Privacy Policy
As at: 2023-01
Market: United States
We are pleased to inform you about the collection, processing, and use of your personal data in this Privacy Policy. Below, you will find information on how we collect, process, and use your personal data, the reasons why we process your personal data, and the data subject rights you have in this regard.
If you would like further information not contained in this Privacy Policy, you can contact us and our Data Protection Officer at any time via the contact details stated in Section 2 of this Privacy Policy. Please see the STIHL Incorporated Mobile and Web App Terms and Conditions for the STIHL MY iMOW® Applications for additional terms.
In this Privacy Policy, we inform you about the collection, processing, and use of your personal data in connection with the STIHL MY iMOW® App and the browser-based application for the use of your iMOW® robot mower ("STIHL MY iMOW® Web App") together also referred to as "STIHL MY iMOW® Applications".
You can use a limited range of functions of the STIHL MY iMOW® Applications without logging into the STIHL MY iMOW® Applications. To log into the STIHL MY iMOW® Applications you need a STIHL Account for the STIHL Digital Platform and its Solutions. Information on the collection, processing, and use of your personal data in connection with the STIHL Digital Platform and your STIHL Account can be found in the Privacy Policy https://app.stihl.com/en-us/legal/privacy for the STIHL Digital Platform and STIHL Solutions.
By agreeing to these Data Protection Provisions you consent to “STIHL Inc.” collecting, processing and using your personal data in compliance with the relevant U.S. federal, state, and local laws and regulations, and in accordance with the following provisions. We will inform you about the processing of your personal data relating to the web addresses (Uniform Resource Locator, "URL") you access. Should you access the STIHL MY iMOW® Applications via a URL that is intended to serve a different country and its legal requirements (i.e. you, as an example, instead of accessing the STIHL URL ending in “usa.com” or “.us”, access a STIHL URL ending in “.de” or “co.uk”) you may end up not being informed in accordance with applicable local legal requirements. For data protection reasons, we do not determine your place of residence ("localization") to determine the law applicable to you.
The following is responsible for the processing of your personal data in connection with the STIHL MY iMOW® Applications, subject to any deviating information in this Privacy Policy:
STIHL Incorporated (hereinafter "STIHL Inc.", "we", “us”)
Address: 536 Viking Drive, Virginia Beach, Virginia 23452, USA
Email: stihlcs@stihl.us
Telephone: 1-800-467-8445
We are responsible for certain processing operations together with other companies of the STIHL Group. Further information on these processing operations subject to joint responsibility and the STIHL companies and our partners involved in the processing can be found below in this Privacy Policy. If the processing of your personal data is carried out in joint responsibility, an agreement on the processing in joint responsibility has been concluded between the STIHL company or our partners involved in the processing.
Please note that we can also cooperate with companies of the STIHL Group and companies outside the STIHL Group within the framework of a separate responsibility, i.e. two independently responsible entities and by means of contract processing.
The Data Protection Officer of STIHL Inc. can be reached at the address for the controller, addressed to "Legal Department" or email to legal.notices@stihl.us.
In the case of processing personal data in join controllership, please also contact the Data Protection Officer at the above contact details.
When we use the term “personal data” in this Privacy Policy, we mean all information that relates to you.
Personal data includes, for example, your name, email address, postal address, telephone number, username, passwords, geolocation data, records of products purchased, mobile devices connected to the “MY iMOW App” and/or the “MY iMOW Web App”, tokens, connected services of third-party providers, consumption data and other data you make available to STIHL Inc. for the purpose of registering. Your personal data also includes all data that identifies you, are linked to you or reasonably linkable to you, or that relate to you, such as data that will be processed when you use the MY iMOW® Applications. We refer to data that does not relate to or that is not linked or reasonably linkable to you as non-personal, de-identified, or anonymous data. The data protection regulations and this Privacy Policy do not apply to such data.
By agreeing to these Data Protection Provisions you consent to STIHL Inc. collecting, processing and using your personal data in compliance with the relevant federal, state, and local laws and regulations, and in accordance with the following provisions. We process your personal data on the following basis:
· The processing of your personal data is necessary for the fulfilment of a contract with you or for the implementation of pre-contractual measures that take place at your request.
· You have given us your consent to the processing of your personal data for one or more specific purposes.
· The processing of your personal data is necessary to fulfil a legal obligation to which we are subject.
· The processing is necessary to safeguard our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail.
Further information regarding processing operations and data protection regulations can be found below in this Privacy Policy.
We process the personal data that you provide us, that we collect (automatically), or that we receive from third parties. Although you are not obligated to provide us with your personal data, the disclosure of certain personal data may be necessary to enable us to offer you the STIHL MY iMOW® Applications.
Personal data you provide to us
We process the information you provide to us regardless of how it is provided to STIHL Inc. (e.g. by phone, email, mobile application, or other means of contact). You can provide us with further data when you make certain settings or configure MY iMOW® Applications according to your needs. We collect and process this data to enable you to use the STIHL MY iMOW® Applications. If you do not provide us with certain information, the use or functionality of the STIHL MY iMOW® Applications may be excluded or impaired.
Personal data we collect
We collect certain information (automatically) and process it when you use the STIHL MY iMOW® Applications. This includes, for example, data such as your IP address, certain login data, and data that will be processed so that we can technically provide you with the STIHL MY iMOW® Applications.
Personal data we receive from third parties
In some cases, we do not receive information directly from you. This may be the case, for example, if information about you is provided to us by third parties. We work with companies that provide services to us and who in turn provide us with information about you. These include, for example, payment service providers or providers of what are known as app stores.
When accessing our website, the browser used on your device automatically sends information to our website server, which temporarily saves it in a so-called log file.
Categories of personal data
The following information will be processed when the website is accessed:
· the IP address of the requesting Internet-enabled device;
· the date and time of the access;
· the name and URL of the retrieved file;
· the website/application from which access was gained (referrer URL); and
· the browser you are using and, if applicable, the operating system of your Internet-enabled computer and the name of your access provider.
Purpose
The processing of your personal data serves the following purpose or purposes:
· ensuring a smooth connection;
· ensuring a comfortable use of our website/application; and
· evaluation of system security and stability.
Controller
Within the context of controlling your iMOW® robot mower, STIHL Inc. is the controller but we work with other STIHL Group companies to be able to provide you with fast customer service regarding your iMOW robot mower. In this respect, we may share your personal data with affiliated STIHL Group members for processing.
Categories of personal data
The following information will be processed:
· settings related to your iMOW® robot mower, such as cutting height, safety functions, rain sensor;
· properties of your mowing application, such as start of mowing, duration of mowing job, if desired mowing zone, standard mowing time;
· a mower plan, if any, that you have defined.
Purpose
The processing of your personal data serves the following purpose or purposes:
· the configuration of your iMOW® robot mower;
· the control of your iMOW® robot mower.
Categories of personal data
The following information is processed in the process of locating your iMOW® robot mower:
· The current geo-coordinates of the iMOW® robot mower are processed when your iMOW® robot mower is connected to the Internet.
· The "Home Area" of the iMOW® robot mower is processed after the "Home Area" function is activated on the mower.
Purpose
The processing of your personal data serves the following purpose or purposes:
· You have the possibility to display your iMOW® robot mower on a map in your MY iMOW® Applications and locate it so that you are always informed about the location of your iMOW.
· Displaying weather forecasts in the mowing plan of the MY iMOW® applications.
· By activating the Home Area function, the mower can lock itself when moved outside the area.
You can use and control your iMOW® robot mower via the MY iMOW® App, including various voice control systems. You will find below information about voice control systems and their providers. We also refer to the privacy policies of these providers, in which you will find further information on the processing of your personal data in connection with the use of voice control.
Controller
If you use one of the voice control systems, the providers of these voice systems may process your personal data subject to their own responsibility in accordance with the providers' privacy policies. This means, among other things, that these providers can process your data for their own purposes.
Categories of personal data
The following information will be processed when communicating with you:
· properties of your mowing application or control of your iMOW® mowing robot, such as starting mowing, duration of mowing jobs, if desired mowing zone, standard mowing time;
· a mower plan, if any, that you have defined.
Purpose
The processing of your personal data serves the following purpose or purposes:
· Controlling your iMOW® robot mower by voice command and providing or querying the current iMOW® status by voice command.
Voice control provider
·
Voice control via Apple Shortcuts App: Provider
is Apple. The privacy policy is available at:
https://www.apple.com/legal/privacy/data/en/shortcuts-sharing/
·
Voice control via Amazon Alexa: Provider is
Amazon. The privacy policy is available at:
https://www.amazon.com/gp/help/customer/display.html?nodeId=GVP69FUJ48X9DK8V
· Voice control via Google Assistant: Provider is Google. The privacy policy is available at: https://policies.google.com/privacy
There are various ways to contact us, for example by email, by mail, by telephone, via contact forms or by other means. We will be happy to answer any questions you may have via any of the communication channels we provide. We will generally contact you by email.
Joint responsibility
If you communicate
with STIHL Inc. TIROL, STIHL Inc. TIROL is responsible for the
processing of your personal data. If communication with you or processing your
request or concern requires the involvement of other STIHL Group companies, we
will process your request or concern together with these companies. Depending
on the subject-matter of your request or concern, other STIHL Group companies
incorporated by STIHL TIROL may process your personal data on behalf of
STIHL, Inc. or as a jointly responsible body with the other STIHL Group
company(ies) TIROL.
Categories of personal data
The following information will be processed when communicating with you:
· your contact details such as your telephone number or email address;
· data relating to your request or concern, such as the subject of your request or our communication with you.
Purpose
The processing of your personal data serves the following purpose or purposes:
· communication with you if you have questions about the STIHL MY iMOW® Applications or the iMOW® robot mower;
· handling and responding to your enquiries and concerns;
· communication with you outside of inquiries and concerns, for example for information purposes or for the fulfilment of legal obligations;
· when we record telephone calls, this is done for quality assurance and training purposes;
If you have any questions or if you cannot use the STIHL MY iMOW® Applications or the iMOW® robot mower as described by us, our support is always at your disposal. We will inform and support you if, regardless of your contact with us, we find that you cannot use the STIHL MY iMOW® Applications or the iMOW® robot mower as described by us.
Controller
As part of the support, we work with other STIHL Group companies to provide you with quick and easy assistance as well as processing operations to improve our support.
Categories of personal data
The following information will be processed as part of the support:
· your contact details;
· communication with you, including recordings of telephone conversations with you, if you have given your consent to the recording;
· data related to the support case and the data required to resolve your support case.
Purpose
The processing of your personal data serves the following purpose or purposes:
· processing your support request;
· if we record the telephone conversations in the context of the support on the basis of your consent, this will be done for quality assurance and training purposes;
· improving our support.
We process certain data in order to improve and further develop STIHL MY iMOW® applications or the iMOW® robot mower and other offers and services (or our support). This concerns in particular data about the use of STIHL MY iMOW® applications as well as data related to, among other things, the properties, security and quality of our offer.
As far as possible, the data will be pseudonymised or anonymised prior to processing for product development and statistical evaluation. If the data are anonymised, they are no longer personal data.
Joint responsibility
In the context of product development and statistical analysis, we cooperate with other companies of the STIHL Group and may process such data jointly
Categories of personal data
The following information is processed in the framework of product development and statistical analysis:
· data on the use of the STIHL MY iMOW® Applications or the iMOW® robot mower;
· data on the properties, security and quality of the STIHL MY iMOW® Applications or the iMOW® robot mower;
· other information we have, e.g. from support requests from you.
Purpose
The processing of your personal data serves the following purpose or purposes:
· improvement and further development of STIHL MY iMOW® Applications or the iMOW® robot mower;
· product development, including in the area of artificial intelligence, (machine learning);
· market research;
· ensuring the security and quality of the STIHL MY iMOW® Applications.
As long as you use the STIHL MY iMOW® Applications or until you delete your STIHL Account, we will process your personal data as it is necessary to provide you with the STIHL MY iMOW® Applications you want. The storage period for your personal data depends in particular on which of the features offered by the STIHL MY iMOW® Applications you use and in accordance with applicable law.
In addition, the storage period depends on the category of personal data processed and the purpose of the processing. Finally, we take into account legal retention periods, which may obligate us to keep your data for a certain period of time. Accordingly, storage may take place if this is provided for by applicable regulations, laws or other provisions to which we are subject.
In the event of a legal dispute, we will keep the personal data we need for legal defence until the final conclusion of the proceedings, or as otherwise required by applicable law or legal retention periods.
For more information on the storage period, please contact us via the contact details to be found in this Privacy Policy under section 2.
If you wish to assert your data rights as specified below, you can contact us at any time and without any required form via the communication channels specified in this Privacy Policy. By email and on the other communication channels, you can reach STIHL Inc. and the Data Protection Officer of STIHL Inc. via the contact details specified under Section 2 of this Privacy Policy.
Verification of Requests
Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.
We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by applicable state law.
The following generally describes the verification processes we use:
· Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity,but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
· Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
· For requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
· For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request. We will maintain all signed declarations as part of our records.
· For requests to delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.
Right to Non-Discrimination for the Exercise of Privacy Rights
STIHL Inc. will not discriminate against any individuals who have exercised any of the above listed privacy rights. We will not deny providing goods or services to you, charge you different prices or provide a different level or quality of goods and services to you unless those differences are related to the value of your information.
In this Privacy Policy, we will always keep you fully and completely informed about the processing of your personal data in connection with the STIHL MY iMOW® Applications. This requires that we update this Privacy Policy regularly. We therefore recommend that you consult this Privacy Policy regularly.