Principles of data processing for the MyLiebherr Account and the Liebherr SmartDevice app (information requirements)

A. General

I. What does this privacy policy regulate?

We attach great importance to the protection and security of your personal data. It is therefore important for us to inform you about what personal data we use for which purposes and what rights you have in relation to your personal data.

MyLiebherr Account

The "MyLiebherr Account" is your central user account at Liebherr-Hausgeräte GmbH. You have to register in order to create a MyLiebherr Account. Your can register on the “MyLiebherr Portal" (https://home.myliebherr.com). When you register via the MyLiebherr Portal, you will receive an e-mail with a confirmation link at the end of the registration process. You must click on the confirmation link in order to complete the registration process. Alternatively, you can also sign up for the MyLiebherr Account using your Google, Facebook or Microsoft accounts (hereinafter referred to as "Social Login"). Please note that we have no influence on the processing of your personal data by Google, Facebook and Microsoft. With your MyLiebherr Account you can use the Single-sign-on service of Liebherr-Hausgeräte GmbH (hereinafter referred to as "SSO"). SSO allows you to use other access-restricted digital services (hereinafter referred to as "Modules") connected to the SSO using identical access data. SSO allows you to navigate between modules without the need for a separate registration and login process. SSO automatically transfers the data stored in your MyLiebherr Account which are required for the use of the relevant modules to the respective module providers in order to offer you the best possible comfort. The modules are operated either by Liebherr-Hausgeräte GmbH or by subsidiaries of Liebherr-Hausgeräte GmbH.

Liebherr SmartDevice App

The Liebherr SmartDevice app allows you to view and configure the data of your Liebherr refrigerator and freezer. To use the Liebherr SmartDevice app, you need a WLAN-enabled module (hereinafter referred to as "SmartDeviceBox"), a MyLiebherr Account and an Internet connection. The SmartDeviceBox connects your Liebherr refrigerator and freezer to the Internet via a WLAN-enabled router. The SmartDeviceBox can be retrofitted to SmartDevice-enabled Liebherr refrigerators and freezers. Some Liebherr refrigerators and freezers already have the SmartDeviceBox integrated. In combination with the SmartDeviceBox, the Liebherr SmartDevice app allows you to control various functions of your Liebherr refrigerator and freezer, such as the cooling temperature, while on the move. With the Liebherr SmartDevice app, you can immediately see any important alarm messages, such as a door accidentally left open. The Liebherr SmartDevice app has a notification function that reminds you when the next air filter change is due or when the ventilation grille needs to be cleaned, for instance. The Liebherr SmartDevice app offers you more convenient food management through shopping and stock lists. With the Liebherr SmartDevice app, you can receive not only valuable ideas for perfect food preparation, but also recipes and inspirations for hobbyists and casual cooks. Ingredients required for a recipe that are not in stock can be added directly to the Liebherr SmartDevice app shopping list. With the help of a refrigerator camera (hereinafter referred to as "FridgeCam”), available as an accessory, the Liebherr SmartDevice app can show you the interior of your refrigerator and freezer at any time. This way, you always know what food you have in your fridge. This will help you avoid duplicating purchases, prevent food waste, and save money.

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

1. "Personal data" (hereinafter also referred to as "data") are any information that reveal something about a natural person. In addition to information that allows a direct inference about a specific person (such as a person’s name or e-mail address), personal data also include information that can be linked to a certain person with appropriate additional knowledge.

2. "Processing" refers to any action taken on your personal data (such as the collection, recording, organisation, ordering, storage, use or deletion of data).

B. Who is responsible for processing my data?

The Controller responsible for processing your data is Liebherr-Hausgeräte GmbH, Memminger St. 77-79, 88416 Ochsenhausen, Germany, Phone: +4973529280; Fax: +497352928408; E-mail: info.hau@liebherr.com.

C. Data processing in relation to the MyLiebherr Account

I. What data are collected for which purposes?

When calling up the MyLiebherr Portal, the following data are processed by our web server and stored in what are known as log files:

1. date of access to the MyLiebherr Portal

2. time of access to the MyLiebherr Portal

3. Internet address of the website on which you were when you called up the MyLiebherr Portal (URL)

4. files you access through the MyLiebherr Portal

5. amount of data transferred to you

6. your browser type and version

7. your operating system

8. the domain name of your Internet access provider (e.g. Telekom, Vodafone, etc.)

9. your (external) IP address

When registering and using a MyLiebherr Account via the MyLiebherr Portal without the use of Social Login, we process the following data in addition to the data mentioned in points 1-9 hereinabove:

10. registration date

11. your unique user ID (UPN)

12. date and time of the last successful login

13. your e-mail address

When registering and using a MyLiebherr Account via Social Login, we process the following data in addition to the data mentioned in points 1-13 hereinabove:

14. Social Login identification feature (so-called identifier)

Note: If you register or authenticate yourself with a Facebook Social Login, Facebook will also provide us with your last name, first name and profile picture in addition to the data listed in points 13 and 14. We do not process such data for any purpose.

Note: When you register or authenticate with a Google Social Login, Google will provide us with your last name, first name, and the link to your Google Plus profile in addition to the information listed in points 13 and 14. We do not process such data for any purpose.

Note: If you register or authenticate with a Microsoft Social Login, Microsoft will provide us with your last name and first name in addition to the information listed in points 13 and 14. We do not process such data for any purpose.

For the optimal use of the modules connected to the MyLiebherr Portal, we collect the following data on a voluntary basis in addition to the data mentioned in points 1-14:

15. your preferred language

16. your title

17. your address

18. your phone number

19. your Liebherr refrigerator and freezer serial number

20. your Liebherr refrigerator and freezer device type

21. your SmartDeviceBox serial number

We process the data listed in points 1- 21 for the following purposes:

1. to protect our website offer (data categories used: 1-9)

2. to register a MyLiebherr Account via the MyLiebherr Portal ( data categories used: 10-13)

3. to register a MyLiebherr Account via Social Login (10-14)

4. for the central administration of user and profile data for SSO (data categories used: 10-21)

5. for the use of SSO (data category used: 11)

6. for transmission to the provider of the selected module (data categories used: 13, 15-21)

7. to support your MyLiebherr Account (data categories used: 1-21)

Note: Please note that your personal data could be transferred to countries outside the EU/EEA if the provider of one of your modules is based in such a country. We will seek your express consent prior to any transmission to such provider.

Processing for other purposes may only occur in so far as legal requirements under Article 6 (4) of the General Data Protection Regulation (GDPR) apply. In this case, we will of course comply with any requirements to provide information according to Art. 13 (3) GDPR and Art. 14 (4) GDPR.

II. On what legal basis do we process your data?

In principle, the legal basis for processing your data is Art. 6 GDPR, in so far as there are no further specific legal provisions.

The processing of your data is based on the following legal bases:

1. Data processing for the performance of contracts (Article 6 (1) (b) GDPR) (applies to purposes 2-7)

2. Data processing based on a balance of interests (Article 6 (1) (f) GDPR) (applies to purpose 1)

3. Data processing to fulfil a legal obligation (Art. 6 (1) (c) GDPR) (applies to purpose 1)

4. Consent (Article 6 (1) (a) GDPR) (applies to any transmission of your data to non-EU/EEA countries for purpose 6)

Our legitimate interests are:

Improvement of the stability, functionality and security of the Portal (applies to purpose 1)

If we process your data on the basis of a balance of interests, you have the right to object to the processing of your data under the provisions of Art. 21 GDPR.

We process your data only to the extent necessary for the fulfilment of the above mentioned purposes.

IV. To whom and for what purposes do we transfer which categories of your data?

Where necessary, we will transfer your data:

1. To the providers of the modules you actively use and possibly of other services (data categories 13, 15-21)

2. To other companies of the Liebherr Group, if this is necessary for the initiation, execution or termination of a contract or if there is a legitimate interest in the transfer on our part and your predominant legitimate interest is not in conflict with the same; (data categories 13-21)

3. To the Social Login provider of your choice (data category 14)

4. To the service providers we use to achieve the above purposes; (data categories 1-21)

5. To any court, arbitration tribunal, public authorities or legal advisor when required to comply with applicable law, or to assert, exercise or defend legal claims. (data categories 1-21)

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

Data transfer to Processors in countries outside the European Union (known as third countries) is only permitted (1) if you have given us your consent or (2) if the European Commission has decided that an adequate level of protection exists in a third country (Art. 45 GDPR). If the Commission has not made such a decision, we may only transfer your data to third parties located in a third country in so far as appropriate safeguards exist (e.g. standard data protection clauses adopted by the Commission or the supervisory authority in a specific procedure) and the enforcement of your rights is ensured.

V. When do we delete or anonymise your data?

We process your data as long as this is necessary for the relevant purpose, unless you have effectively objected to the processing of your data or have effectively revoked your consent.

As far as statutory retention obligations exist - e.g. in commercial law or tax law - we will have to save the relevant data for the duration of the retention obligation. After the expiry of the retention period, we check whether there is any further need for processing. If there is no such further necessity, your data will be deleted.

D. Data processing in relation to the Liebherr SmartDevice App

I. What data are collected for which purposes?

To use the Liebherr SmartDevice app, you need a MyLiebherr Account. In addition to the data in C.I., we also collect the following data from you:

1. the device data of your Liebherr refrigerator and freezer (serial number, selected name, model and type)

2. the sensor data of your Liebherr refrigerator and freezer (temperature status, compressor speed, open door status)

3. the device data of your Liebherr SmartDeviceBox (serial number, model, type, connection status)

4. the technical configuration of your device (model, manufacturer, operating system used, connection status)

5. the device data of your FridgeCam (serial number, model and type)

6. the sensor data of your FridgeCam (Wi-Fi signal strength, battery status)

7. Images of the interior of your Liebherr refrigerator and freezer

We generally process such data only for the following purposes:

1. Provision of the functions of the Liebherr SmartDevice app (data categories used: 1-7)

2. Error analysis and improvement of the app (data categories used: 1-6 and data categories in C.I. 1-9)

3. Development and assessment of the Object Recognition function (data category used: 7)

Processing data for other purposes may only occur in so far as the legal requirements of Article 6 (4) GDPR apply. In this case, we will of course comply with any requirements to provide information according to Art. 13 (3) GDPR and Art. 14 (4) GDPR.

II. On what legal basis do we collect your data?

In principle, the legal basis for processing your data is Art. 6 GDPR, in so far as there are no further specific legal provisions.

Your data is processed based on one or more of the following legal bases:

1. Consent (Article 6 (1) (a) GDPR) (applies to purposes 2 and 3)

2. Data processing for the performance of contracts (Article 6 (1) (b) GDPR)

(applies to purpose 1)

If we process your information based on your consent, you have the right to withdraw your consent at any time with future effect.

We process your data only to the extent necessary for the fulfilment of the above mentioned purposes.

IV. To whom and for what purposes do we transfer which categories of your data?

Where necessary, we will transfer your data:

1. To other companies of the Liebherr Group, if this is necessary for the initiation, execution or termination of a contract or if there is a legitimate interest in the transfer on our part and your predominant legitimate interest is not in conflict with the same; (data categories 1-7)

2. To the service providers we use to achieve the above purposes; (data categories 1-7)

3. To any court, arbitration tribunal, public authorities or legal advisor when required to comply with applicable law, or to assert, exercise or defend legal claims. (data categories 1-7)

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

Data transfer to Processors in countries outside the European Union (known as third countries) is only permitted (1) if you have given us your consent or (2) if the European Commission has decided that an adequate level of protection exists in a third country (Art. 45 GDPR). If the Commission has not made such a decision, we may only transfer your data to third parties located in a third country in so far as appropriate safeguards exist (e.g. standard data protection clauses adopted by the Commission or the supervisory authority in a specific procedure) and the enforcement of your rights is ensured.

V. When do we delete or anonymise your data?

We process your data as long as this is necessary for the relevant purpose, unless you have effectively objected to the processing of your data or have effectively revoked your consent.

As far as statutory retention obligations exist - e.g. in commercial law or tax law - we will have to save the relevant data for the duration of the retention obligation. After the expiry of the retention period, we check whether there is any further need for processing. If there is no such further necessity, your data will be deleted.

VI. Liebherr SmartDevice App Skill for Amazon Alexa

Amazon Echo is Amazon hardware for voice input and output. Amazon Echo devices allow Amazon to analyse, evaluate and execute voice commands. Amazon Echo devices require an Amazon user account to function and can be extended to include additional features by adding so-called "skills". The Liebherr SmartDevice app skill allows you to control some functions of the Liebherr SmartDevice app via your Amazon Echo device through voice commands. This requires you to activate the Liebherr SmartDevice app skill in your Amazon account and link your MyLiebherr Account to this skill. Through this link, voice commands given by you can be interpreted by Amazon and sent to the Liebherr SmartDevice app for execution via an anonymous digital signature. Except for the data indicating that you have an Amazon account and a MyLiebherr Account, no personal data will be sent by us to Amazon or by Amazon to us.

VII. Liebherr SmartDevice App Trigger for IFTTT

IFTTT is a service of IFTTT Inc., which allows you to combine the functions of the Liebherr SmartDevice app with various applications supported by IFTTT. In this way, a particular event (e.g. entering your home) can trigger a specific action (e.g. activating the Supercool feature). To use IFTTT, you will need to activate the Liebherr SmartDevice App Trigger in your IFTTT account and link your MyLiebherr Account to the Liebherr SmartDevice App Trigger. Except for the data indicating that you have an IFTTT account and a MyLiebherr Account, no personal information will be sent by us to IFTTT Inc. or sent by IFTTT Inc. to us.

E. How are my personal data secured against unauthorised access and loss?

We use technical and organisational security measures in order to secure your data against loss, incorrect modification and unauthorised access by third parties. Moreover, on our part, only authorised persons will ever have access to your data and they can only access it to the extent required within the framework of the purposes named above. All data is transferred in encrypted form.

F. Cookies

We use what are known as cookies in order to recognise your preferences and achieve optimum website design. This facilitates navigation and ensures a high level of user friendliness.

I. What are cookies?

Cookies are small files that are stored on your terminal device. They can be used to determine if there has already been communication between your terminal device and our MyLiebherr Portal. Only the cookie is identified on your terminal device. Personal data can then be stored in cookies if you have given your consent for this or where this is technically essential, e.g. for a secure login.

Further information on cookies is available at www.allaboutcookies.org.

II. What do we use cookies for?

We use cookies

 to check your registration status and user identification after successful registration

 to ensure a secure Internet environment;

 to check our website performance;

 to evaluate the manner in which you use our sites in order to improve our services. For example, we can detect when a process is too time-consuming and results in the user cancelling the process underway This knowledge enables the process steps to be simplified and made more customer-oriented;

 to improve user-friendliness, traceability for our user customers and the online experience.

We do not use your cookies in order to track your Internet activity outside of the MyLiebherr Portal and connected modules.

III. What type of cookies do we use and what is their purpose?

a. Session cookies

Session cookies are deleted when the browser is closed. They record navigation on the MyLiebherr Portal as well as the length of your visit, and save the content of your registration information for the duration of your visit to the MyLiebherr Portal. Session cookies also keep your login active during the session.

b. Persistent Cookies or Tracking Code

Persistent Cookies or Tracking Codes do not contain any personal data. They record where the website was accessed from, which search engine was used, which link was clicked and which search term was selected, as well as the user's location when accessing a website. They record the number of visits and the duration of the first, current and previous visit. These cookies only register visits to the MyLiebherr Portal. They are not activated when visiting other websites.

c. Re-Targeting or Remarketing

Our website uses so-called re-targeting technologies to make the website more interesting for you. This means your visit to certain websites is marked by cookies, which later identify visits to other websites. We are convinced that the insertion of personalised, interest-based advertising is generally more interesting to Internet users than non-personal advertising. The insertion of this advertising material on our partners’ pages is based on cookie technology and an analysis of previous usage behaviour. This form of advertising takes place completely anonymously. No personal data will be stored and no user profiles will be merged with your personal data.

d. Conversion Tracking

See Use of Google technology

I. Can I delete cookies that are stored on my terminal device?

You can delete the cookies that are saved for the MyLiebherr Portal. In this case, however, your individual data and content, including your cookie settings, will be lost and you will not be recognised as a returning visitor the next time you visit the MyLiebherr Portal.

II. Do you agree to our use of cookies?

The user concept of our MyLiebherr Portal includes some online features designed to make your visit as comfortable as possible. However, these only work with the help of cookies. Continued navigation on our website indicates your agreement to the use of these cookies. You can revoke your agreement at any time.

III. How can I withdraw my consent regarding the use of cookies?

If you do not want us to recognise your terminal device, you can prevent the storage of cookies on your terminal device by selecting "Do not accept cookies" in your browser settings. Please refer to the instructions from your browser producer for more details.

You can set your browser so that cookie storage is only accepted if you give your agreement. If you do not want to accept cookies from our service providers then you can select the setting 'block cookies from third party providers' in your browser.

You can usually search in the help function in the menu of your web browser to find out how to reject new cookies or deactivate those you have already received.

Please note, however, that certain 'essential' cookies are indispensable for unobstructed navigation on the MyLiebherr Portal and for selection and design. We use these cookies only to check the efficiency of MyLiebherr Portal and record visitor frequency.

G. Use of Google technology

I. How can I prevent the storage of Google technology (cookies)?

If you do not want Liebherr-Hausgeräte GmbH to collect and analyse data about your visit, you can object to this at any time with future effect (so-called "Opt-Out").

For the technical implementation of this objection, an "Opt-Out cookie" will be set in your browser. This cookie is only used to signify your objection. Please note that for technical reasons "Opt-Out cookies" can only be used for the browser from which they are set. If you delete cookies or use another browser or device, you will need to opt out again.

Install the “Opt-Out-Cookie” directly here. Alternatively, you can download and install the browser plug-in available under the following link

II. What is Google Analytics?

MyLiebherr Portal uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses cookies that are stored on your device to analyse your use of the website. The information generated by the cookie about your use of this website is usually transmitted to and stored by Google on servers in the United States.

We have activated IP anonymisation on the MyLiebherr Portal, so your IP address will be shortened by Google within the member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of Liebherr-Hausgeräte GmbH, as the operator of the MyLiebherr Portal, Google will use the above information to evaluate your use of the MyLiebherr Portal, to compile reports on website activity and to provide other services related to website activity and internet usage to Liebherr-Hausgeräte GmbH.

The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google information. You can prevent the storage of cookies through the corresponding settings in your browser software; however, please be aware that if you do this you may not be able to use the full functionality of this website.

You may also prevent Google from collecting the data (including your IP address) generated by the cookie in relation to your use of the website, as well as from processing such data with effect for the future, by downloading and installing the browser plug-in available from the following link: http://tools.google.com/dlpage/gaoptout?.

III. What is Google AdWords?

We use the Google AdWords online advertising program and conversion tracking as part of Google AdWords. The conversion tracking cookie is set when a user clicks on a Google-served ad. These cookies lose their validity after 30 days and are not used for personal identification.

If the user visits certain pages on the advertiser's website and the cookie has not expired, Google and the customer will be able to recognize that the user clicked on the ad and was redirected to that page. Each customer receives a different cookie. Cookies cannot therefore be tracked through the websites of AdWords customers.

The information obtained using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive any information which would make it possible to personally identify users.

Google AdWords is only used if you expressly agree to this use through the so-called cookie canner. If you want to disable cookies for conversion tracking, you can set your browser to block cookies from the domain "googleadservices.com".

For more information on "Data Protection" in relation to the online advertising program Google AdWords, please visit https://www.google.com/policies/privacy.

IV. What is DoubleClick?

DoubleClick by Google is a service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). DoubleClick by Google uses cookies to show you advertisements that are relevant to you. Your browser will be assigned a pseudonymous identification number (ID) to monitor which ads have appeared in your browser and which ads have been viewed. The cookies do not contain any personal information. Using the DoubleClick cookie allows Google and its affiliate websites to serve ads based on previous visits to our or other websites on the Internet. The information generated by the cookies is transmitted for evaluation by Google to a server in the USA and stored there. Google only transfers data to third parties due to legal regulations or in the context of order data processing. Under no circumstances will Google merge its data with other data collected by Google.

By agreeing to this through the banner displayed on your first visit to the Liebherr website, you consent to the processing of the data collected by Google about you, the manner of processing described above and the stated purpose. You can prevent the storage of cookies through the corresponding settings in your browser software; however, we would like to point out that in this case you may not be able to use all functions of the Liebherr website in full.

You may also prevent Google from collecting the data generated by the cookies relating to your use of the Liebherr website and processing such data by downloading and installing the browser plug-in available at https://adssettings.google.com/ under the item DoubleClick Deactivation Extension. Alternatively, you can disable DoubleClick cookies on the Digital Advertising Alliance website at the following link: http://optout.aboutads.info/?c=2#!/

H. Data Subject Rights and Right of Appeal

Within the legal framework, you have the right to

1. information about your data;

2. the correction of incorrect data and completion of incomplete data;

3. the deletion of your data, in particular, if (1) they are no longer necessary for the purposes stated in this privacy policy, (2) you withdraw your consent and there is no further legal basis for processing, (3) your data have been unlawfully processed or (4) you have objected to the processing and there are no legitimate reasons for processing.

4. Limitation of the processing of your data, especially should you dispute the accuracy of the data or the processing of your data is illegal and you demand limitation of use in place of deletion.

5. The right to receive your data in a structured, standard and machine-readable form and to demand that we transfer your data directly to another responsible party.

Please note that the lawfulness of processing based on consent prior to your withdrawal of such is not affected by your withdrawal of consent.

We ask for your understanding that, where the above rights are not asserted in writing, we may require you to provide evidence proving that you are the person you claim to be. You also have a right of appeal with the responsible supervisory authority.

I. How do I contact the Data Protection Officer?

Should you have any questions regarding data protection please contact:

Data Protection

Liebherr-IT Services GmbH

St. Vitus 1

88457 Oberopfingen, Germany

datenschutz@liebherr.com

Last updated: February 2019