Privacy Policy of Mobile Industrial Robots A/S
Mobile Industrial Robots A/S ("MiR”) and each of our related corporations, affiliates, subsidiaries, and associated companies take processing of Personal Data very seriously. Mobile Industrial Robots ensures a reasonable and transparent processing of Personal Data in accordance with all applicable laws, local and international regulations, including the European Union’s General Data Protection Regulation ("GDPR"). MiR protects Personal Data and the privacy of individuals within all areas of its business in accordance with the terms of this Privacy Policy of Mobile Industrial Robots A/S (“Privacy Policy”).
1. Personal Data and Data Subject
For purpose of this Privacy Policy, “Personal Data” means any information relating to an identified or an identifiable natural person (a “Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, for example, by reference to a name, an identification number or online identifiers.
The Personal Data is generally categorized as either “Ordinary Personal Data” or “Sensitive Personal Data”. Sensitive Personal Data is always confidential and includes racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, health, and sexual orientation. Ordinary Personal Data is partially confidential, and includes but is not limited to name, customer number, contact information such as email and telephone number, photos, IP addresses, other usage information collected via cookies, information related to criminal offenses and national identification numbers, as well as information regarding a person's salary, pension, debt, employment application materials, etc.
This Privacy Policy applies to all Personal Data MiR collects and processes about individuals, including but not limited to visitors, customers, suppliers, other stakeholders and users of MiR’ website and services.
2. Data Controller
MiR is the data controller (“Data Controller”) of the Personal Data covered by this Privacy Policy.
Contact details:
Mobile Industrial Robots A/S
Emil Neckelmanns Vej 15
5220 Odense SO, Denmark
Telephone: +45 20 377 577
Website: https://www.mobile-industrial-robots.com/
For any questions related to this Privacy Policy and processing of personal data, please contact the MiR Data Protection Team.
MiR has offices worldwide. Location and contact details of worldwide offices can be located on the MiR’ website on the contact page.
MiR’ parent company is Teradyne Inc., located at Riverpark Drive, North Reading, Massachusetts 01864, USA.
MiR may share Personal Data with other companies and brands owned or controlled by Mobile Industrial Robots A/S (“Affiliates”), including, but not limited to:
Mobile Industrial Robots GmbH (Germany)
MiR Robots S.L. (Spain)
MiR Robots (Shanghai) Co., Ltd.
Mobile Industrial Robots A/S, Japanese Branch
In the event MiR shares Personal Data with Affiliates, the Affiliates’ use of such Personal Data is subject to this Privacy Policy.
All Personal Data transfers, including cross-border transfers between MiR, Affiliates and MiR’ parent company are made in compliance with applicable law. More information on data transfers can be found in Section 5 of this Privacy Policy.
3. Legal Grounds for Processing of Personal Data
MiR may process Personal Data if one of the following options applies:
- Individual/company has given prior consent to processing of his/her/its Personal Data for one or more specific purposes. Note: Under some legislation MiR may be allowed to process Personal Data until an individual objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, when the processing of Personal Data is subject to European Data Protection laws;
- Processing of data is necessary for the performance of a contract and/or for any pre-contractual obligations;
- Processing is necessary for compliance with any legal obligations;
- Processing of Personal Data is necessary to establish, exercise or defend any legal claims;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in MiR; and/or,
- Processing is necessary for the purposes of the legitimate interests pursued by MiR or by a third party, if such interests are considered to override individual/company interests or fundamental rights. Such legitimate interests may include MiR’ interests in developing, marketing and selling products and providing services, and pursuing and maintaining business relationship with customers, suppliers, distributors, partners and other business relations.
Upon request, MiR will provide information to clarify the specific legal basis that applies to specific processing activities, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Consent & withdrawal of consent. To the extent that MiR’ processing activities are based on the Data Subject’s consent, the Data Subject maintains the right to withdraw his/her/its consent at any time. If Data Subject withdraws his/her/its consent, MiR will cease processing of the Data Subject’s Personal Data, unless and to the extent that continued processing is permitted or required according to the applicable Personal Data legislation or other applicable law. If the Data Subject withdraws his/her/its consent, it will not affect the lawfulness of processing conducted prior to the withdrawal.
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in MiR or for the purpose of the legitimate interests pursued by MiR, an individual may object to such processing by providing a ground related to the individual’s particular situation to justify the objection. However, if Personal Data is processed for direct marketing purposes, an individual can object to such processing at any time without providing any justification by contacting the Data Protection Team.
Notice of statutory or required processing. In cases where MiR processes Personal Data based on a legal obligation or a requirement under a contract or a requirement that must be met in order to enter into a contract, the customer is obliged to provide MiR with the information so that MiR can maintain the customer relationship, fulfil the contract and invoice for our services, etc. If the customer does not wish to provide MiR with the information MiR needs to comply with contractual and/or statutory obligations, the consequence may be that MiR is unable to establish or continue the business relationship.
Individuals are not obliged to provide MiR with Personal Data in all cases, for example, for use in MiR marketing and newsletter distribution. However, in such instances, the individuals will not be able to receive marketing materials and newsletters from MiR.
4. The Types of and Purpose for the Collection of Personal Data
MiR collects and processes Personal Data, including Sensitive Personal Data (if any) only for specified, explicit, and legitimate purposes which are relevant to MiR’ business. Internal MiR departments and MiR employees who have access to Personal Data must follow applicable legal requirements; this Privacy Policy; and internal guidelines.
Employment. MiR collects and processes Personal Data, including Sensitive Personal Data (if any) of applicants, candidates and employees for employment purposes and in accordance with legal requirements.
Visitors. MiR collects and processes Personal Data of visitors including name, title (if applicable) and contact details for security reasons and registers such information in the visitor log prior to granting visitors access to the MiR premises.
MiR’ website users. MiR collects by itself or through third parties Personal Data of website users, which may include: cookies, usage data, name, contact details, and company information, if applicable. The data is collected and processed for marketing, advertising, and analytics purposes, and also for contacting the website users, including MirGo users, any App users, and MiR Academy users, managing contacts and sending messages, remarketing and behavioral targeting.
For operation and maintenance purposes, MiR and any third-party service providers may collect files that record a user’s interaction with the website. Such Personal Data is obtained through consent by the website users and collected automatically on the MiR´ website.
The MiR’ website does not support “Do Not Track” requests. To determine whether any of the MiR’ third-party service providers honor “Do Not Track” requests, please read the providers’ respective privacy policies.
Users are responsible for any third-party Personal Data obtained, published or shared through the website by the user and the users confirm that they have the third party's consent to provide such Personal Data to MiR. Users who are uncertain about which Personal Data is mandatory are welcome to contact the MiR Data Protection Team.
Data of Minors. MiR’ websites and online services are not directed to children under the age of 16, unless in very specific instances, e.g., issuance of scholarships, under which circumstance parental and/or school consent will be obtained. If MiR has Personal Data that pertains to a child under the age of 16, MiR will promptly delete such Personal Data from its respective systems.
Cookies. Any use of cookies – or other tracking tools – by the website and/or by the owners of third-party services used by the website serves the purpose of providing the services required by the user, in addition to any other purposes described in this Privacy Policy and the Cookie Policy.
MiR uses cookies to understand and save user preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. MiR may contract with third-party service providers to assist in better understanding MiR website visitors. These service providers are not permitted to use the information collected on MiR’ behalf except to help conduct and improve MiR’ business.
More details related to cookie notice please find in the Cookie Policy.
Marketing. MiR collects and processes Personal Data (including name and contact details) about current and new customers, business partners, suppliers, distributors, leads and individuals, website users and on individuals who have signed up for MiR’ newsletters or other electronical marketing materials, as well as in some cases for the following purposes: analytics, contacting, managing contacts and sending messages, remarketing and behavioral targeting, advertising, and exhibitions.
Such Personal Data is collected and processed under the marketing consent. MiR obtains valid consent through an online form. The marketing department and other involved departments must ensure that marketing consent is obtained before collecting and processing such Personal Data.
MiR may use third parties as a service provider to send out marketing information on its behalf but only in accordance with applicable legal requirements.
For any further questions related to marketing information, please contact the marketing department at marketing@mir-robots.com
Contracts. In connection with its sales and purchase transactions, MiR collects and processes Personal Data, including names, contact details, delivery details, correspondence, and payment details necessary for fulfilling its contractual obligations and as may be necessary to comply with export control regulations and other legal due diligence obligations.
Accounting and Finance. MiR collects Personal Data for accounting and financial purposes in accordance with applicable requirements. This information is provided to accounting by other internal departments or received directly from the individuals/companies, employees, and includes information such as name, address, company name, registration number, payment details and bank details, delivery address and other mandatory information.
Educational Programs. MiR Academy (“MiR Academy”) collects information from individuals/companies when they register as users on the training website at: https://www.mobile-industrial-robots.com/en/insights/mir-academy/, or when they use a company or other entity user profile on the website, and MiR Academy gathers data when individuals participate on the MiR Academy platform by reading, writing, and evaluating the content shared here as well as when purchasing in-class training. MiR collects and processes Personal Data (including, contact details, technical data, the URL user came from, the URL user goes to, the browser utilized by user, user IP address, and user IP domain information and cookies) for the following purposes: to facilitate users’ use of MiR website, services and products, to contact users as part of MiR’ customer relationship and to provide customer service and support, to send newsletters or other marketing material, surveys etc., to pursue business leads and remarketing, behavioural targeting and advertising.
Legal action. In case of a dispute, MiR may retain Personal Data necessary for its legitimate interest to ensure that MiR can properly bring or defend legal claims in court or during the stages leading to possible legal action. MiR may need to share this information with third parties such as insurance and/or legal advisers and MiR may also be required to reveal Personal Data upon request of public authorities.
Whistleblowing system. MiR respects confidentiality of whistleblowers and has several channels in place for such reporting, including electronic/digital systems (https://www.whistleblowerservices.com/teradyne). MiR collects and processes Personal Data in the whistleblowing system for the purpose of conducting investigations, and to take remedial or legal actions in accordance with legal requirements; this Privacy Policy; and the Whistleblower Policy.
5. Place and International Data Transfer
The Personal Data is processed at the MiR’ operating offices and in any other places where the parties involved in the processing are located. MiR ensures that: (i) the Personal Data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards that require the recipient to treat the Personal Data in a manner that is essentially equivalent to legal requirements.
Specific rules apply when MiR transfers Personal Data from the EU/EEA to third countries or international organizations. When transferring Personal Data to third countries or international organizations, MiR is obligated to establish appropriate safeguards prior to the transfer, which in practice are established by entering the European Commission’s Standard Contractual Clauses (“EU SCCs”) or by collecting consent from the Data Subject (Art. 49(1)(a) GDPR).
MiR may use electronic communications service providers or share data with partners based outside of EU, including countries where the legal regime for protection of Personal Data might not be as sufficient as within the EU. As an example, transfers to the US may entail that U.S. FISA 702 (surveillance legislation) can require the data to be handed over by U.S authorities. In such a scenario, the legal basis for the transfer is Data Subject consent (Art. 49(1)(a) GDPR).
In accordance with the GDPR, MiR has concluded Data Processing Agreement (DPA) and/or Joint Data Controller Agreement (JDCA) and/or agreements with Standard Contractual Clauses (SCCs) with external parties and affiliated companies, as applicable.
The Personal Data relating to individuals in the United Kingdom (“UK”) maybe processed by MiR in countries outside of the UK. In this regard the UK International Data Transfer Agreement (“IDTA”) and UK Addendum will apply to data transfer from the UK to other countries.
The Personal Data relating to individuals in China Mainland may be processed by MiR in countries outside of China Mainland. Where this occurs, it will be done in compliance with local laws, including the Personal Information Protection Law (“PIPL”). As outlined in this Privacy Policy, MiR may also transfer such Personal Data to third parties, who may in turn store or transfer the data outside of China Mainland. Please see also MiR China Privacy Policy.
6. Retention Period
The Personal Data collected by MiR shall be processed and stored for as long as required by the purpose for which the Personal Data was originally collected and in accordance with Teradyne Retention Policy. MiR may be permitted to retain the Personal Data for a longer period if MiR has obtained valid consent to the processing activity, to the extent such consent is not subsequently withdrawn. Furthermore, MiR may be obliged to retain Personal Data for a longer period, whenever required to do so for the performance of a legal obligation or where necessary to establish, exercise, or defend a legal claim.
Once the retention period expires, the Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be accommodated after expiration of the applicable retention period.
7. Individuals’ Rights
Where legally required, MiR shall inform individuals of the purpose of processing their Personal Data, rights to have their Personal Data rectified, deleted or blocked, and the identity of the company responsible for the collection and process their Personal Data. In all other cases, users may inquire with Data Protection Team to find out which rights apply to them.
Individuals have the following rights:
- Withdrawal of consent - the right at any time to withdraw previously given consent to the processing of his/her/its Personal Data.
- Object to processing of Personal Data - the right to object to the processing of Personal Data if such processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section of this Privacy Policy.
- Access to Personal Data - the right to learn if Personal Data is being processed by MiR, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
- Verify and seek rectification - the right to verify the accuracy of his/her/its Personal Data and ask for it to be updated or corrected.
- Restrict the processing of Personal Data - the right, under certain circumstances, to restrict the processing of his/her/its Personal Data. In this case, MiR will not process mentioned Personal Data for any purpose other than storing it.
- Have Personal Data deleted or otherwise removed - the right, under certain circumstances, to obtain the erasure of his/her/its Personal Data from MiR.
- Have Personal Data transferred to another data controller - the right, under certain circumstances, to have Personal Data transmitted to another controller without any hindrance.
- Lodge a complaint - the right to bring a claim before his/her/its competent data protection authority.
8. Training
To prevent any violation of applicable law, regulations and corporate standards, MiR organizes formalized data protection training for its employees in accordance with a corporate training plan. Training on data protection may be conducted via electronic communication, webinars, or in-person training. All employees are trained on basic data protection requirements and certain groups have more advanced training on Personal Data processing based on business needs.
9. Ongoing Audit & Monitoring
Through a combination of external and internal controls, ongoing audit and monitoring, MiR seeks to maintain secure processing of data and prevent data loss. In case of audit findings, the responsible department must prepare a mitigation plan, including corrective and preventive actions to mitigate risks and bring procedures and policies in compliance with legal requirements, corporate standards and this Privacy Policy.
10. Reporting System and Contact Details
In case of questions and/or possible violations of this Privacy Policy, please contact the Data Protection Team at:
Mobile Industrial Robots A/S
Emil Neckelmanns Vej 15
5220 Odense SO
Denmark
Telephone: +45 89 93 89 89 (please request to speak with the Legal Department)
E-mail: dataprotection@mir-robots.com
Any request can be exercised free of charge and will be addressed as expeditiously as possible and always within one (1) month or sooner, if required by applicable law.
11. Changes to this Privacy Policy
MiR reserves the right to amend this Privacy Policy. The latest edition will always be available at our website, and we strongly recommend that you continually monitor and update yourself with our Privacy Policy.
12. Region-Specifics
In accordance with applicable privacy laws and depending upon the jurisdiction, the additional requirements may apply with respect to the collection and processing of Personal Data.
MiR may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions or states.
- For the EU/ EEA and UK residents, and other regions, if it is not mentioned otherwise, apply this Privacy Policy.
- For the resident of the State of California in the United States, please see the Privacy Notice for California Residents.
- For the residents of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact Data Protection Team at dataprotection@mir-robots.com with the subject line, “Nevada Opt-Out Request.”
- For the residents of Colorado, Connecticut, Utah and Virginia in the United States, please see the Privacy Notice for Residents of Colorado, Connecticut, Utah and Virginia.
- For China residents, please see MiR China Privacy Policy.
