Version dated 1 December 2024

This Privacy Statement describes the collection and further processing of personal data by companies of the V-ZUG Group and its affiliates (collectively V-ZUG) as far as they are not covered by other data protection policies or are evident from the circumstances or are provided for by applicable law. The term “personal data” shall include all information relating to an identified or identifiable person.

This Privacy Statement describes in Section I the processing of personal data by V-ZUG in general. Section II contains specific provisions for different applications (e.g. online shops, newsletter, etc.) and for data processing in connection with the use of the V-ZUG apps.

Where applicable laws permit, V-ZUG may disclose business partner data to the following categories of third parties who process business partner data in accordance with the purpose of data processing on behalf of V-ZUG or for their own purposes:

• Service providers (within V-ZUG as well as external, for example for share registers, support and service), including processors;

• Distributors, suppliers and other business partners;

• Customers and buyers of V-ZUG products and services;

• Local, national and foreign authorities as well as stock exchanges and related supervisory and enforcement bodies (including SIX Exchange Regulation AG, the Swiss Financial Market Supervisory Authority FINMA, law enforcement authorities and courts);

• Media and private reporters and journalists;

• The general public, including visitors to V-ZUG websites and social media channels;

• Industry organizations, associations, organizations and other committees;

• Competitors;

• Acquirers or parties interested in acquiring business units, companies or other parts of V-ZUG;

• Other parties in potential or actual legal proceedings;

• Other companies of V-ZUG

(collectively “third parties”).

V-ZUG may disclose business partner data within the V-ZUG Group as well as to third parties and in every country worldwide, including all countries in which V-ZUG is represented by companies, affiliates, exhibition and other sales premises and representatives or distributors as well as to countries in which service providers of V-ZUG process their data. If data is disclosed to countries that do not guarantee adequate protection, V-ZUG will ensure adequate protection of data by way of technical and organizational measures and putting adequate contractual guarantees in place, namely on the basis of an international treaty; the data protection clauses in a contract between V-ZUG and a processor which have been notified in advance to the Federal Data Protection and Information Commissioner (FDPIC); the currently valid EU standard clauses; standard contractual clauses approved, issued or recognized in advance by the FDPIC; binding internal company data protection rules approved in advance by the FDPIC or by another competent supervisory authority of a state that ensures adequate protection; or other suitable guarantees under applicable data protection law. In the absence of such guarantees, V-ZUG relies on the exception of consent, the performance of the contract, the establishment, exercise or enforcement of legal claims, overriding public interests, the data published by the business partner or the grounds that it is necessary to protect the integrity of such persons. The business partner can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact unit named in Section I, para. 1. V-ZUG reserves the right to redact such copies for reasons of data protection or secrecy reasons.

V-ZUG may use personal data of business partners with their consent (if such consent is required under applicable law), or based on other grounds recognized under data protection law, in order to provide them with information about goods or services (promotions, e.g. marketing communications, competitions or campaigns). The promotions may be carried out in compliance with the relevant applicable law, in particular on the websites of V-ZUG, third-party websites, via newsletters, by e-mail and by post (see Section II. para. 4) and/or on social networks. Further information can be found in the details on the individual promotions.

Any data subject may request information from V-ZUG as to whether data concerning them is being processed. In addition, they have the right to request the correction, deletion or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the data subject may withdraw consent at any time. In countries of the EU and EEA the data subject may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable/electronic format which allows for further use and transfer. Requests in connection with these rights shall be submitted to the data protection officer or contact unit (see Section I, para. 1). V-ZUG reserves the right to restrict the rights of the data subject in accordance with applicable law and, for instance, not to disclose comprehensive information or delete data. 

Should V-ZUG make an automated decision with respect to a certain individual which may have a legal effect for the data subject or seriously affect them in a similar way, the data subject shall have, in accordance with applicable law, the right to communicate with a responsible person of V-ZUG and to request a reconsideration of the decision or to request the prior evaluation by a person. In this case, the data subject might no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance. 

Any data subject may also file a complaint with the competent data protection authority.

The following provisions shall supplement the provisions of the general part for certain activities of V-ZUG. In the event of any inconsistency, the following provisions shall prevail over the provisions of the general part.

V-ZUG processes personal data in order to fulfil obligations arising out of or in connection with orders, deliveries, installations, fittings, calibration, acceptance (FAT/SAT), warranty claims, service and support, care and maintenance, further enquiries or transfer of information material (newsletters, product information, events, etc.). Personal data includes, but is not limited to, name, address, phone number, e-mail address, etc. The data is processed for product, customer and quality control purposes.

V-ZUG may send newsletters or other commercial communications in connection with its products and services to business partners. In accordance with applicable law V-ZUG reserves the right to do so without prior consent of existing business partners. However, these business partners may object to further mailings at any time. In other cases, V-ZUG will send such communications only upon previous request of the business partner (e.g. newsletter opt-in via a website-account, double opt-in). As part of a newsletter mailing, V-ZUG may use measuring instruments and other identifiers, e.g. tracking pixels or web beacons, to the extent permitted by applicable law. V-ZUG measures whether and when an e-mail has been opened and which linked content has been clicked on or downloaded (known as newsletter tracking). However, the business partner may block this application in his/her e-mail application. The following personal data is processed: e-mail address, IP address. This data is processed to determine the effectiveness of the newsletter and to prepare content for business partners on a more targeted basis. 

However, the respective customers and business partners may object to a further mailing of newsletters or other commercial communications at any time through their account on the respective website or through the link indicated in every mailing. However, the termination of one newsletter does not necessarily terminate the mailing of other newsletters. It is possible that personalized advertisements are placed during the visit to the website. Every banner advertisement displayed to the business partner contains products offered on websites which have previously been visited by the business partner. The advertisement is generated by V-ZUG by means of cookies (see Section I para. 6).

In conjunction with the use of the V-ZUG Home app (the "application"), V-ZUG stores the following personal data once the user registration process has been completed (double opt-in): title, first name and surname, e-mail address and password. When a new V-ZUG household appliance is connected to the application, location data is processed. However, this processing only takes place during activation and only within the scope of and for the purposes of authenticating the user. The appliance connection is confirmed by e-mail. Every time the application is accessed, relevant information is recorded in a log file. This involves processing the following personal data: IP address of the requesting mobile device, serial number of the V-ZUG appliance, UID of the smartphone or tablet when using push notifications. This data is processed in order to facilitate use of the application in its current version, to guarantee system security and stability and – in aggregated and anonymized form – for statistical and analytical purposes. Data may also be passed on to third parties – exclusively in anonymized form – for these purposes. IP addresses will only be evaluated in the event of attacks on the network infrastructure of the V-ZUG website. Log data will be automatically and irretrievably deleted after 3 months. V-ZUG's legal basis for processing this data is to meet contractual obligations or to safeguard justified interests. In conjunction with the use of the V-ZUG Home app, users of a particular connected V-ZUG appliance are visible to other users of the same V-ZUG appliance via the V-ZUG Home app, and potentially also the appliance itself. This visibility is restricted to first and last name as well as the appliance usage data that can be retrieved from the V-ZUG Home app (e.g. whether the appliance is currently in operation). Moreover, each user has the option of removing the connection of all other users to the same V-ZUG appliance. The user of the application has the option of consenting to the transfer of usage and diagnostic data to V-ZUG in order to present operation and consumption data and to improve products and services, and may end such transfer at any time. If the user consents to the transfer of usage and diagnostic data, technical data (e.g. temperature, selected programme and duration) will be transferred along with the serial number of the appliance when the appliance is used via the application. Consent can be provided separately for each appliance connected to the application and can be revoked at any time. Users of the application can provide V-ZUG with voluntary feedback. When sending feedback, the user can supply their title, first name, surname and e-mail address on a voluntary basis along with their message. If this information is not provided, it will not be possible to identify the person involved or to draw any conclusions about the behaviour of the user. Any additional data relating to business partners (e.g. postal address, telephone number, date of birth, etc.) is provided on a voluntary basis. The same conditions apply to processing of such data.

For users within the territory of the People’s Republic of China the following provisions apply in addition: Controller of personal information and personal sensitive information is V-ZUG (Shanghai) Domestic Appliance Co. Ltd, Block 1 & 2, No. 1320 Yu Yuan Road, 200050 Shanghai, China. Personal data is stored on servers within the territory of the People’s Republic of China. V-ZUG processes the following personal sensitive information: network identity information (combination of personal information subject account and password and, in case of voluntary provision by the user, information about food allergy, subject to valid consent, if such consent is required by applicable law.Personal information may be transferred to overseas recipients, subject to valid consent, if such consent is required according to applicable law. Overseas recipient is V-ZUG Ltd., Industriestrasse 66, 6300 Zug, Switzerland. The following personal information may be transferred: name, surname, e-mail address, mobile phone number, user preferences and WIFI password. Personal data may only be transferred to overseas recipients for the following purposes: software update of connected appliances, technical user support, processing of data subject requests (restrict or refuse, copy, correction and supplementation, deletion, withdrawal of consent).Personal information and personal sensitive information may be transferred to the following sub-processors (i.e. other personal information processors): Flyingnets, 2nd Floor, Block F, Phase II, Xuhui Vanke Center, No. 9339 Humin Road, Xuhui District, Shanghai, People’s Republic of China, for the provision of cloud hosting services, subject to valid consent, if such consent is required by applicable law. The following personal information may be transferred: name, surname, e-mail address, mobile phone number, user preferences and WIFI password. Personal information and personal sensitive information may only be processed by sub-processors for the following purposes: technical user support, processing of data subject requests (restrict or refuse, copy, correction and supplementation, deletion, withdrawal of consent).