Pre-contractual information according to the Regulation (EU) 2023/2854
(“Data Act”) EU Data Act from Positec Tool Corporation

As a manufacturer of connected products, Positec Tool Corporation (“Positec”) is committed
to ensuring transparency about how these products generate data about their usage and
performance and how our customers can access or share this data with third parties in
accordance with the Regulation (EU) 2023/2854 (“Data Act”) for connected products

Some of the information contained in this notice applies to all product types. Other
information varies by product category. Positec periodically updates this Pre-Contractual
Information Notice under the EU Data Act to reflect the introduction of new products and
features. Users may want to bookmark or print this page for future reference.

For all connected products and related services referenced in this document, Positec
Germany GmbH acts as the data holder as defined under the EU Data Act.

Positec Germany GmbH
Schanzenstrasse 22
51063 Köln
Germany
Contact for EU Data Act Requests:
Email: [email protected]

Data generation

Positec offers a wide range of connected products and apps across various categories, each
designed to enhance the user experience. The type of data generated varies by product
type. The amount of data generated by connected products depends heavily on the device
type, usage patterns, and the granularity of data collection.

Connected products and associated services from Positec generate various data and
information during use. Below you will find information about the data available in the
product, data access, and your data rights.

You can access the data generated and potentially stored in Kress product as follows:

Kress Mission & Commercial Apps

Direct App Access (Real-Time): Users can view real-time status and historical work logs
through the Kress Mission RTKⁿ app or Kress Commercial app. This data is provided free of
charge.

Type, format and estimated volume of data generated by the machine

The following data may be generated during operation and use of the product. The actual
data generated varies depending on the specific use of the product.

Types of product data

  • Performance data: battery status, mowing duration, blade usage, error codes.
  • Environmental data: GPS position (if activated), terrain and slope detection,
    weather/obstacle sensors.
  • Usage data: start/stop times, mowing patterns, maintenance alerts.
  • Images: acquired from the camera (diagnostic images remain linked to the mower,
    product improvement images are fully anonymized)

The estimated volume of product data generated

  • The volume depends on usage frequency and time
  • Products generate data continuously and in real-time
  • Connected products can store data on-device and on a remote server

Storage location and storage duration

The data is stored in the product

  • Depending on the type, the data is either overwritten cyclically or stored
    permanently.
  • A factory reset of the product will delete the data

You can ask us to delete data we hold about you, by sending a request to
[email protected]. You can also factory reset your mower by pressing and
holding the power button on the machine for approximately 10 seconds. Release then
mower will restart, indicating the factory reset has been performed.

Type, format and estimated volume of data generated by our Apps

The following data may be generated during operation and use of Apps. The actual data
generated varies depending on the specific use of the product.

Types of App data

  • Identity & contact data
  • Technical data
  • Product & usage data
  • Diagnostics & logs
  • Anonymized/aggregated data
  • User settings/preferences

The estimated volume of data generated by our Apps

  • The volume depends on usage frequency and time
  • Products generate data continuously and in real-time
  • Apps can store data on-device and on a remote server

You can request the deletion of your data by contacting us at
[email protected].

Storage location and storage duration

The data is stored in the App and on a remote server
Depending on the type, the data is either overwritten cyclically or stored
permanently.
A factory reset of the product will delete the data.

Can the Data Be Shared?

  • You may share your data with third parties
  • To do this, you can authorize data access directly from your IoT device or by making a
    request to us.
  • We will provide the data with the same quality and detail as we use internally.
  • What Do We Use Data For?
  • To provide core functionality (mowing automation, safety features).
  • To maintain and improve product performance (software updates, diagnostics).
  • To provide customer support if issues occur.
  • We do not sell your personal data. Any anonymized, aggregated data may be used
    for research and product development.

Data Formats and Portability

  • Data is commonly used in machine-readable formats (CSV, JSON, XML).
    Retention & Deletion
  • Device performance data is kept for as long as the product is registered, unless you
    request deletion.

Your Rights

  • Right of access: You can see and download all data your lawnmower generates.
  • Right to share: You can authorize third parties to access your data.
  • Right to deletion: You can ask us to delete data we hold about you, subject to legal
    obligations.
  • Right to portability: You can move your data to another service provider.

Under the EU Data Act, you have the right to lodge a complaint if you believe your rights
regarding access, use, or sharing of data have been infringed.

If you have any questions or require further assistance regarding data access, please contact
Us at [email protected]

This document is provided in line with the EU Data Act (Regulation (EU) 2023/2854).

Last Updated: December 19, 2025

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