Data Access and Sharing Notice

A. Introduction

This statement informs you about your rights and options regarding access to and sharing of data generated through the use of our connected products and services. You will learn which data is collected, how you can request or share it, and which safeguards and procedures apply. This way, you know exactly where you stand and how your data is protected under the Data Regulation.

This Data Access and Sharing Notice (“Notice”) is provided by Daikin Europe N.V. (“We”, “Us”, or “Our” / “DENV-G”) in compliance with Regulation (EU) 2023/2854 (the “EU Data Act”) in its quality of data holder (“Data Holder”).

B. Purpose

In accordance with Article 3(2) of the EU Data Act, this Notice informs you (“You”, “Your” or “User”), prior to entering into any contract with Us or using our Connected Products and Related Services, about:

• The types of data generated by Your use of Our Connected Products and Related Services;
• How You can access, use and share these data, including with third parties of Your choice;
• The procedures for requesting data access or sharing;
• Any limitations or exclusions that may apply (see also the sections “Limitations and Safeguards” and “Trade Secrets and Intellectual Property”).

For information on how We process personal data unrelated to product use, please refer to Our Data Protection Policy.

C. Scope

This Notice applies to all Users—both business (B2B) and consumer (B2C)—who use Our Connected Products and Related Services.

It covers data generated through the use of our Connected Products and Related Services, including, but not limited to (“Data”):

• Connected Products:

These are physical items that obtain, generate or collects Data about its use, performance or environment and is capable of communicating these Data via an electronic communications service (such as Wi-Fi, Bluetooth, LAN, or mobile networks), a physical connection or on-device access.

Examples include air-conditioning units, heating systems, ventilation equipment, refrigeration units and smart sensors.

• Related Services:

These are all digital services, including software, that are incorporated in or interconnect with a connected product and are necessary for the product to perform its functions, or that enable the user to access, collect or use Data generated by the connected product. 

D. Types of data 

The following categories of Data may be generated and collected through the use of Our Connected Products and Related Services:

• Status Data – e.g. configuration settings, firmware version, maintenance logs, consumption metrics
• Sensor or Measured Data – e.g. temperature, humidity, airflow, pressure
• Usage Data – e.g. user preferences, interaction patterns, feature engagement
• Operational Data – e.g. operating modes, schedules, runtime behaviour
• Location Data – e.g. device geolocation or installation site
• Diagnostic Data – e.g. error codes, system warnings, performance anomalies
• Telemetry Data – e.g. real-time performance metrics, device uptime, battery levels, firmware update status.
• Automation Data – e.g. insights into automated system behaviour, including thresholds, triggers and control logic.
• Predictive Maintenance Indicators – e.g. vibration patterns, compressor starts, discharge pressure and other early failure signals.
• User Feedback Data – e.g. voluntary feedback submitted via apps or platforms, used to improve product functionality.
• Metadata – e.g. data about data—such as timestamps, data source identifiers and transmission logs.
• Security and Access Logs – e.g. authentication attempts, access control records and audit trails.
• Warranty data
• Service packages data – e.g. activated packages for remote monitoring.
• Developer Portal - e.g. application credentials, rate limits.

E. Your Rights Under the EU Data Act

F. Data Access – rights and procedures 

1) Who?

o   You (the Data User):

As the user, owner or lessee of a Connected Product (or Related Services), You have the right to:

• Access all Data generated by Your use, free of charge.
• Request Your Data in a structured, commonly used, machine-readable format (e.g., JSON, XML, CSV).

o   Authorized Third Parties:

You may authorize third parties (such as service providers, analytics companies, or insurers) to access Data generated by Your use of our Connected Products and Related Services. Access is only granted with your explicit consent and is limited to the data categories You specify. Third parties must enter into a data use agreement and are prohibited from using Your Data to develop competing products or services. You will be informed when Your Data is shared with a third party, and you may withdraw your consent for third-party access at any time by notifying us.

o   DENV-G (Data Holder):

We may access and use Data for the following purposes:

• Product functionality and support (e.g., diagnostics, software updates)
• Service optimization (e.g., improving efficiency and safety)
• Predictive maintenance (e.g., alert generation, failure prevention)
• Aggregated analytics (e.g., usage trend insights, non-personal data)
• Business administration and customer management
• Product distribution and supplier administration
• Direct marketing (where permitted)
• Improving the quality of products and services
• Bookkeeping and accounting
• Complaints and legal disputes
• Prevention of fraud or crime
• Corporate affairs and administration

o        Public Sector Bodies:

Certain public sector bodies or institutions may request access for crisis response, public safety, environmental protection or law enforcement purposes (under strict legal requirements). We will respond to valid, proportionate requests in line with Article 21 of the EU Data Act.

2) How to request access

You can request access by sending an email to da@daikineurope.com or by completing Our Data Request Form .

Please specify your Connected Product and the type of Data requested. Indicate if the Data should be provided to a third party, or if you are a third party acting on a User’s behalf. We may request proof of identity and permitted use.

Once your request is verified, we will prepare the Data and confirm the contractual terms. You will receive the Data within 30 calendar days in a structured, commonly used format (e.g., JSON, XML, CSV), along with download instructions.

3) Costs, format and frequency

Access to Data for You as the User of the Connected Product(s) is free of charge.

If You request that Your Data be shared with a third-party data recipient, DENV-G may request reasonable compensation from the data recipient for providing access or sharing, as permitted under Article 9 of the EU Data Act. The level of compensation will reflect the cost and value of data provision. This does not affect Your right to receive data free of charge under the GDPR’s data portability rules.

Data will be provided in a structured, commonly used, machine-readable format (e.g., JSON, XML, CSV).

The volume and frequency of Data provision will depend on the Connected Product and usage scenario. Data may be provided as a one-time download or on a periodic basis, with volumes potentially reaching up to 200 MB/day.

4) Limitations and safeguards

In certain exceptional cases, We reserve the right to restrict or prohibit the access, use or further sharing of the Data generated by You, to ensure security requirements in accordance with EU or national law.

No insights about Your economic situation or assets will be derived from the use of Data. Data will not be used in any way that is significantly detrimental to Your legitimate interests.

Appropriate organisational and technical measures are implemented to protect generated Data, particularly against unlawful and unauthorised third-party access.

G. Sharing of Non-Personal Data

Data generated by the use of Connected Products and Related Services may be shared by DENV-G with third parties, for commercial and non-commercial purposes, such as research institutions (for research related to connected products) or app developers (for maintenance, updates, analytics and improvements). When DENV-G shares Data, adequate protection measures are applied to ensure confidentiality and compliance with applicable laws.

Upon Your request, Data can be made available without undue delay to a third party of your choice, in accordance with legal requirements under EU or national law. Data will be provided in the same quality as available to DENV-G.

Data recipients may be required to implement adequate protection measures to preserve confidentiality. If adequate protection cannot be ensured, sharing may be withheld, suspended or refused.

For general safeguards and limitations, see the section “Limitations and Safeguards”.

For limitations related to trade secrets and intellectual property, please refer to the section “Trade Secrets and Intellectual Property” below.

You may withdraw Your request to share Data with a third party at any time by providing written notice to da@daikineurope.com. Upon withdrawal, DENV-G will cease providing access to the relevant Data to the designated third party without undue delay. You may request a copy of Your Data within 30 days after access is withdrawn.

If the data recipient acts in a professional capacity, a separate agreement based on fair, reasonable, and non-discriminatory terms in compliance with Chapter III and IV of the EU Data Act will be required before sharing.

The right to share Data with third parties does not apply to organisations designated by the European Commission as gatekeepers under the Digital Market Act (Regulation (EU) 2022/1925). 

H. Data Storage and Retention 

Data generated by Your use of Our Connected Products and Related Services is stored on secure servers within the European Economic Area (EEA) and retained for a maximum of two years, unless a longer retention period is required by applicable law, regulatory obligations or for the establishment, exercise or defence of legal claims. 

I. Trade Secrets and Intellectual Property

Certain Data may be protected as trade secrets under Directive (EU) 2016/943 or by intellectual property rights. In accordance with the EU Data Act, We will only withhold or restrict access to such data if and to the extent that disclosure would genuinely compromise these rights. Where possible, we will take reasonable measures (such as confidentiality agreements) to enable Data sharing while safeguarding trade secrets and IP. If access is restricted for these reasons, We will inform You and, where feasible, provide partial access or summaries of the Data.

J. Changes to This Notice

We may update this Notice to reflect regulatory changes or improvements to our data practices. All updates will be published on Our website.

K. Your right to lodge complaints

For disputes related to accessing or sharing of generated Data, You have the right to lodge a complaint with the national competent authority designated subject to article 37 EU Data Act, or to submit their dispute to one of the certified dispute settlement bodies.

Data Holder and Contact Information:

Daikin Europe N.V.

Zandvoordestraat 300

8400 Oostende

Contact: da@daikineurope.com