Data Protection Policy for Thermomix® Friend App

1 GENERAL  
   1.2 Subject matter of the Data Protection Policy 
   1.3 Legal basis of processing 
2 PROCESSING ACTIVITIES 
   2.3 USAGE DATA 
3 DELETION / RETENTION OF DATA 
4 RECIPIENT OF DATA, DATA TRANSFER TO THIRD COUNTRIES 
5 RIGHTS OF DATA SUBJECTS 
6 DATA PROTECTION AND SECURITY MEASURES 
7 RESERVATION OF AMENDMENT 

1 GENERAL

1.1 CONTROLLER / Data protection officer(s)
The controller within the meaning of the EU General Data Protection Regulation (hereinafter: GDPR) and other national data protection laws of the Member States as well as other data protection provisions with regard to personal data, which are processed as described below, is: Vorwerk International & Co. KmG Verenastrasse 39
CH- 8832 Wollerau
You can reach the data protection officer of the controller at: The Data Protection Officer c/o Vorwerk Vorwerk International & Co. KmG Verenastrasse 39 CH- 8832 Wollerau
Email: dpo@vorwerk.ch

1.2 Subject matter of the Data Protection Policy
The purpose of Thermomix® Friend app is to manage the updates for the Thermomix® Friend device. For that purpose we do not require from you sharing any personal data with Vorwerk that would involve your identification.
The following information will inform you about the functionality of the Thermomix® Friend app (“App”). Vorwerk is the provider of the App and thus the controller for data processing activities with
regard to the App. This information is available for you at any time in the App under “More” / “Legal Information” / “Data Protection”.

1.3 Legal basis of processing
The processing of personal data (e.g. collection, retrieval, use, storage, or transmission) always requires a legal basis. Processed personal data will be deleted as soon as the purpose of processing has been achieved and there are no longer any statutory mandatory retention obligations. In case provisioning of personal data is required for customer service support (See Sec. 2.2.) in case you decide not to provide the data we will not be able to provide you with services.

2 PROCESSING ACTIVITIES

Below you will find information about the specific processing activities, the scope and purpose of the data processing, the legal basis for processing, and the duration of storage, insofar as the latter deviates from the information under Clause 5.

2.1 Usage of the App

2.1.1 You can use the App without creating a user account. When you open the App for the first time you will be asked to enable Bluetooth connection. Enabling the connection will allow you to connect to the cooking station and installation of updates.

2.1.2 Periodic updates will be made available for you. You will be asked to install the updates in order to ensure efficient work of the cooking station.

2.1.3 The legal basis of the data processing is Art. 6 Para. 1(b) GDPR.

2.2 Customer service support

2.2.1 In case you experience any technical issues with the cooking station and decide to contact customer service support, in order to process your request Vorwerk will need to collect personal data from you (first name, last name, email address, telephone number, serial number of the cooking station).

2.2.2 The legal basis of the data processing is Art. 6 Para. 1(b) GDPR.

3 DELETION / RETENTION OF DATA

Vorwerk stores your data as long as this is necessary and permissible for the purpose of data processing. After completion of the intended purpose or after the expiry of the statutory retention periods, your data will be deleted immediately.

4 RECIPIENT OF DATA, DATA TRANSFER TO THIRD COUNTRIES

4.1 Vorwerk International is the provider of the App that engages other third parties to provide the technical infrastructure and associated services (service provider). These service providers process your personal data only according to our instructions. These third parties are obliged to maintain data protection technical and organizational measures and confidentiality of the data.

4.2 In addition, we only disclose your personal data to third parties if you have given your express consent in accordance with Art. 6 para. 1 sentence 1(a) GDPR,
• it is legally permissible and required in accordance with Art. 6 para. 1 sentence 1(b) GDPR in
order to fulfil a contractual relationship with you,
• there is a statutory obligation of disclosure in accordance with Art. 6 para. 1 sentence 1(c) GDPR,
• the disclosure according to Art. 6 para. 1 sentence 1(f) GDPR is necessary for the safeguarding of legitimate company interests as well as for the assertion, exercise, or defence of legal claims, and there is no reason to believe that you have an overriding, protectable interest in the non-disclosure of your data.

4.3 Vorwerk reserves the right to transmit your data to third parties outside the EU, in particular in the USA and in Switzerland, in order to provide services. In these cases, we ensure that your personal data will only be forwarded to third parties outside the EU if an appropriate level of data protection has been established by the European Commission or we have agreed to the standard contractual clauses with these third parties.

5 RIGHTS OF DATA SUBJECTS

5.1 Given the fact that no personal data are being collected or processed by Vorwerk via this App (Sec. 1.2 and 2.1.1, According to Art. 11 GDPR data subject rights listed in Art. 15 to 20 GDPR shall not apply.

5.2 For the processing activities relating to customer service support (Sec. 2.2.) following data subject rights apply: you have the right to obtain information from us (Art. 15 GDPR), the right to rectification (Art. 16 GDPR) and deletion (Art. 17 GDPR), with respect to your data, the right to limit the processing (Art. 18 GDPR), the right to object to the processing (Art. 21 GDPR), and the right to data portability (Art. 20 GDPR).
These rights can be asserted to Vorwerk, e.g. by e-mail to dpo@vorwerk.ch

5.3 You also have the right to complain to a supervisory authority pursuant to Art. 77 GDPR.

6 DATA PROTECTION AND SECURITY MEASURES

6.1 We protect your privacy and will treat your personal data confidentially.

6.2 In order to avoid a manipulation, loss, or misuse of your data stored by us, we take extensive technical and organisational security precautions that are regularly reviewed and updated in line with technical advancements.

6.3 However, we would like to point out that it is possible, due to the structure of the internet, that the rules of data protection and the aforementioned security measures are not comprehensively observed by other persons or institutions not within our area of responsibility.

7 RESERVATION OF AMENDMENT

We reserve the right to adapt the Data Protection Policy from time to time, e.g. if there are changes in data processing. In the event of an update of this data protection information, we will inform you in an appropriate manner, e.g. via the App or via email.