with information technology, systems administration and customer services, and to help us manage certain activities and services on our behalf, and we will contractually bind such parties to only act in accordance with our instructions and not to use the Data for any purposes or in any way going beyond the use that is permissible in accordance with this clause and to otherwise comply with protection measures and restrictions set out in this contract.
  2. Third parties when required by Law or to Protect our Business and Services
    We will disclose your Data to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; to protect our customers (e.g., to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g., to prevent or stop an attack on our systems or networks); to protect the health and safety of our colleagues and others with whom we have contact; or to protect the rights or property of Panasonic, including enforcing any terms or agreements governing the use of our Services.
  3. Other Parties in Connection With Corporate Transactions
    We may disclose the Data to a third party or within the Panasonic Group of Companies as part of a reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of Panasonic's business, assets, or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

ACCESSING DATA

Under the EU Data Act, Users have the right to access the Data generated by Connected Products or Related Services as well as to give access to third parties (Data Recipients).

When the User is not the data subject, we will only make the Data which is personal data only available to the User or to a Data Recipient, when there is a valid legal basis for making personal data available under Article 6 of Regulation (EU) 2016/679 (GDPR) and only, where relevant, the conditions set out in Article 9 of that Regulation and of Article 5(3) of Directive 2002/58/EC (Directive on privacy and electronic communications) are met.

 

How can the User access the Data?

The Data will be accessible directly from the Service, see the overview above. When this is the case, the User will be able to download and erase data.

Some Data can only be accessed on request, see the overview above. For such data, at the request of the User or a party acting on their behalf, we will make the Data accessible to the User without undue delay. The request can be made by sending a mail with the request to support.pfseu@eu.panasonic.com.

We may ask for information to verify that the request is made by the User, but this shall not go beyond what is necessary. If the request is made by a party acting on behalf of the User, evidence of their mandate must be provided.

If the User is not the Data Subject, the User must indicate to the Data Holder, in each request, the legal basis for processing under Article 6 of Regulation (EU) 2016/679 (and, where relevant, the applicable derogation under Article 9 of that Regulation and Article 5(3) of Directive (EU)2002/58) upon which the making available of personal data is requested.

We will make the Data available in the following way:   via a secure-convenient electronic medium the Data can be made available by Data Holder to the User, either by transfer or access, and in for the Data suitable format.

We undertake not to keep any information on the User’s access to the requested data beyond what is necessary for:

  • the sound execution of (i) the User’s access request and (ii) the contract with the user;
  • the security and maintenance of the data infrastructure; and
  • compliance with our legal obligations to keep such information.

 

How can the User give access to third parties (Data recipients)?

Upon request from the User or a party acting on its behalf, we will make the Data accessible to the Data Recipient free of charge for the User. The request can be made by sending a mail with the request to support.pfseu@eu.panasonic.com. We may ask for information to verify that the request is made by the User, but this shall not go beyond what is necessary. If the request is made by a party acting on behalf of the User, evidence of their mandate must be provided.

When the User is not the data subject, the User must indicate to us, in each request presented under the previous clause, the legal basis for processing under Article 6 of Regulation (EU) 2016/679 (and, where relevant, the applicable derogation under Article 9 of that Regulation and Article 5(3) of Directive (EU) 2002/58) upon which the making available of personal data is requested.

We will make the Data available to a Data Recipient with at least the same quality as they become available to the Data Holder, and in any case in a comprehensive, structured, commonly used and machine-readable format, easily and securely.

Where the User submits such a request, we will agree with the Data Recipient the arrangements for making the Data available in accordance with Chapter III and Chapter IV of the Data Act.

COMPLAINTS

If the User has issues getting access to the Data and if the User notifies us with a detailed description of  such issues, we will cooperate in good faith to identify the reason of such issues and, where this is due to our failure to comply with our obligations under this notice, our contract with the user or under the Data Act, we will remedy this within a reasonable period of time. This is without limitation to the User’s rights under our contract with the user.

If the User is not satisfied with how we handle the Data, the User is entitled to lodge a complaint with the competent authority, designated in accordance with Article 37(5), point (b) of the Data Act.

CONTACT US

For any questions regarding the handling of Data, request access to the Data or technical issues with access, please contact us at:

Support.pfseu@eu.panasonic.com

You can also contact our EU representative at
Panasonic Europe B.V. Germany Branch
Hagenauerstrasse 43
D-65203 Wiesbaden