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Information on EU Data Act
In light of the EU Data Act (Regulation (EU) 2023/2854) (“Data Act”), VTech (“we”, “our”) informs you of the following.
The Data Act applies to certain hardware devices and their associated services, which are defined in the regulation as “connected products” and “related services”. This document provides you, prior to the purchase or use of our connected products, with the information required under the Data Act. The purpose of this document is to ensure transparency about what data is collected, how it is accessible to you, and under what conditions third parties may gain access.
The VTech connected products can generate data through their use, performance, or environment in order to provide their core functions. Data is generated when you interact directly with the device (e.g., when you press a button to adjust the speaker volume of your device) or when you use an app to control sensors or device features (e.g., when you use our app to control the camera of your device, or when you select the language for your device). The data generated qualifies as “product data” under the Data Act, including operational data (e.g., camera user configuration data), interaction data (e.g., app/soother settings), and technical/diagnostic data (e.g., camera logging data).
The VTech connected products generate different types of product data, depending on the device’s functionalities, specific settings and configurations, and how the device is used. Depending on the product, data may be generated continuously and in real time. The volume and types of data generated may vary depending on the particular device being used.
Please refer to the following tables for details on the data that the VTech connected product is capable of generating:-
a) Baby Monitors
Type of Product Data | Categories of Product Data | Format | Estimated Volume Per User |
Camera User Configuration Data | Operational Data | Text | <1MB |
Camera Logging Data | Technical/ Diagnostic Data | Text | <100MB |
App Crash Logs Data | Technical/ Diagnostic Data | Text | <23MB |
App Analytics Data | Technical/ Diagnostic Data | Text | <30MB |
App User Settings Data | Operational Data | Text | <1MB |
b) Soother Products
Type of Product Data | Categories of Product Data | Format | Estimated Volume Per User |
App/Soother Settings | Operational Data, Interaction Data | Binary | <30KB |
App Crash Logs Data | Technical/ Diagnostic Data | Text | <23MB |
The data collected through the use of the VTech products is processed primarily to ensure the proper functioning of the products and services, to provide the users with core functionalities, and to maintain a safe and reliable user experience. This includes enabling essential features, delivering necessary updates, and facilitating troubleshooting in case of technical issues. For the manufacturer, the data may also be used to monitor and improve product performance, to carry out safety and quality checks, and to comply with applicable legal and regulatory obligations. Data processing is strictly limited to these legitimate purposes. The data will not be used for profiling or tracking of children under any circumstances, nor will it be used for marketing or advertising activities without the user’s consent.
To the extent that VTech collects data that qualifies as personally identifiable information (“personal data”), we process this data in accordance with applicable data protection laws. For detailed information about the types of personal data collected, the purposes of processing, retention periods, and individuals’ rights, please refer to our Privacy Policy at https://www.vtechphones.eu/en-eu/legal/privacy-policy.
Some limited operational data may be stored on your device until it is overwritten by new information or removed when the device is restarted. Certain data may be stored on a remote server for the period necessary to provide the core functions of our connected products. A small amount of usage data (e.g., registered email address) that can identify you personally may be shared with VTech only when necessary to provide the specific services or functions that you have opted to use. This data is retained only for as long as needed to deliver those services. For further information, please view our Privacy Policy at https://www.vtechphones.eu/en-eu/legal/privacy-policy.
The user of the VTech product has the right to access all product- and service-related data collected by the device. You may authorize third parties to access this data, provided it is technically feasible and secure, and only upon your explicit request.
Users have the right to request the erasure of data generated through the use of our connected products and services, to the extent permitted by applicable law and provided that the data controller does not have a legitimate interest in retaining such data, such as for security purposes or for the establishment, exercise, or defense of legal claims. Data erasure requests can be submitted by contacting our Customer Service at Policy_standard@vtech.com. Upon verification of the request, the data will be permanently erased from our active systems using secure deletion methods.
If VTech processes data in a way that personally identifies you, you have the right to access and erase your data. For more information, please refer to our Privacy Policy at https://www.vtechphones.eu/en-eu/legal/privacy-policy.
If you authorize a third party to access your data, they may submit a request to VTech. Access will be granted only to the extent that VTech holds the data in an identifiable form. You retain control of these authorizations and may revoke them at any time by contacting our Customer Service at Policy_standard@vtech.com.
You may request your data in a structured, commonly used, and machine-readable format (e.g., JSON and CSV). You may transfer your data to a third party of your choice, provided they meet security and privacy requirements.
Questions or requests may be directed to our Customer Service at Policy_standard@vtech.com.
You also have the right to lodge a complaint with the competent authority designated under Article 37 of the Data Act, in the EU member state where you reside, work, or are established.
You may use VTech’s services for as long as you wish, unless your access is terminated by you or by VTech. This includes services that enable control of hardware features on your device. You may stop using VTech services at any time. To delete your VTech account, please contact our Customer Service at Policy_standard@vtech.com. Please note that deletion may be irreversible and may affect your access to other VTech or third-party services linked to your account.
Please contact our Customer Service at Policy_standard@vtech.com.