Rules on Fair Access to and Use of Data in the European Union
These Rules are provided in accordance with Regulation (EU) 2023/2854 (the “Data Act”) and apply exclusively to customers and partners based in the European Union.
1. Definitions
The following terms are used in these Rules with the meanings given to them in the Data Act:
· ‘connected product’ means an item that obtains, generates or collects data concerning its use or environment and that is able to communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the user;
· ‘customer’ means a natural or legal person that has entered into a contractual relationship with a provider of data processing services with the objective of using one or more data processing services
· ‘data’ means any digital representation of acts, facts or information and any compilation of such acts, facts or information, including in the form of sound, visual or audio-visual recording;
· ‘data holder’ means a natural or legal person that has the right or obligation, in accordance with the Data Act, applicable Union law or national legislation adopted in accordance with Union law, to use and make available data, including, where contractually agreed, product data or related service data which it has retrieved or generated during the provision of a related service;
· ‘data recipient’ means a natural or legal person, acting for purposes which are related to that person’s trade, business, craft or profession, other than the user of a connected product or related service, to whom the data holder makes data available, including a third party following a request by the user to the data holder or in accordance with a legal obligation under Union law or national legislation adopted in accordance with Union law;
· ’data subject’ identified or identifiable natural person;
· ‘metadata’ means a structured description of the contents or the use of data facilitating the discovery or use of that data;
· ‘product data’ means data generated by the use of a connected product that the manufacturer designed to be retrievable, via an electronic communications service, physical connection or on-device access, by a user, data holder or a third party, including, where relevant, the manufacturer;
· ‘related service’ means a digital service, other than an electronic communications service, including software, which is connected with the product at the time of the purchase, rent or
lease in such a way that its absence would prevent the connected product from performing one or more of its functions, or which is subsequently connected to the product by the manufacturer or a third party to add to, update or adapt the functions of the connected product;
· ‘user’ means a natural or legal person that owns a connected product or to whom temporary rights to use that connected product have been contractually transferred, or that receives related services;
· Other applicable definitions shall have the same meaning as set out in the Data Act.
2. Connected Products (Article 3.2 Data Act)
a. Type, format, and estimated volume of product data During the operation and use of ProGlove devices, the following data may be generated and transmitted:
· Operational Data: Barcode scan data, usage timestamps (~0.5 KB per event).
· Metadata: Device model, firmware version, IP address, battery status, operating system, connectivity information (~0.5 KB per event).
· IMU Data: Inertial data from motion sensors (optional, disabled by default; ~10–100 KB/hour, configurable).
· Error Messages: Error logs (~0.5 KB per event).
b. Continuous and real-time generation ProGlove devices are capable of generating and transmitting data in real time during use.
c. Storage capability and retention Device-generated data can be stored either on the device or on remote servers. The retention period is 30 days.
d. User access and retrieval Users can access and retrieve their data via Insight Mobile (Android).
3. Related Services (Article 3.3 Data Act)
a. Nature, volume, and frequency of data obtained When using related services, the following data may be generated and obtained:
· Connectivity Events: Device connection/disconnection.
· Configuration Events: Device or gateway settings, site-specific configurations.
· Display Events: Screen change events when using Mark Display or MAI scanner.
The amount of data varies depending on use. Data is collected in real time and continuously.
b. Nature and volume of related service data generated The amount of data varies depending on the data point and the use of the service, with data volumes per data point ranging from 0.5 KB/h to anything higher dependant on usage levels.
c. Use and sharing of data Data holder does not use this data for purposes other than providing the contracted services and does not share it with third parties, except where expressly agreed with the customer.
d. Identity of the data holder Workaround GmbH Bavaria Towers George-Brauchle-Ring 23 80992 Munich, Germany
e. Contact Email: support@proglove.de
f. Requests for third-party data sharing Customers may request that their data be shared with third parties by contacting support@proglove.de.
g. Complaints Customers may lodge complaints regarding infringements of this Chapter with the competent authority designated under Article 37 of the Data Act.
h. Trade secrets The data generated by ProGlove connected products and related services does not contain trade secrets.
i. Duration and termination The arrangements set out in these Rules remain in force for the duration of the customer’s contract with Workaround GmbH. Termination rights follow the applicable contract terms and statutory provisions.
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4. The rights and obligations of users and data holders with regard to access, use and making available product data and related service data
a. Where data cannot be directly accessed by the user from the connected product or related service, data holders shall make readily available data, as well as the relevant metadata necessary to interpret and use those data, accessible to the user without undue delay, of the same quality as is available to the data holder, easily, securely, free of charge, in a comprehensive, structured, commonly used and machine-readable format and, where relevant and technically feasible, continuously and in real-time. This shall be done on the basis of a simple request through electronic means where technically feasible.
b. The user shall not use the data obtained pursuant to a request referred to in paragraph 1 to develop a connected product that competes with the connected product from which the data
originate, nor share the data with a third party with that intent and shall not use such data to derive insights about the economic situation, assets and production methods of the manufacturer or, where applicable the data holder.
c. The user shall not use coercive means or abuse gaps in the technical infrastructure of a data holder which is designed to protect the data in order to obtain access to data.
d. Where the user is not the data subject whose personal data is requested, any personal data generated by the use of a connected product or related service shall be made available by the data holder to the user only where there is a valid legal basis for processing under Article 6 of Regulation (EU) 2016/679 and, where relevant, the conditions of Article 9 of that Regulation and of Article 5(3) of Directive 2002/58/EC are fulfilled.
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5. Access to Data
In the European Union, data access required under the Data Act is provided free of charge. Users may access, retrieve or, where relevant, erase the data, through Insight Mobile (Android). Use of Insight Mobile (Android) is stipulated in ProGlove End-user License Agreement.
V.1
12 September 2025