Data protection provisions of MyLiebherr and the Liebherr SmartDevice app

A. General information

I. What does this data protection policy govern?

The protection and security of your personal data is extremely important to Liebherr-Hausgeräte GmbH. It is accordingly important to us to inform you of the type of personal data we collect when you visit the MyLiebherr portal (https://home.myliebherr.com) and when using our Liebherr SmartDevice app, how we use this data and what your rights are in relation to your data.

II. What is personal data and what does processing mean?

1. “Personal data” is any information that says something about a natural person. Personal data is not only information that makes a direct reference to a specific person (such as the name or email address of a person), but also information that with appropriate additional knowledge a reference to a specific person can be made indirectly.

2. “Processing” means any measures that are carried out with your personal data (such as the collection, recording, organisation, ordering, storage, use or deletion of personal data).

III. What functions do the MyLiebherr portal and the Liebherr SmartDevice app offer?

1. Among other things, the MyLiebherr portal offers a single sign-on service. After one-off registration and authentication at Liebherr-Hausgeräte GmbH, it allows you to access all the restricted areas and content of the Liebherr offers connected to the single sign-on service (from the participating companies of the Liebherr Group and their authorised dealers or other third parties), by logging on with unified credentials and without having to go through a separate registration process again. The MyLiebherr portal also offers the option of a centralised appliance registration that allows you, for example, to check the warranty period of a registered appliance at any time and to use other services that require the registration of an appliance without being required to provide further information. The MyLiebherr portal also gives you the option to use a platform for acquiring Liebherr products from third parties (also known as the “marketplace”) without registering for the single sign-on service. The marketplace is the central platform for all authorised Liebherr Domestic Appliances shops and it allows you to order goods and services from the respective shops without having to re-enter your personal data if you registered for the single sign-on service.

The MyLiebherr portal accordingly includes a single sign-on service that provides you with a centralised registration and log-on feature, an appliance registration function that allows you to register your appliance and the marketplace where you can, for example, obtain accessories and consumables for your Liebherr fridge and freezer from third-party vendors.

2. After registering for the single sign-on service, the Liebherr SmartDevice app allows you to use various functions in relation to your Liebherr fridge and freezer (for example, to control the temperature of your Liebherr refrigerator and freezer) via a mobile device.

3. In future, we intend making even further offers available to you on the MyLiebherr portal and in the Liebherr SmartDevice app. As soon as a further offer is added to the MyLiebherr portal or in the Liebherr SmartDevice app, we will of course inform you by email.

B. Data processing

I. Who is in control of the processing of my personal data?

The body in control (‘the controller’) of the processing of your personal data is

Liebherr-Hausgeräte GmbH

Memminger Strasse 77-79

888416 Ochsenhausen

Germany

Phone: +4973529280

Fax: +497352928408

Email: info.hau@liebherr.com

II. What personal data do we collect and for what purposes and on what legal basis?

1. Log files

a. When the MyLiebherr portal is accessed, the web browser of your device transmits the following data in particular to our web server, which we store in so-called log files:

  • Date of access
  • Time of access
  • URL of the referring website
  • File retrieved
  • Amount of data transferred
  • Browser type and version
  • Operating system
  • Domain name of your Internet access provider
  • IP address

We process this data to be able to detect, trace and prevent instances of misuse of the MyLiebherr portal and thereby ensure data security on our web servers. The legal basis for the processing is Article 6 (1) (f) of the General Data Protection Regulation (GDPR).

b. We only generate error reports in the Liebherr SmartDevice app if you enable this feature in the Liebherr SmartDevice app and expressly give your consent. The error reports contain a crash log file that contains the following data in particular:

  • Local information about your device and SmartDeviceBox (for example, the technical configuration of your device and the version number of your SmartDeviceBox)
  • Communication data between your device, the SmartDeviceBox and our web servers (for example, the connection status of your WLAN and your user principal name “UPN”)
  • Time of the error and the configuration of your Liebherr SmartDevice app (for example, the status of special functions such as SuperCool and SuperFrost)

We process error reports subject to your express consent for the purpose of error analysis and improvement of the functionality of the Liebherr SmartDevice app. For this purpose, the error reports are sent to Liebherr-Hausgeräte Ochsenhausen GmbH, Memminger Straße 77-79, +49 7352 928-0, info.hau@liebherr.com, Liebherr-IT Services GmbH, Oberopfingen, St. Vitus 1, 88457 Kirchdorf an der Iller, Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, +49 22180100, [kunden@microsoft.com] and For Sale Mobile GmbH, Yokohamastraße 2, 20457 Hamburg, +49 40 53799060, [info@for-sale-mobile.de]. Your consent constitutes the legal basis for the processing and is voluntary. Your consent is not a precondition for the use of the Liebherr SmartDevice app. If you do not grant your consent, we will not generate and transmit any error reports. You can make full use of the Liebherr SmartDevice app without granting your consent. You have the right to revoke your consent at any time with effect from the date of your revocation. You can revoke your consent, for example, by deactivating the error reporting feature in the settings of the Liebherr SmartDevice app or by sending an email to info.hau@liebherr.com. The revocation of your consent will not affect the legality of the processing carried out on the basis of your consent until the revocation. If you revoke your consent, we will delete all references to persons from the data in your error reports.

2. Cookies

“Cookies” are small text files that are temporarily stored locally in the memory of your web browser with the data associated with a web site, such as the language and font size selected by you. If you access the MyLiebherr portal via your web browser, we use cookies so that the MyLiebherr portal can be displayed in accordance with your individual preferences. When you log in to your MyLiebherr user account, we use cookies so that you can make use of all the offers on the MyLiebherr portal without additional login processes being required. You can also view the MyLiebherr portal and the Liebherr SmartDevice app without the use of cookies. If you want to prevent the use of cookies, your web browser has an option to prevent new cookies from being accepted and stored. Please refer to the help function of your web browser to find out how to do this with your web browser.

3. Master data of your MyLiebherr user account

a. In order to use the MyLiebherr portal and the Liebherr SmartDevice app, a MyLiebherr user account is required. When creating a MyLiebherr user account (registration), you are obliged to provide the following information:

  • Email address
  • Access password

In order to prevent misuse and misunderstandings, you need to activate your MyLiebherr user account after completing the registration process. In order to do so, we will send you an email with an activation link to the email address that you provided. Your MyLiebherr user account is activated by simply clicking the activation link in the email. We process your email address and your access password to set up a MyLiebherr user account for you. The legal basis for the processing for this purpose is Article 6 (1) (b) of the General Data Protection Regulation (GDPR).

Subject to you having given us your express consent, we process your email address and the information that you voluntarily provided during registration for advertising and information purposes; specifically, to provide you with information about products and offers as well as other advertising information (for example, competitions and newsletters) via email. Your consent constitutes the legal basis for the processing for advertising and information purposes and is voluntary. Your consent is not a precondition for creating a MyLiebherr user account. If you do not give your consent, we will not use your data for advertising and information purposes. You have the right to revoke your consent at any time with effect from the date of your revocation. The revocation of your consent will not affect the legality of the processing carried out on the basis of your consent until the revocation.

b. If you connect a SmartDeviceBox to your Liebherr SmartDevice app, we add the following data to that of your MyLiebherr user account:

  • Serial number of your Liebherr appliance
  • Model of your Liebherr appliance
  • Serial number of your SmartDeviceBox

We process this data in order to be able to provide the services and functions of the MyLiebherr portal and the Liebherr SmartDevice app. The legal basis for the processing is Article 6 (1) (b) of the General Data Protection Regulation (GDPR).

c. No further personal data is stored in your MyLiebherr user account, unless you volunteer such information.

4. Your device data

The Liebherr SmartDevice app requires access to certain functions and your device data for you to be able to use the Liebherr SmartDevice app. In order to do so, you need grant certain permissions on your device. The categories of permissions are defined differently by the manufacturers of devices. On Android, for example, the individual permissions are grouped in permission categories and you can only agree to the permission category as a whole. We however only use the permissions authorised by you to the extent described below:

  • Memory (photos/media/files)

The Liebherr SmartDevice app needs to access the memory to save the required media content on your device for the Liebherr SmartDevice app to function.

  • Camera

The Liebherr SmartDevice app needs to access the camera of your device to be able to take pictures of the interior of your fridge and to display these within the “stock list” function.

  • Information about the WLAN connection

The Liebherr SmartDevice app needs to access the WLAN connection information of your device to connect the SmartDeviceBox to the Liebherr SmartDevice app.

  • Retrieving data from the Internet and network connections

The Liebherr SmartDevice app needs to access the Internet and your network connection to be able to make the functions of the Liebherr SmartDevice app available to you via our web server.

  • Push notifications

The Liebherr SmartDevice app needs to access push notifications so that prioritised messages, such as alerts or reminders, can be displayed on your device.

We process the data of the above-mentioned permissions to be able to provide you with the services and functions of the Liebherr SmartDevice app. The legal basis for the processing is Article 6 (1) (b) of the General Data Protection Regulation (GDPR).

5. Machine data of your Liebherr appliance and usage data of your Liebherr SmartDevice app

a. In order to use the functions of the Liebherr SmartDevice app, in particular the functions “Appliance control”, “Alarm message” and “Reminders”, the Liebherr SmartDevice app needs to access the machine data of your Liebherr appliance and the usage data of your Liebherr SmartDevice app. The machine data consists of all the operating values and statuses of your Liebherr appliance that are communicated, for example, by the temperature, speed, voltage and door-contact sensors. The usage data is all the data generated by the interaction with your Liebherr SmartDevice app, such as the temperature and special settings, e.g. SuperFrost and SuperCool, that you made. The “Appliance control” function allows you to access the appliance status of your Liebherr appliance (for example, the set temperature and the status of the special functions) via your Liebherr SmartDevice app. The “Appliance control” function also allows you to control the temperature of your Liebherr appliance and special functions, such as SuperFrost and SuperCool, via your Liebherr SmartDevice app. The “Alarm message” function notifies you of critical temperatures, for example, in the event of a power failure or if the door of your Liebherr appliance has been left open. The “Reminder” function sends you messages about events that you have predefined, for example, a reminder to replace the air filter.

b. We process the machine data and usage data in order to provide you with the functions of the Liebherr SmartDevice app (especially the functions “Appliance control”, “Alarm message” and “Reminder”). The legal basis for the processing is Article 6 (1) (b) of the General Data Protection Regulation (GDPR).

III. To whom and for what purposes do we transmit your personal data?

In general, we only provide your personal data to third parties if this is necessary for you to be able to use the functions and services of the MyLiebherr portal and the Liebherr SmartDevice app. In addition, we provide personal data to third parties:

  • If and insofar as this is necessary to comply with an existing contractual relationship with you or to enforce claims to which we are entitled
  • If you have consented to the disclosure
  • If we are legally obliged to do so or are required by a court to do so, or
  • If the request is from a public authority, in particular from law enforcement or regulatory authorities, and to the extent that this is necessary to prevent threats to public order and safety or for the prosecution of criminal offences.

IV. Will my personal data be processed outside the European Union?

No. We only process your data to the extent legally permitted within the European Union on servers in Germany and Ireland.

V. When do you delete or anonymise my personal information?

1. The log data that we process when the MyLiebherr portal is opened is deleted after seven days. The error reports within the Liebherr SmartDevice app are deleted after two years.

2. Cookies are deleted when you logout of your MyLiebherr user account. If you selected the option “Remember my email address” (stay logged in) on the MyLiebherr portal, the cookies are deleted after 30 days. You should however never choose this option if you are working on a public computer or one that is used by several users.

3. The master data of your MyLiebherr user account is automatically deleted if you have not logged in to your MyLiebherr user account for one year. You will be notified by email before the deletion. You then have the option of preventing the deletion by logging into your MyLiebherr user account again. You can also request the deletion of your MyLiebherr user account at any time.

4. The machine data, usage data and the data of your device will be anonymised after two years or when your MyLiebherr user account is deleted. This means that although the data still exists, no personal reference to you can be made.

C. Profiling

I. What is profiling?

“Profiling” is any kind of automated processing of personal data which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular by analysing or predicting aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location of that natural person.

II. Is my personal data used for profiling?

No. In order to optimise the MyLiebherr portal and for statistical purposes even when merely accessing the MyLiebherr portal, we only collect non-personal data. For example, we collect the time of the visit, the websites visited on the MyLiebherr portal, the duration the visit, the regional origin and that of the website from which the MyLiebherr portal was called up. We use certified data protection-compliant web analytics software for this purpose from WiredMinds, which collects non-personal data only in an anonymous form. The visitors of the MyLiebherr portal cannot be identified by means of this data. You can prevent the collection of non-personal data by installing a cookie on the device that you are currently using by clicking on the following link.

Click here to prevent the collection of non-personal data.

D. How is my personal data protected from unauthorised access and loss?

We use technical and organisational security measures to ensure that the personal data of our users is protected from loss, improper changes or unauthorised access by third parties. Moreover, we ensure that from our side only authorised persons are granted access to your personal data and then only to the extent necessary for the above-mentioned purposes. The transmission of all data is encrypted.

E. The rights of the data subject and the right to lodge a complaint

Within the provisions of the legislation, you have the right to:

  • Information about your data
  • The correction of incorrect data and the completion of incomplete data
  • The deletion of your data, especially if they are no longer necessary for the purposes stated in this data protection policy, you revoke your consent and there is no other legal ground for the processing, your data has been unlawfully processed or you have objected to the processing and there are no overriding legitimate grounds for the processing
  • The restriction of the processing of your data, especially if the accuracy of the data is contested by you or the processing of your data is unlawful and you request the restriction of use instead of erasure.
  • The right to receive your data in a structured, commonly used and machine-readable format and to have your information transmitted by us directly to another controller.

In addition, you have the right to lodge a complaint with a supervisory authority.

F. Who do I contact in respect of data protection issues and how do I contact him or her?

If you have questions about data protection, please contact our data protection officer:

Mr Sinan Sen

Liebherr-IT Services GmbH

Oberopfingen, St. Vitus 1

88457 Kirchdorf an der Iller

Germany

Email: datenschutz@liebherr.com

Revised: April 2018