• Data act
• Room Air Conditioner
  Commercial Air Conditioner
  A2W heat pumps
  Hydronic heat pumps,
  CZ-256ESMC3
• Cold Chain Refrigeration products
• Panasonic Comfort Cloud
  Panasonic AC Smart Cloud
  Panasonic Service Cloud
• Panasonic H&C Control App

Data Act Notice

Panasonic Comfort Cloud, Smart Cloud and Service Cloud

Panasonic is committed to ensuring that any data generated by our connected products and related services is used fairly, lawfully, and securely. We place high importance on compliance with Regulation (EU) 2023/2854 (the “Data Act”)

This Notice is intended to tell Users which data can be generated by the products we sell and our related services. Where we are Data Holder under the Data Act for data generated by our products or related services, we will also tell you how we use such data, what rights and obligations users have for such Data, how users can get access to such Data and where to go in case of complaints. You will also find contact information for any questions related to data handling.

This Notice must be read jointly with, and is without prejudice to, the applicable data privacy notice, which shall prevail over this Notice as concerns personal data.

GENERAL

Panasonic Corporation, registered in Japan whose registered office is at 1006, Oaza Kadoma, Kadoma-shi, Osaka, Japan, is responsible for the handling of Product Data/Related Service Data as the “Data Holder” under the EU Data Act (“we”, “us” or “our” in the following).

The present notice covers the Related Service(s) which are falling under the EU Data Act:

Comfort Cloud App, Smart Cloud and Service Cloud, which can be used with Panasonic-branded Air to water heat pumps and air to air heat pumps (the Product(s))

The provision of these Service(s) requires the user to enter into an agreement with us specific to that service and can be terminated in accordance with the provisions of the relevant agreement.

DATA GENERATED BY OUR PRODUCTS/RELATED SERVICE(S)

The following Data, which is stored on the server, is being generated through your use of our Product and Related Service.

WHAT DO WE USE THE DATA FOR?

We undertake to use the Data that are non-personal Data only for the purposes as follows:

• Performing an agreement with the User or activities related to such Service(s) (e.g. issuing invoices, generating and providing reports or analysis, financial projections, impact assessments, calculating staff benefit);

• Providing support, warranty, guarantee or similar activities or to assess User’s or third party’s claims (e.g. regarding malfunctions of the Product) related to the Product or Related Service;

• Monitoring and maintaining the functioning, safety and security of the Product or Related Service and ensuring quality control;

• Improving the functioning of any product or related service offered by Panasonic;

• Developing new products or services.

WHO WILL WE SHARE THE DATA WITH?

We may have to disclose the Data to the following categories of recipients for the purposes set out above:

I. Panasonic Holdings Corporation and Affiliates

We may need to transfer your Personal Data within the Panasonic Group of Companies. All companies within the Panasonic Group are required to follow strict information security regulations and can only process the Data in line with this Notice and the contract with the User.

II. Service Providers

We use external service providers to provide us with information technology, systems administration, customer services and maintenance services, and to help us manage certain activities and services on our behalf, and we will contractually bind such parties to only act in accordance with our instructions and not to use the Data for any purposes or in any way going beyond the use that is permissible in accordance with this clause and to otherwise comply with protection measures and restrictions set out in this contract.

III. Third parties when required by Law or to Protect our Business and Services

We will disclose your Data to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; to protect our customers (e.g., to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g., to prevent or stop an attack on our systems or networks); to protect the health and safety of our colleagues and others with whom we have contact; or to protect the rights or property of Panasonic, including enforcing any terms or agreements governing the use of our Services.

IV. Other Parties in Connection With Corporate Transactions

We may disclose the Data to a third party or within the Panasonic Group of Companies as part of a reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of Panasonic's business, assets, or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

ACCESSING DATA

Under the EU Data Act, Users have the right to access the Data generated by Connected Products or Related Services as well as to give access to third parties (Data Recipients).

When the User is not the data subject, we will only make the Data which is personal data only available to the User or to a Data Recipient, when there is a valid legal basis for making personal data available under Article 6 of Regulation (EU) 2016/679 (GDPR) and only, where relevant, the conditions set out in Article 9 of that Regulation and of Article 5(3) of Directive 2002/58/EC (Directive on privacy and electronic communications) are met.

How can the User access the Data?

The Data can only be accessed on request, see the overview above. At the request of the User or a party acting on their behalf, we will make the Data accessible to the User without undue delay. The request can be made by submitting a request through the email set out here:

DataAct@eu.panasonic.com

We may ask for information to verify that the request is made by the User, but this shall not go beyond what is necessary. If the request is made by a party acting on behalf of the User, evidence of their mandate must be provided.

If the User is not the Data Subject, the User must indicate to Panasonic, in each request, the legal basis for processing under Article 6 of Regulation (EU) 2016/679 (and, where relevant, the applicable derogation under Article 9 of that Regulation and Article 5(3) of Directive (EU)2002/58) upon which the making available of personal data is requested.

We will make the Data available in the following way: The data will be provided to you using our secure file transfer system. The User will receive an email with instructions on how to obtain the files and a link to the files.

We undertake not to keep any information on the User’s access to the requested data beyond what is necessary for:

1. the sound execution of (i) the User’s access request and (ii) the contract with the user;

2. the security and maintenance of the data infrastructure; and

3. compliance with our legal obligations to keep such information.

COMPLAINTS

If the User has issues getting access to the Data and if the User notifies us with a detailed description of such issues, we will cooperate in good faith to identify the reason of such issues and, where this is due to our failure to comply with our obligations under this notice, our contract with the user or under the Data Act, we will remedy this within a reasonable period of time. This is without limitation to the User’s rights under our contract with the user.

If the User is not satisfied with how we handle the Data, the User is entitled to lodge a complaint with the competent authority, designated in accordance with Article 37(5), point (b) of the Data Act.

CONTACT

For any questions regarding the handling of Data, request access to the Data or technical issues with access, please contact us at:

DataAct@eu.panasonic.com

You can also contact our EU representative at:

Panasonic Europe B.V. Germany Branch

Hagenauerstrasse 43

D-65203 Wiesbaden

Germany