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Data processing of mobile
cleaning robots

The protection of your personal data is very important to us. By publishing the following information, we comply with our obligation to provide information pursuant to Article 13 of the GDPR (General Data Protection Regulation).

+1. Description of the processing activity

Development and improvement of navigation algorithms for self-propelled cleaning machines.  

Development of a face recognition algorithm for automatic pixelation of persons in the software of self-propelled cleaning machines.

+2. Identity of the responsible body and contact details of the data controller responsible for the processing

Hako GmbH
(Mr) Dr.-Ing. Nils Rottmann
Hamburger Straße 209-239
23843 Bad Oldesloe
Germany

+3. Contact details of the data protection officer

Astrid Bartel, datenschutz@hako.com

+4. Purpose of the processing

The purpose of the development and improvement of navigation algorithms is to create/optimise the software for mobile path planning and control. These algorithms allow autonomous navigation and control of the cleaning machines.

The purpose of the development of the face recognition algorithm is the teaching-in of the software and minimising the software’s error rate. The algorithm is used in the saleable machines to automatically pixelate the faces of people captured by the machine’s control cameras (anonymisation).  

+5. Legal bases of the processing

Art. 6 para. 1 f) GDPR (economic interest)

The recording of the camera data is necessary to operate the self-propelled cleaning machine autonomously. The data is also used to further optimise the navigation software (debugging).

The recording of the data subjects is necessary in order to develop pixelation software for the commissioning of the machines. The legitimate interests of the data subject worthy of protection are not outweighed by the fact that no identification of the persons is made, the recording is made during a defined (limited) period of time, no meta data of the images is collected, the recordings are only used for this specific purpose and are deleted upon completion of the software development.

+6. Categories of personal data

Image data, video recordings (no sound recordings, no collection of meta data)

+7. Recipients or categories of recipients of the personal data

Processors with employment contract

+8. Transfer of personal data to a third country

A third country transfer does not take place and is not planned.  

+9. Automated decision-making

Data is not collected and evaluated to create personality, behaviour, movement profile or similar, i.e. no profiling takes place. Automated decision-making is not used.

+10. Duration of the storage of personal data

The data is deleted immediately after the algorithms have been developed.

+11. Right of withdrawal in case of consent

The processing does not take place on the legal basis of consent, a right of withdrawal according to Art. 7 DSGVO is therefore not given.  

+12. Rights of data subjects

Data subjects have the right

  • to receive information about the data stored,
  • to withdraw consent (if given) or, under certain conditions, to object to the processing of their data,
  • to have incorrect data corrected,
  • that data which is no longer required is deleted,
  • under certain conditions, to restrict the processing of their data; and
  • under certain conditions, to receive their data in a machine-readable format (transferability)
     

To exercise their rights, data subjects should contact the data controller or the data protection officer.

If data subjects are of the opinion that the processing of their data violates data protection law or that their data protection rights have been violated in any other way, they can complain to the supervisory authority.

In Schleswig-Holstein: State Commissioner for Data Protection (Landesbeauftragte für Datenschutz), Holstenstraße 98, 24103 Kiel, www.datenschutzzentrum.de

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