GT Power Generator App Privacy Policy

1. About this policy

This policy explains how Euroquip Limited (NZBN 9429000093798, company number 2026556) (“GT Power”, “we”, “us”, “our”) handles personal information in connection with the GT Power generator app (the “app”).

GT POWER is a registered trade mark used by Euroquip Limited. Euroquip Limited operates the app and is the agency responsible under the Privacy Act 2020 for personal information collected through it. Euroquip is a New Zealand company that has supplied power and industrial equipment since 1974.

We are bound by the Privacy Act 2020 and the 13 information privacy principles set out in that Act. Where this policy and the Privacy Act 2020 differ, the Act prevails.

This policy applies to the app only.

2. What the app does

The app pairs with a compatible GT Power generator over Bluetooth Low Energy and displays operating information from that generator on your phone or tablet. Examples include fuel level, output load, runtime hours, battery voltage and fault codes.

Operating data from your generator is also sent to our servers so that we can support the machine, diagnose faults, and improve our products.

You do not need to create an account to use the app.

3. Summary of what we collect

We do not sell personal information. We do not use the app for advertising or advertising measurement.

4. Information we collect

4.1 Information from your generator

When you pair the app with a GT Power generator, the app receives operating data from that machine and transmits it to our servers. This may include the model and serial number, engine runtime hours, fuel level, output voltage and load, battery voltage, service intervals and diagnostic or fault codes, together with the date and time of each reading.

This data is stored in our backend, which is provided by Convex, Inc. and hosted on infrastructure located in the United States.

On its own this is information about a machine rather than about a person. It becomes personal information under the Privacy Act 2020 when it is linked to an identifiable individual, for example when you give us the serial number in a warranty claim or support enquiry. We treat generator data as personal information wherever that link exists or could reasonably be made.

4.2 Bluetooth information

The app needs Bluetooth access to find and connect to your generator. It uses Bluetooth to identify nearby GT Power machines and to maintain the connection while the app is open. The app does not scan for or connect to your generator while running in the background.

Pairing information, including the Bluetooth identifier of your generator, is stored on your device so the app can reconnect automatically.

A note about location permission on Android. On Android versions before 12, the operating system requires apps to hold location permission in order to scan for Bluetooth devices at all. This is an Android requirement, not a GT Power one. If your device asks for location permission, that permission is used solely to allow Bluetooth scanning. The app does not request, collect, store or transmit your location. On Android 12 and above we declare the Bluetooth scan permission with the “never for location” flag.

On iOS the app requests Bluetooth permission only.

4.3 Device and app information

The app records basic technical information such as your device model, operating system version and app version, so that the app can display correctly and so we can support you if something goes wrong. This is sent to our Convex backend along with generator data.

4.4 Information you give us directly

If you contact us through the app, by email, or by phone, we collect what you choose to tell us. That usually means your name, contact details, the generator you own and a description of your problem. If a service call or repair is needed, we also collect your address so this can be arranged.

This information passes through our Convex backend and is stored in our HubSpot account, which is used to manage customer service requests. It is not retained in Convex itself. We use it to answer you and to keep a record of the enquiry.

5. Analytics and crash reporting

The app does not use analytics, crash reporting or tracking services. Generator data described above, and any information you provide to us directly, are the only data sent from the app to our servers.

6. Why we collect information

We collect personal information only for purposes connected with supplying, supporting and improving GT Power products. Specifically:

• to let the app connect to and display readings from your generator
• to help you monitor servicing needs and operate the machine safely
• to diagnose faults in your generator and in the app
• to answer your enquiries and provide warranty and technical support
• to arrange service or repairs where you have asked for one
• to identify reliability patterns across our product range so we can improve future models
• to meet our legal obligations, including product safety obligations

We will not use your personal information for a different purpose unless you authorise it or the Privacy Act 2020 permits it.

7. How we collect information

We collect information directly from you and from the generator you connect to. We do not buy personal information, and we do not collect information about you from third parties.

Where we collect personal information, we do so lawfully, fairly, and in a way that is not unreasonably intrusive.

8. Who can see your information

Access to personal information we hold is limited to those who need it to do their job, which in practice means our customer support, technical and product staff.

We may share personal information with:

• Convex, Inc., which hosts generator and app data on our behalf, as described in section 9
• HubSpot, Inc., which hosts service request and support contact information on our behalf, as described in section 9
• our service providers, such as our app developer and IT providers, who act on our instructions and are contractually required to protect it
• GT Power authorised service agents and resellers, where this is needed to carry out a warranty claim or repair you have asked for. These are independent businesses, and once we pass your details to them they are responsible for that information under their own obligations as agencies under the Privacy Act 2020. We only give them what they need for the job, typically your name, contact details, address and the generator concerned
• a person or body we are required or authorised to disclose to by law, including a regulator or a court

We do not share personal information with anyone for their own marketing purposes.

9. Where your information is stored, and sending it overseas

Generator and app data is stored on infrastructure provided by Convex, Inc., located in the United States (US East, N. Virginia region).

Service request and support contact information is stored in our HubSpot account, also hosted in the United States (US East).

Where personal information is disclosed to a person or organisation outside New Zealand in a way that engages information privacy principle 12, we satisfy ourselves that the recipient is required to protect the information in a way that provides comparable safeguards to those in the Privacy Act 2020.

10. Storage and security

We take reasonable steps to protect personal information against loss, unauthorised access, use, modification, disclosure and other misuse, as required by information privacy principle 5.

Those steps include:

• restricting staff access to what is needed for the role
• encrypting data in transit using industry standard transport security
• encrypting data at rest on our servers
• requiring our service providers to maintain appropriate security controls
• keeping the app and its components patched and up to date
• reviewing our security practices periodically

Bluetooth connections between the app and your generator are local to your device and your machine. As with any wireless technology or internet service, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. How long we keep information

We keep personal information only for as long as we need it for the purpose it was collected, or for as long as the law requires us to keep it.

• We do not currently have a fixed retention period for generator operating data. We keep it for as long as it remains useful for supporting your generator, diagnosing faults, and improving our products. You can ask us to delete the data we hold for your machine at any time — see section 12.
• We do not currently have a fixed retention period for support and warranty records. We keep them for as long as they remain necessary to honour warranty obligations and meet our record keeping duties. You can ask us to delete the records we hold for your machine at any time — see section 12.

Generator data held on your device is under your control. You can delete it by [clearing the app data / unpairing the generator / uninstalling the app]. Uninstalling the app does not delete data already sent to our servers.

12. Deleting your information

You can ask us to delete the generator data we hold for your machine, and any support or service request records associated with it. Contact our Privacy Officer using the details in section 17 and tell us the serial number of the generator.

Because the app has no accounts, we will need to confirm that the machine is yours before we act. We may ask for proof of purchase or warranty registration details.

We will action your request within 20 working days, except where we are required to keep the information, for example to meet an outstanding warranty or legal obligation. If we cannot delete everything, we will tell you what we have kept and why.

13. Your right to see and correct your information

Under information privacy principles 6 and 7, you have the right to:

• ask whether we hold personal information about you
• ask for a copy of that information
• ask us to correct it if you think it is wrong

To make a request, contact our Privacy Officer using the details in section 17. We will respond as soon as we reasonably can and no later than 20 working days after we receive your request. We may need to verify your identity first.

There is normally no charge. If a charge does apply we will tell you before we proceed. In limited circumstances the Privacy Act 2020 allows us to withhold information, and if that happens we will tell you why.

If we do not agree to correct information, you can ask us to attach a statement of the correction you sought, and we will take reasonable steps to do so.

14. Unique identifiers

We do not assign a unique identifier to you as an individual. Generator serial numbers identify a machine, and we currently use the serial number alone to associate readings with the correct generator. We do not use it as an identifier for individuals or share it for that purpose.

15. Privacy breaches

If we experience a privacy breach that has caused, or is likely to cause, serious harm to anyone affected, we will notify the Office of the Privacy Commissioner and the affected individuals as soon as practicable, as required by Part 6 of the Privacy Act 2020.

16. Children

The app is designed for owners and operators of GT Power generators and is not directed at children. Generators are not for use by children. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, contact our Privacy Officer and we will delete it.

17. Contact us

Our Privacy Officer is appointed under section 201 of the Privacy Act 2020 and is responsible for how we handle personal information.

18. Making a complaint

If you are not happy with how we have handled your personal information, please contact our Privacy Officer first. We take complaints seriously and will try to resolve the matter with you directly.

If you are still not satisfied, you can complain to the Office of the Privacy Commissioner:

19. Changes to this policy

We may update this policy from time to time. If we make a change that materially affects how we handle your personal information, we will tell you through the app or on our website before the change takes effect. The version number and date at the top of this policy show when it was last changed.

Previous versions are available on request from our Privacy Officer.

This policy is published at https://www.gtpower.co.nz/app/privacypolicy and is linked from the App Store and Google Play listings for the GT Power app.