Graco Auto Lube App Data Protection Notice

I.         INTRODUCTION AND SCOPE

Graco Inc. (“Graco”), its affiliates and subsidiaries (together “we”, “our”, or “us”) is committed to protecting your privacy. This notice (“Notice”) describes the data processing activities in connection with the use of Auto Lube™, including the mobile app, web site, cloud software, and the cellular module. Auto Lube™ App has been designed to assist Graco GLC X users with use of their Graco automatic lubrication system (“Lubrication System”), including monitoring and controlling the Lubrication System and reporting of past usage. Auto Lube™ App can therefore be used by different user groups, including company administrators, company users, distributors, and repair centers. This Notice addresses all groups in their capacity as Auto Lube™ App users. It describes the categories of personal data we process, the purposes for which personal data is collected, the parties with whom we share it and the security measures we take to protect the data. It also informs users about their rights and choices with respect to their personal data, and how they can contact us to inquire about our data protection practices. We encourage our Auto Lube™ App users to read this Notice carefully. This Notice may change from time to time, for more information about notice amendments see Section XII below.

II.         DATA CONTROLLER

For the purpose of this Notice

Graco Inc.
Attn: Legal-Privacy
88-11^th Avenue Northeast
Minneapolis, MN 55413
USA

is responsible for the processing of your Personal Data as the data controller. You can contact us by emailing privacy@graco.com, calling either  +1 612 379 3654 (US) or +32 (0) 89 770 960 (EU) or mailing:

Graco Inc.
Attn: Legal-Privacy
88-11^th Avenue Northeast
Minneapolis, MN 55440-1441
USA

III.         PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (“Personal Data”).

When using our Auto Lube™ App there is currently no option to provide us with Personal Data relating to you.

• The Auto Lube App is only connected to us through your Graco device ID.
• The Auto Lube App does not provide for the creation of a user account.  There is no App registration.
• The Auto Lube App does not collect user account, contact, or personal information.
• The Auto Lube App does not collect the account or personal information from your smart device.

However, we do automatically collect certain operational information through your Auto Lube™ App usage.  More information about the categories of Personal Data and the ways in which we collect it are described below.

(1) Personal Data You Give to Us. At this time, we do not collect any Personal Data through the Auto Lube App, except to the extent you provide a device nickname that contains Personal Data.  The data collected is operational data related to usage information, such as system events, system configuration, metrics, your device’s nickname (named by you), and a Bluetooth ID. You do not create an Auto Lube App account or provide your personal information or contact information.

 (2) Personal Data We Automatically Collect. At this time, we do not automatically collect any Personal Data through the Auto Lube App, as described above.

(3) Personal Data from other sources. At this time, we do not obtain information from other sources.

IV.         HOW WE USE YOUR PERSONAL DATA

To the extent there is any information that is deemed Personal Data, we will only process your Personal Data for specific, explicit and legitimate purposes. We will not process your Personal Data for any further purposes than the ones the data was originally intended for, unless the new purpose is compatible with the original one. In the absence of compatibility, the processing of data for further purposes is subject to your prior explicit consent.

V.         HOW WE SHARE YOUR PERSONAL DATA

To the extent there is any information that is deemed Personal Data, and due to the international scope of our business, your Personal Data can be shared or accessed by Graco-affiliated entities within the company group. You can find more information on data transfers to affiliates in Section VI of Graco’s Global Privacy Notice at https://www.graco.com/us/en/privacy-policy.html.

Subject to applicable law and regulations, we share your Personal Data with:

• Public authorities, including law enforcement; and
• Service providers acting on our behalf for the purposes listed above in Section IV. We require these service providers to only process Personal Data in accordance with our instructions and only as long as necessary to perform the requested services or in compliance with applicable law (e.g., app administration providers).

VI.         INTERNATIONAL TRANSFERS OF PERSONAL DATA

See Section VI of Graco’s Global Privacy Notice at https://www.graco.com/us/en/privacy-policy.html.

VII.         DATA RETENTION

Retention periods vary depending on the categories of data concerned. As a general rule, we will not retain your Personal Data for longer than is allowed under the applicable data protection laws or for longer that is necessary in relation to the purposes for which it was originally collected or otherwise processed. Unless statutory retention periods apply, we will delete your Personal Data within a period of 2 years. System-related operational data, however, will be anonymized and retained beyond that period for statistical purposes.

In the absence of statutory retention periods, alternatively after completion of those periods, we will erase your Personal Data. Further, we will erase your Personal Data where one of the following applies: (i) when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; (ii) when you object to the processing and there are no overriding legitimate grounds for the processing; (iii) when your Personal Data has been unlawfully processed; and (iv) when it is necessary to comply with legal obligations.

VIII.         YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA

You have certain rights regarding the Personal Data we maintain about you and certain choices about what Personal Data we collect from you, how we use it, and how we communicate with you.

• The right to request access to and receive information about the Personal Data we maintain about you.
• The right to rectification or erasure of your Personal Data.
• The right to restriction of processing of your Personal Data.
• The right to data portability in order to transfer your Personal Data easily to another company.
• Where Personal Data processing is based on your consent, the right to withdraw your consent at any time. You can tell us not to send you any further marketing emails by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below.
• The right to lodge a complaint with a supervisory authority.
• The right to object to processing concerning your Personal Data.

You can submit a request to exercise these rights at any time by contacting our DPC at privacy@graco.com, calling either +1 612 379 3654 (US) or +32 (0) 89 770 860 (EU), or mailing:

Graco Inc.
Attn: Legal-Privacy
88-11^th Avenue Northeast
Minneapolis, MN 55413
USA

IX.         DATA SECURITY

The security of your Personal Data is important to Graco and we are committed to protection the data we collect. We maintain administrative, technical and physical safeguards designed to protect the Personal Data you provide or we process against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

X.         THIRD PARTY CONTENT

Our Auto Lube App may contain links to third party websites. The links are provided exclusively for your convenience. Please be aware that this Notice does not apply to those third party websites nor do we have control over the content of linked third party websites. We encourage you to read the data protection policies and terms and conditions of linked or referenced website you enter.

XI.         CHILDREN

Our Auto Lube App is not intended for children and we have no intention of collecting Personal Data from individuals under eighteen years of age. If a child has provided us with Personal Data, a parent or a guardian of that child may contact us to request to have such information deleted emailing privacy@graco.com, calling either +1 612 379 3654 (US) or +32 (0) 89 770 860 (EU), or mailing

Graco Inc.
Attn: Legal-Privacy
88-11^th Avenue Northeast
Minneapolis, MN 55413
USA

XII.         REVISIONS TO OUR DATA PROTECTION NOTICE

We reserve the right to amend this Notice from time to time consistent with applicable data protection laws and regulations. Any changes to this Notice will be posted on this page. If we make material changes to how we treat your Personal Data, the latest version will be posted to this webpage. The date this notice was last revised is identified at the top of the page.