Privacy Notice ICE Robotics EMEA

Welcome to our Privacy Notice

We respect your privacy and are committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you visit ICE Robotics websites* and portals, regardless of where you visit it from and tell you about your privacy rights. We will refer to the website and the portal as the “Services”.

1. Introduction

2. Categories of Data

3. How We Collect Your Personal Data

4. How We Use Your Personal Data

5. Disclosure of Personal Data

6. Data Security

7. Data Retention

8. EU Data Privacy Rights

*https://icecompanies.com/, https://www.schoonmaakmachineleasen.nl, https://www.icebenelux.com, https://www.shop-schoonmaakmachines.nl, https://www.ice4france.fr, https://www.icerobo.com, http://www.iceroboemea.com/.

1. Introduction

Effective Date: 9 July 2020

Latest Update and Release Date: 9 July 2020

ICE Robotics is focused on changing the cleaning industry by offering a subscription model on enhanced Intelligent Cleaning Equipment and reducing repetitive tasks for cleaning professionals through the deployment of autonomous cleaning equipment. We are global company under the leadership of Simon Chen with offices located in the United States, The Netherlands and China.

We respect your privacy and are committed to protecting your personal data. This Privacy Notice explains our privacy practices for the activities described herein. Please read this Privacy Statement carefully to understand how we collect, use, share and otherwise process information relating to individuals ("Personal Data") and to learn more about your rights and choices regarding your Personal Data.

Any reference to "ICE Robotics EMEA", “ICE”, "we", "us", “our” or the "Company" is a reference to ICE Robotics EMEA and the relevant affiliates involved in the collection, use, sharing or otherwise processing of Personal Information.

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how ICE Robotics collects and processes your personal data through your use of our Services. We do not sell your personal data.

It is important that you read this Privacy Notice together with the Website’s Terms of Use or any other policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

ICE Robotics’ Contact Information

If you have any questions with respect to this Notice or the way in which we process your personal data, you may contact us via the below contact details:

ICE Robotics EMEA

Point of contact: Lesley Hessels

Email address: gdpr@icerobo.com

Postal address: Airborne Avenue, 55, 2133 LV, Hoofddorp, The Netherlands

Changes to this Privacy Notice and You Notifying Us of Changes

We will notify you of any material changes to this Privacy Notice. It is important that the personal data we hold about you is accurate and current. We will at all times publish the up-to-date version on our Website, together with a summary of key changes. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our Website, we encourage you to read the Privacy Notice of every website you visit.

2. Categories of Data

Personal data, or personal information, means any information about an individual from which that person can be identified. We or our service providers may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

· Identity Data includes first name, last name, username or similar identifier.

· Contact Data includes email address and telephone numbers.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version,time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.

· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

· Usage Data includes information about how you use our Services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

International Data Transfers

If you choose to provide us with information, we may transfer that information to our affiliates, subsidiaries, third party service providers or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world, for example, to our affiliates ICE Robotics U.S.A. or ICE Robotics China. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data, in particular standard contractual clauses.

If you would like to obtain more information about such safeguards you can request this from us via the contact details above. You may find general information on the standard contractual clauses via this website. For more information on the third parties with whom we share your data please see Section 5 below.

Minor Users

This Website is not intended for children and we do not knowingly collect data from children. If we learn that we have received information directly from a child under age 16 without the parent or legal guardian’s verified consent, we will use that information only to respond to the child/parent/guardian to inform the child that he or she may not use the Website.

3. How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data when you interact with us. This includes personal data you provide when you:

· apply for our products or services;

· create an account on the Portal;

· purchase or rent a product;

· purchase services;

· subscribe to our service or publications;

· request marketing to be sent to you;

· conduct a survey; or

· give us some feedback.

Third-party sources. We may receive personal data about you from various third parties including our third-party service providers. We employ other companies and individuals to perform functions upon our behalf. Examples include storing and analyzing data, providing search results and links (including paid listings and links), providing customer service, and payment processing. They have access to user information needed to perform their functions but may not use it for other purposes.

You are not under a statutory obligation or otherwise obliged to provide us with your information, but if you refrain from doing so, we may not be able to provide you with our services.

This Notice solely describes how we handle your personal data and does explicitly not describe how third parties from which we collected your personal data process your personal data. We have no influence on this.

4. How We Use Your Personal Data

Purpose and legal basis

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Furthermore, we may only process your personal information if we have a legal basis for data processing. If we do not have such a legal basis, the data processing will not be lawful. The lawful basis ties in with the processing purpose.

Examples of legal basis are:

i) you have given your consent for the processing of your personal information for one or more specific purposes; or

ii) the processing is necessary for the purposes of the legitimate interests pursued by us or a third party, but only if your interests, fundamental rights or fundamental freedoms do not outweigh our legitimate interests. Accordingly, we performed a balancing test. If you would like to receive more information on the outcome of a balancing test in a specific circumstance, please contact us via the above-mentioned contact details.

Please find below the purposes for which we process your personal information and the legal basis on which we rely.

Activity	Purpose	Legal basis
When you apply for our products or services	Responding to your request (i.e. providing you with requested information and materials). Providing our products or services.	Legitimate interest in engaging with our (potential) customers
When you create an account on our Website	To register you as a new customer or prospect.	Legitimate interest in engaging with our (potential) customers
When you purchase or rent a product	Processing and delivering your order, manage payments, fees, and charges and providing information about our products.	Legitimate interest in performing under a contract with the company you represent.
When you purchase services	Processing and delivering your order, manage payments, fees, and charges and providing information about our services.	Legitimate interest in performing under a contract with the company you represent.
When you request marketing to be sent to you	Sending marketing communications.	Consent
When you conduct a survey or give us feedback	Collecting feedback on our products and services, improving our products and services and responding to feedback on our products and services services	Legitimate interests of ICE Robotics, being the review and improvement of our products and services

Opting Out

You can ask us to stop sending you marketing messages at any time by replying to a marketing email with “unsubscribe” in the subject line, clicking “unsubscribe” in the marketing email itself, or by Contacting us at any time at the contact details above.

5. Disclosure of Personal Data

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include third parties who assist us in operating our site, conducting our business, or servicing you, so long as those parties process the data upon or instructions (processors), or are subject to the same or similar data protection rules. Those parties include:

Vendors, consultants, and/or other service providers
affiliates of ICE Robotics, including, but not limited to, ICE Robotics U.S.A. and ICE Robotics China
partners of ICE Robotics, including, but not limited to, in the U.S.A., Europe, and China
In the event of the purchase or sale of a business, your personal information may be transferred as part of the transaction.

Those third-party partners may:

Provide you with various services
Provide database maintenance and security
Help us manage transactions
Help us process and fulfill orders, transactions, donations, or requests

We may also release your information when we believe release is necessary to comply with the law or request from governmental (enforcement) agencies, or protect ours or others’ rights, property, or safety.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. 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.

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.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. EU Data Privacy Rights

In accordance with the applicable laws, you have the right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability and the right to object. Most of these rights are not absolute and subject to exemptions in the law, and/or may only apply to certain types of information or processing.

Below we set out your rights in more detail. You can exercise any of your rights by sending an e-mail to gdpr@icerobo.com. We will respond to your request within one month but have the right to extend this period with two further months (for example if your request is complex). If we extend the response period, we will let you know within one month from your request.

Please note that to help protect your privacy and maintain security, we may take steps to verify your identity before complying with your request.

Your right	Description
Right to access	You may ask us to confirm if we are processing your personal data, and if so, access to your personal data. In such case we will provide you with a copy of your personal data and certain information relating to the processing. This enables to check that we are lawfully processing your personal data. Please note that (data protection) rights and/or freedoms of others may stand in the way of us (fully) complying with your request. If your request is clearly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.
Right to correction	You may ask to correct or complete your personal data if it is inaccurate or incomplete.
Right to erasure	You may ask us to delete certain of your personal data. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims / a legal dispute.
Right to restriction	You may ask us to suspend the processing of your personal information, but only in certain cases (for example if you want us to establish its accuracy or the reason for processing it).
Right to data portability	You may ask us to help you transfer certain of your information you provided to you or other companies (in a structured, commonly used and machine-readable format), but only if the processing is: i) legally based on your consent or on a contract between you and ICE Robotics; and ii) carried out by automated means. Please note that (data protection) rights and/or freedoms of others may stand in the way of us (fully) complying with your request.
Right to object	If we are processing your personal information based on a legitimate interest (or those of a third party), you may object to processing on this ground. However, we may be entitled to continue processing your personal information based on (compelling) legitimate grounds.
Right to object to direct marketing	You may request us to stop processing your personal data for direct marketing purposes.
Right to withdraw consent	If the processing of personal data is based on your consent, you have the right to withdraw your consent at any time. Please note that the withdrawal of your consent does not affect the validity of the processing prior to your withdrawal.
Right not to be subject to automated decision making	To the extent applicable, you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.

Inquiries regarding the processing of personal data should be directed to dpo@icerobo.com.

You also have the right to file a complaint with the Dutch data protection authority (Autoriteit Persoonsgegevens). However, before you do that, please contact us first, as ICE Robotics is committed to resolve complaints about our collection or use of your personal information.