Universal Robots A/S ("Universal Robots") and each of our related corporations, affiliates, subsidiaries, and associated companies take processing of Personal Data very seriously. Universal 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"). Universal Robots protects Personal Data and the privacy of individuals within all areas of its business in accordance with the terms of this Privacy Policy of Universal 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 Universal Robots collects and processes about individuals, including but not limited to visitors, customers, suppliers, other stakeholders and users of Universal Robots’ website and services.

2.      Data Controller

Universal Robots is the data controller (“Data Controller”) of the Personal Data covered by this Privacy Policy.

 

Contact details:

Universal Robots A/S

CVR-number: 29138060

Energivej 25, 5260 Odense S, Denmark

 

Telephone: +45 89 93 89 89

Website: https://www.universal-robots.com/

 

For any questions related to this Privacy Policy and processing of Personal Data, please contact the Universal Robots Data Protection Team.

 

Universal Robots has offices worldwide. Location and contact details of worldwide offices can be located on the Universal Robots’ website on the contact page. 

 

Universal Robots’ parent company is Teradyne, Inc., located at Riverpark Drive, North Reading, Massachusetts 01864, USA.

 

Universal Robots may share Personal Data with other companies and brands owned or controlled by Universal Robots A/S (“Affiliates”), including, but not limited to:

 

Universal Robots Mexico S.A. de C.V.

Universal Robots GmbH

Universal Robots (Spain) S.L.

Universal Robots (UK) Ltd

Universal Robots (Shanghai) Co. Ltd.

Universal Robots (India) Pte Ltd.

Universal Robots, Czech Republic Branch (odstepny zavod)

Universal Robots France Representative Office

Universal Robots, Italy Branch

Universal Robots A/S, Sweden Branch

Universal Robots A/S, Japanese Branch

Universal Robots A/S, Korea Branch

Universal Robots, Taiwan Branch

 

In the event Universal Robots 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 Universal Robots, Affiliates and Universal Robots’ 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

• Individual/company has given prior consent to processing of his/her/its Personal Data for one or more specific purposes. Note: Under some legislation Universal Robots 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 Universal Robots; and/or,
• Processing is necessary for the purposes of the legitimate interests pursued by Universal Robots or by a third party, if such interests are considered to override individual/company interests or fundamental rights. Such legitimate interests may include Universal Robots’ 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, Universal Robots 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 Universal Robots’ 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, Universal Robots 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 Universal Robots or for the purpose of the legitimate interests pursued by Universal Robots, 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 Universal Robots 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 Universal Robots with the information so that Universal Robots can maintain the customer relationship, fulfil the contract and invoice for our services, etc. If the customer does not wish to provide Universal Robots with the information Universal Robots needs to comply with contractual and/or statutory obligations, the consequence may be that Universal Robots is unable to establish or continue the business relationship.

 

Individuals are not obliged to provide Universal Robots with Personal Data in all cases, for example, for use in Universal Robots marketing and newsletter distribution. However, in such instances, the individuals will not be able to receive marketing materials and newsletters from Universal Robots.

4.       The types of and purpose for the collection of personal data

Universal Robots collects and processes Personal Data, including Sensitive Personal Data (if any) only for specified, explicit, and legitimate purposes which are relevant to Universal Robots’ business. Internal Universal Robots departments and Universal Robots employees who have access to Personal Data must follow applicable legal requirements; this Privacy Policy; and internal guidelines.

 

Employment. Universal Robots collects and processes Personal Data, including Sensitive Personal Data (if any) of applicants and candidates for employment purposes and in accordance with legal requirements.

 

Visitors. Universal Robots 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 Universal Robots premises.  

 

Universal Robots’ website users. Universal Robots 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 UR+ users, any App users, and Universal Robots Academy users, managing contacts and sending messages, remarketing and behavioral targeting.

 

For operation and maintenance purposes, Universal Robots 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 Universal Robots´ website.  

 

The Universal Robots’ website does not support “Do Not Track” requests. To determine whether any of the Universal Robots’ 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 Universal Robots. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Universal Robots Data Protection Team.

 

Data of Minors. Universal Robots’ 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 Universal Robots has Personal Data that pertains to a child under the age of 16, Universal Robots 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.

 

Universal Robots 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. Universal Robots may contract with third-party service providers to assist in better understanding Universal Robots’ website visitors. These service providers are not permitted to use the information collected on Universal Robots’ behalf except to help conduct and improve Universal Robots’ business.

 

More details related to cookie notice please find in the Cookie Policy.

 

Marketing. Universal Robots 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 Universal Robots’ 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. Universal Robots 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.

 

Universal Robots 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 marketing purposes, Universal Robots may share Personal Data (including name and contact details) with third parties (e.g., distributors, business partners, and corporate affiliates). A list of distributors can be found on the Universal Robots’ webpage here. The list of other third parties can be provided upon request.

 

For any further questions related to marketing information, please contact the marketing department at marketing@universal-robots.com

 

Contracts. In connection with its sales and purchase transactions, Universal Robots 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. Universal Robots 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. Universal Robots Academy (“UR Academy”) collects information from individuals/companies when they register as users on the training website at: https://academy.universal-robots.com/, or when they use a company or other entity user profile on the website, and UR Academy gathers data when individuals participate on the UR Academy platform by reading, writing, and evaluating the content shared here as well as when purchasing in-class training. Universal Robots 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 Universal Robots’ websites, services and products, to contact users as part of Universal Robots’ 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, Universal Robots may retain Personal Data necessary for its legitimate interest to ensure that Universal Robots can properly bring or defend legal claims in court or during the stages leading to possible legal action. Universal Robots may need to share this information with third parties such as insurance and/or legal advisers and Universal Robots may also be required to reveal Personal Data upon request of public authorities.

 

Whistleblowing system. Universal Robots respects confidentiality of whistleblowers and has several channels in place for such reporting, including electronic/digital systems (https://www.whistleblowerservices.com/teradyne). Universal Robots 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 Universal Robots’ operating offices and in any other places where the parties involved in the processing are located. Universal Robots 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 Universal Robots transfers Personal Data from the EU/EEA to third countries or international organizations. When transferring Personal Data to third countries or international organizations, Universal Robots 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).

 

Universal Robots 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, Universal Robots 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 Universal Robots 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 Universal Robots 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, Universal Robots 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 Universal Robots China Privacy Policy.

6.       Retention period

Personal data collected by Universal Robots shall be processed and stored for as long as required by the purpose for which the personal data has been collected.  Universal Robots may be allowed to retain personal data for a longer period if Universal Robots has obtained valid consent to the processing activity as long as such consent is not withdrawn. Furthermore, Universal Robots may be obliged to retain the personal data for a longer period, whenever required to do so for the performance of a legal obligation or to establish, exercise or defend a legal claim.

 

Once the retention period expires, 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 retention period.

7.       Individuals’ Rights

Where legally required, Universal Robots 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 Universal Robots, 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, Universal Robots 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 Universal Robots.
• 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, Universal Robots 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, Universal Robots 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:

 

Universal Robots A/S

Energivej 25

5260 Odense S

Denmark

Telephone: +45 89 93 89 89 (please request to speak with the Legal Department)

E-mail: dataprotection@universal-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

Universal Robots 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.

 

Universal Robots 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@universal-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 Universal Robots China Privacy Policy.

 

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Privacy Notice for California Residents

 

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in Universal Robots’ Privacy Policy and applies to all visitors, users, and others who reside in the State of California. Universal Robots adopts this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

 

Collection of Personal Information. Universal Robots collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information“). In particular, Universal Robots has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

 

Categories	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers	YES
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	NA
D. Commercial information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

 

Personal Information does not include information that is:

• Lawfully made available from government records.
• Deidentified or aggregate information.
• Otherwise excluded from the scope of the CCPA.

 

The chart above provides the categories of Personal Information (as defined by the CCPA) which Universal Robots has collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this Privacy Notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

 

Use of Personal Information. Universal Robots may use or disclose the Personal Information that Universal Robots collects for one or more of the following business purposes:

 

• To fulfil or meet the reason the individual provided the information. For example, if Data Subject’s shares his/her/its name and contact information to ask a question about our products or services, Universal Robots will use that Personal Information to respond to the Data Subject’s inquiry. If an individual provides Personal Information to purchase a product or service, Universal Robots will use that information to process the payment and facilitate delivery. Universal Robots may also save an individual’s information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop products, and services.
• To create, maintain, customize, and secure an account with Universal Robots.
• To provide individuals with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to the recipient.
• To provide an individual with support and to respond to the inquiries.
• To process requests, purchases, transactions, and payments and prevent transactional fraud.
• To deliver content and product and service offerings relevant to an individual’s interests, including targeted offers and ads through Universal Robots website, third-party sites, and via email or text message (with consent, where required by law).
• For auditing related to a current and/or concurrent transaction with a Data Subject.
• To help maintain the safety, security, quality, and integrity of Universal Robots’ products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
• For testing, research, analysis, and product development and demonstration, including to develop and improve Universal Robots’ products, and services.
• To respond to law enforcement requests and as otherwise required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Universal Robots assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Universal Robots about Universal Robots’ website users is among the assets transferred.
• As described, Universal Robots is collecting the Personal Information, as articulated in this Privacy Policy, Privacy Notice or as otherwise set forth in the CCPA.

 

Universal Robots will not collect additional categories of Personal Information or use the Personal Information that Universal Robots collects for materially different, unrelated, or incompatible purposes without providing notice.

 

Sharing the Personal Information. Universal Robots may disclose Personal Information to a third party for a business purpose. When Universal Robots discloses Personal Information for a business purpose, Universal Robots enters into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and to not use it for any purpose except performing the contract.

 

Universal Robots may share Personal Information with the following categories of third parties:

• Related corporations, affiliates, subsidiaries, associated companies, and parent company.
• Service providers.
• Third parties to whom the Data Subject has authorized Universal Robots to disclose his/her/its Persona Information in connection with a product, service or offering.

 

Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, Universal Robots has disclosed the following categories of Personal Information for a business purpose:

 

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G. Geolocation data

Category I: Professional or employment-related information.

 

California Privacy Rights. According to the CCPA, California residents may make certain requests to Universal Robots regarding Personal Information, specifically:

 

• The Right to Access/Know: the specific pieces or categories of the Personal Information, which also maybe disclosed or sold (if any) to the third parties for the business purposes, and categories of such third parties to whom this information was disclosed or sold; and the business or commercial purposes for collecting or selling the Personal Information.  
• The Right to Request Deletion: the right to request the deletion of Personal Information, subject to certain exceptions.
• The Right to Correction: the right to request that any inaccuracies in Personal Information be corrected, taking into account the nature of the Personal Information and the purposes of the processing of Personal Information.
• The Right to Opt-Out of Sales or Sharing of Personal Information: the right to direct Universal Robots not to “sell” Personal Information to third parties for monetary or other valuable consideration, or “share” the Personal Information to third parties for cross-context behavioral advertising purposes.
• Right to Limit Use and Disclosure of Sensitive Personal Information: the right to direct Universal Robots to limit the use of the sensitive personal information to certain purposes, including to perform the services or provide the goods or services reasonably.
• The Right to Non-Discrimination: the right not to receive discriminatory treatment for exercising any of the rights described above, with limits to process Personal Information, such as in the case of a deletion request.
• “Shine the Light”: California residents that have an established business relationship with Universal Robots have the right to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). Universal Robots does not share Personal Information with third parties for Universal Robots’ own direct marketing purposes.

 

Universal Robots may only be able to process the request to the extent it is able to identify individuals in Universal Robots systems. The request should be submitted as mentioned in the section 10 of this Privacy Policy.

 

Right to Opt-Out of Personal Information Sales or Sharing. Unless a Data Subject has exercised his/her/its right to opt-out of Personal Information sales, Universal Robots may sell Personal Information to third parties for monetary or other valuable consideration. The third parties may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. These third parties may include business partners, third party advertising networks, social media companies and other third parties.

 

Do Not Sell or Share Personal Information. In certain circumstances, an individual may be permitted to use an authorized agent to submit requests on their behalf where Universal Robots can verify the authorized agent’s authority to act on their behalf. In order to verify the authorized agent’s authority, Universal Robots generally requires evidence of either (i) a valid power of attorney or (ii) a signed letter containing the name and contact information of the Data Subject of the request, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and location/residency, Universal Robots may still need to separately reach out to the Data Subject to verify the Data Subject’s identity in connection with the request and to confirm that the authorized agent has permission to act on the Data Subject’s behalf.

 

Appealing Privacy Rights Decisions. Depending on the Data Subject’s location or jurisdiction of residency, the Data Subject may be able to appeal a decision Universal Robots has made in connection with his/her/its privacy rights request. All appeal requests should be submitted in accordance with Section 10 of this Privacy Policy.

 

Non-Discrimination. Universal Robots will not discriminate against you for exercising any of individual’s CCPA rights. Unless permitted by the CCPA, Universal Robots will not:

• Deny goods or services.
• Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide a different level or quality of goods or services.
• Suggest that individual may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, Universal Robots may offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive that Universal Robots offers will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

Contact Information. In case of questions and/or suspected violations of this Privacy Notice, please contact the Data Protection Team at: dataprotection@universal-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.

 

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Privacy Notice for Residents of Colorado, Connecticut, Utah, and Virginia

 

In accordance with applicable privacy law, and depending upon the jurisdiction in which the Data Subject resides, the Data Subject may have some or all of the following rights with respect to his/her/its Personal Information:

 

• Right of Access: The Data Subject may have the right to obtain:

• confirmation of whether, and where Universal Robots processes Data Subject’s Personal Information;
• information about the categories of Personal Information Universal Robots is processing, the purposes for which Universal Robots processes the Personal Information and information as to how Universal Robots determines applicable retention periods;
• information about the categories of recipients with whom Universal Robots may share the Personal Information; and
• a copy of the Personal Information Universal Robots holds about the Data Subject.

 

• Right of Portability: The Data Subject may have the right, in certain circumstances, to receive a copy of the Personal Information that Data Subject has provided to Universal Robots in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of the Personal Information to another person.

 

• Right to Rectification or Correction: The Data Subject may have the right to obtain rectification or correction of any inaccurate or incomplete Personal Information which Universal Robots holds about the Data Subject.

 

• Right to Deletion or Erasure: The Data Subject may have the right, in some circumstances, to require Universal Robots to delete erase his/her/its Personal Information.

 

• Right to Restriction: The Data Subject may have the right, in some circumstances, to require Universal Robots to limit the purposes for which Universal Robots processes the Data Subject Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by the Data Subject.

 

• Right to Opt-Out: The Data Subject may have the right to opt-out of certain processing activities. For example, the Data Subject may have the right to opt-out of the use of his/her/its Personal Information for targeted advertising purposes, or to “sell” or “share” his/her/its Personal Information with third parties in certain contexts.

 

• Right to Withdraw Consent: If the Data Subject has provided consent for the processing of his/her/its Personal information, the Data Subject may have the right to withdraw this consent. If the Data Subject withdraws his/her/its consent, this will not affect the lawfulness of Universal Robots’ use of the Personal Information before withdrawal.

 

• Right to Appeal: In the event that Universal Robots declines to take action on a request exercising the rights set forth above, the Data Subject has the right to appeal such decision.

 

The Data Subject does not need to create an account with Universal Robots in order to exercise its privacy rights. However, before processing the Data Subject’s request, Universal Robots will need to verify Data Subject’s identity and confirm Data Subject’s state if residency. In order to verify Data Subject’s identity, Universal Robots will generally either require the successful authentication of Data Subject’s account, or the matching of sufficient information the Data Subject provides to Universal Robots which maintains in the systems. This process may require Universal Robots to request additional Personal Information from Data Subject, including, but not limited to, email address, and/or date of last transaction with Universal Robots.

 

Universal Robots will only use Personal Information provided in a privacy rights request to review and comply with the request. If the Data Subjects choose not to provide this information, Universal Robots may only be able to process the request to the extent Universal Robots is able to identify the Data Subject in the system(s). Universal Robots may not process the request if Universal Robots, in good faith, believes that the request is fraudulent. In such instances, Universal Robots will send a notice to the requestor explaining the decision. If Universal Robots is unable to comply with all or a portion of a Data Subject’s request, Universal Robots will explain the reasons for declining to comply with the request.

 

Opt-Out Rights in Relation to Cookies and Other Tracking Technologies. As is common practice, Universal Robots permits third party advertising networks, social media companies and other third-party businesses to collect and disclose the Personal Information (including preferences, geolocation, commercial information and internet, network and device information) directly from Data Subject’s browser or device through cookies or tracking technologies when the Data Subject visits or interacts with the websites; uses Universal Robots apps; or otherwise engages with Universal Robots. These third parties use this information for the purposes of providing ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting. There third parties may sell that information to other businesses for advertising and other purposes. 

 

To opt out of the sharing of Personal Information with third parties for cross-context behavioral advertising purposes, the Data Subject may submit a request by clicking “Change your consent/Withdraw Your Consent” on the Cookie Policy.

 

Contact Information. In case of questions and/or suspected violations of this Privacy Notice, please contact the Data Protection Team at: dataprotection@universal-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.