EU Data Addendum
EU Data Act Addendum to the Terms of Use
This Addendum supplements and forms part of the Terms of Use between SVP Worldwide ("we," "us," or the "Company") and you. It applies only to users who are resident in the European Union and who have purchased, rented, or leased a connected sewing machine (the "Machine") and, where applicable, use the associated Creativate application (the "App"). It is provided to satisfy the pre-contractual information duties under Articles 3(2) and 3(3) of Regulation (EU) 2023/2854 (the "EU Data Act"). Where this Addendum conflicts with the general Terms of Use, this Addendum controls for the users and subject matter described above.
1. Categories of Data the Machine and App Generate
The Machine and the App are capable of generating the categories of data set out below. Individual technical fields are grouped into these categories; the examples are illustrative and not exhaustive.
A. Data from the Machine (product data)
| # | Category | What it covers (examples) | Typical format |
|---|---|---|---|
| A1 | Machine identity and configuration | Model, serial number, brand, machine type and firmware version; machine settings and changes to them; needle, presser-foot, feed-dog and hoop configuration | Identifiers, version strings, coded values, timestamps |
| A2 | Usage & stitch data | Operating hours; lifetime, per-session and milestone stitch counts (including stitches since last service and since last needle change); sewing and embroidery sessions; bobbin winding; stitch/pattern selections and fabric parameters | Whole-number counters, durations, coded values |
| A3 | Performance, diagnostics, connectivity, maintenance and safety events | Motor, thermal, power and ambient sensor readings; self-diagnostics, calibration, maintenance and service events; reset/boot data; firmware-update status; error and fault codes; thread and needle breaks, stitch-quality warnings, jams, automatic stops, overload protection and unexpected shutdowns; Wi-Fi/Bluetooth connection status and signal; design-file transfers to and from the Machine | Numeric sensor readings with units, coded status/event values, timestamps, file metadata |
B. Data from the Creativate App (related-service data)
| # | Category | What it covers (examples) | Typical format |
|---|---|---|---|
| B1 | Account, registration and subscription | Sign-in and authentication method and outcome; Machine registration and pairing; subscription tier, billing period and changes (including cancellation reason and any feedback you provide) | Coded values, identifiers, yes/no flags, free text |
| B2 | App usage and content interaction | App sessions and navigation; feature and on-screen interactions; design and stitch selection and editing; favorites, searches, catalog and content interactions; tutorials, help and onboarding; project actions; content sharing; cloud sync; and App error events | Coded values, identifiers, counters, durations, free text (e.g., search terms) |
C. Common technical metadata
| # | Category | What it covers (examples) | Typical format |
|---|---|---|---|
| C1 | Event metadata & identifiers | Event identifiers, timestamps, software/schema versions, source system, device identifier, account and session identifiers, and approximate location (country, region, city, time zone) that accompany the data in categories A and B | Identifiers, timestamps, version strings, ISO country/region codes |
Some data in these categories may constitute personal data. Our processing of personal data is governed by our Privacy Policy and applicable data-protection law, in addition to this Addendum.
2. How the data is generated, stored and accessed
Volume and generation. The estimated volume of data varies with how much you use the Machine and App. The Machine generates certain data continuously and in real time during operation (for example, sensor and performance readings) and other data on the occurrence of an event (for example, error, maintenance or configuration events).
Storage. Data is stored on the Machine and/or on our (or our service providers') cloud servers. Intended retention period: We retain this data indefinitely, or until we no longer have a business purpose for retaining it, whichever occurs first. Where data constitutes personal information under the GDPR, the applicable retention period is set out in our Privacy Policy.
Access, retrieval and erasure. As the user, you can access and retrieve the readily available data generated by your use of the Machine and App, and request its erasure, free of charge, through accessing your CREATIVATE account online, found at www.creativate.com . Data is provided in a commonly used, machine-readable format where technically feasible. Applicable terms of use and quality-of-service conditions are set out in the Terms of Use.
3. Sharing your data with third parties
Our use. We use the data described above for providing and maintaining the Machine and App, to ensure useability of the Machine, for safety (such as diagnostic information), product improvement, and support. We do not make this data available to third parties for their own purposes, our sharing of the data described above is only to service providers in order to provide our services to you.
Sharing at your request. You may request that we make readily available product and related-service data available to a third party of your choice, and you may end that sharing, by contacting us. We will make such data available to the third party without undue delay, on the terms required by the EU Data Act.
Right to complain. You have the right to lodge a complaint regarding our compliance with Chapter II of the EU Data Act with the competent authority in your EU Member State.
Trade secrets. Certain data (for example, inferred or derived diagnostic values and internal reset/fault data) may contain our trade secrets; such data may be shared subject to proportionate measures to preserve confidentiality.
4. Data holder identity and contact
The data holder for the purposes of the EU Data Act is VSM Group Aktiebolag.
5. Term
This Addendum applies for the duration of your contract for the Machine and, where applicable, the App, and to the arrangements for terminating that contract as set out in the Terms of Use.