HMS Customer Privacy Policy

Processing of personal data is necessary to handle orders and deliver products or services to the company where you are employed, as well as handle warranty and payments.

We process information about which company you represent and your contact information, payment information and information about the products ordered. If you use our on-line services related to this, your IP number will also be stored.

The data collected during order handling can also be used to contact you regarding products updates and advisories, HMS customer surveys and marketing of new products and services.

If you do not want to receive such information you can ask us to block delivery by contacting us. We will store your data for seven years after your last contact with us, it will then be erased at the end of that year.

In addition, economic transaction data will be archived according to the legal requirements for bookkeeping and taxes, in general for maximum ten years + current year.

When using our cloud services, we are responsible data controller for processing information in the following categories:

• Identification data (name, address, telephone, phone number, email address, company name and company identification)

• Account data (user name, account name)

• List of connected devices (like Flexy/Cosy/CD/Netbiter, Anybus Edge devices etc.)

• Traffic metadata (including: the time and duration of the connection, number of bytes transferred, device identification and similar metadata)

• Credentials (password, hint password)

We process your data as long as you have an active service account. If there has not been any traffic associated to the account for seven years, the account and any associated data will be permanently deleted.

We process this information to be able to provide the services as defined in the terms of usage and to develop and maintain our cloud services.

This processing is based on our legitimate interest. The processing of personal data is necessary to ensure that only authorized individuals access the cloud services and to ensure that the cloud services are fully functioning and continuously developed, which we also believe is beneficial for you as a customer representative or user. In light of the above we have come to the conclusion that our legitimate interest outweighs your interest of not having your personal data processed for these purposes. You may object to this assessment, please read more about your rights below.

If you do not provide your personal data to us we may not be able to provide you with access to the cloud services.

Personally Identifiable Information in customer data / log data

Traffic data generated to/from connected devices (log data) is owned by the HMS customer responsible for the current account. In case there is personal identifiable information processed in this data, the account owner (HMS Customer) is the responsible data controller and HMS will act as data processor in regards of this data.

To deliver excellent services and provide you with quotations etc. we use a customer relationship management system. In this system we process your contact information, our activities (phone calls, emails, visits etc.) and what kind of information you want to receive.

We base this process on legitimate interest and keep this information for seven years from the last activity.

To provide you with customer support we process your contact details, information about the product or service supported and other information you may submit related to the support case.

To efficiently follow up on your cases we keep this data for seven years after last contact, after this period we may keep general support information to improve our products and solutions but will remove any information that can be linked to an individual.

We base this process on legitimate interest or contractual requirement in case the product is under warranty.

We will send you marketing information if you are a customer, have actively signed up to receive email marketing or otherwise showed clear interest in HMS and our products and services, for example, at fairs or seminars. We may also get address information from marketing partners that provide addresses to relevant companies.

For statistical purposes we use web beacons in our marketing emails to measure if the email is opened, the links that are followed together with date and time.

You can say no to further marketing information at any time by clicking the unsubscribe link in the footer of the email you receive from us. You can also say no to further marketing activities by contacting us at the address at the end of this policy. You have the possibility to say no to specific communication channels (phone, e-mail, fax etc.)

We base our processing for marketing purposes on legitimate interest or by your consent when you sign up on mailing lists or otherwise show clear interest in our products.

To enhance our offering, check trends and your overall satisfaction with HMS and our product and services, we do customer surveys from time to time.

If not otherwise mentioned, we will store your contact information together with your answers to be able to follow up on you if necessary.

We will send you surveys based on our legitimate interest, as described in the beginning of this section. The processing of your answers is based on your consent to participate in the survey.

If you attend our seminars, presentations or training workshops arranged by HMS, on-line or at location, we will store your contact information for follow up and for marketing activities.

Events may be recorded, should this be the case participants will be notified.

In case food is provided we may ask for specific food preferences, this information can be sensitive and is only processed if required for the arrangement of the event and is then deleted.

If you submit information to our on-line forums or social media accounts managed by HMS, you provide this information based on your consent for us to process it. We ask you to not post any information that can be related to any third person.

When you visit our webpages, we automatically collect some technical information on the web server:

Name of the file accessed, date and time of access, amount of data transmitted, notification of successful access, web browser, requesting domain and the public IP addresses of the requesting computer.

We store this information based on legitimate interest only to be able to detect misuse or technical problems. The server logs are stored for six months.

To be able to complete our services, we may transfer your data to external parties, where they are the responsible data controller, this includes:

• Address and contact information to transportation companies to deliver your order.
• Your contact details with contracted distributors to sell our products, respond to your product requests, organize marketing or promotional operations, contests, games and similar events; and fight against fraud.
• Invoicing information, like data usage, to an HMS Distributor when we sell to you via such channel.

We will never sell your information to any third party but can process your information within the HMS group globally.

Please be informed that, notwithstanding the abovementioned, in the event of a designated authority lawfully requesting HMS Industrial Network to retain and provide personal data, communications content and/or traffic data, we will provide all reasonable assistance and information to fulfil this request.

We use external data processors to provide us with different services, including:

• IT service providers (Hosting, back-up, cloud solutions etc.)
• Marketing partners (Surveys, e-mailing etc.)
• Services to handle payments, like credit cards

These service providers are only allowed to process information on behalf of HMS and as specifically instructed by us.

It is important for us that your data is safe. We use up-to-date data protection mechanisms and have a good security posture.

HMS Industrial Network entities ensure due care and take appropriate organizational and technical measures to protect the confidentiality and integrity of the personal data and communication data provided, collected and/or stored on our systems and shall not retain it any longer than permitted in order to perform its services or as required under relevant legislation.

Your personal and communication data can only be accessed by authorized employees of HMS Industrial Networks that need to have access to this data in order to be able to fulfil their given duties.

Your information may be stored and processed in any country in which HMS Industrial Network maintain facilities, including outside of the European Economic Area (EU, Norway, Liechtenstein and Iceland).

We only make such transfer if the recipient of the data is located in a country which provides an adequate level of protection following a European Commission adequacy decision or if appropriate safeguards as within the EU have been provided HMS Industrial Network by executing standard contractual clauses.

You have the right to know what information we process about you and the right to have your information corrected or deleted unless we have a legal duty to keep it. You also have the right of data portability.

You can withdraw your consent for processing at any time. Please note that such withdrawal will not affect the lawfulness of processing based on your consent before the withdrawal.

If you want to exercise one of your rights, please contact us using the contact information below. Within a reasonable period of time and upon verification of your identity and to the extent your request is legitimate, we will fulfil your request, provided we will not act contrary to applicable legislation by fulfilling your request.

HMS is responsible for your personal data, do not hesitate to contact us in case you have questions. HMS refers to HMS Industrial Networks AB and its subsidiary companies. For the purposes of applicable data protection law, the controller of your data will be the HMS affiliate which is providing services or communicating to you.

For data protection questions in general, or questions regarding our global processing:

HMS Industrial Networks AB
Att: Data protection responsible
PO Box 4126
SE-300 04 Halmstad
Sweden
dataprotection@hms-networks.com

For Argos and Talk2M cloud services:

HMS Industrial Networks SA
Att: Data protection responsible
22, Avenue Robert Schuman
1400 Nivelles
Belgium
dataprotection@hms-networks.com

In case you do not think we have fulfilled our obligations you have the right to lodge a complaint with a supervisory authority.

For HMS Industrial Networks, the supervisory authority is:

Datainspektionen
Box 8114
104 20 Stockholm
Sweden
https://www.datainspektionen.se