The Data Act (EU Regulation 2023/2854) is directly applicable European Union legislation that regulates the conditions for access to data generated by connected products and related services after 12 September 2025. The Regulation extends the rights of users – both individuals and companies – to use this data and allows them to share it with third parties at their discretion.
ETA a.s. is ready to fully implement solutions in line with the Data Act and build trust in data services and innovation. In this context, it has prepared this document to provide its business partners and customers with basic information about its rights, the data generated when using connected products and related services, and other information required by the Regulation.
1.1. Definitions
- Customer: Refers to customers of ETA a.s., i.e. either end customers of ETA a.s. or its contractual partners who sell or otherwise distribute the products or provide services to them.
- Data: is any digital record of events, facts or information. This includes files such as audio recordings, images, videos or other electronic records.
- User: Anyone who owns a connected product (e.g., an Internet-connected device) or has been contractually granted temporary rights to use that product. The user may also use the services associated with the product.
- Data Holder: The person or company that has the right or obligation under this Regulation or the law to use and disclose data from the product or related services. This may be data that was created during the use of the connected product or created during the provision of a related service, if this is the result of a contract. Most often, it is the manufacturer of the connected product or the provider of the related service.
- Data recipient: The person or company that receives the data from the data holder for its business or professional purposes. The recipient of the data is not the user of the product itself, but someone else – for example, a third party to whom the data holder provides the data either at the request of the user or if required by law.
- Connected product: a product that in its use acquires, creates or collects data about itself or its environment. This product is capable of transmitting data through an electronic communications service, physical connection, or access to a device. Its primary function is not to store, process or transmit data on behalf of persons other than the user.
- Related service: A digital service (e.g. software, application) that is associated with the connected product at the time of purchase, rental or lease, such that the product cannot perform some of its functions without it. It may also be a service added later by the manufacturer or a third party to add, update or modify the functions of the connected product.
1.2. Key principles of the Data Act
- User control and transparency: Users (natural or legal persons) have the right to access and manage data from connected products.
- Fair access and use: Data can be provided to the user themselves or securely shared with selected third parties.
- Data security and legal compliance: Data sharing is subject to strict security rules and legal safeguards.
- Dispute resolution: The Data Act provides clear mechanisms for resolving conflicts over data access.
1.3. What does the Data Act cover?
The Data Act applies to so-called connected products and related digital services. In the case of customers of ETA a.s., this includes in particular ETA a.s. products that are directly manufactured or resold/distributed by ETA a.s. and which:
- generate usage, condition, or environmental data, including changes in patterns of use.
- transmit this data via wired or wireless connections, or
- include mobile applications that allow remote control of product functions.
ETA a.s. sells/distributes mainly products of brands such as:
- ETA, JVC, GoGEN, Hyundai, Gallet, GND, Goddess and other our brands.
1.4. What data is covered by the Regulation?
The Data Act covers raw data generated by the use of connected product and related digital services, as long as the data is readily available from the product. Readily available data is data from products and related services that the data holder lawfully obtains or can lawfully obtain from the connected product or related service without unreasonable effort beyond a simple operation.
ETA’s connected products include various models, configurations and integrated services. The amount of data generated by their use depends on the specific product, its features, hardware version, usage pattern, software updates and third-party services activated.
Typically, in the case of ETA a.s. connected products, these are:
- Device information: Technical specifications and identifiers including software version, module status, system status and monitoring records.
- Operational data: Analytical data on how the connected product is used, such as device status, time of use, battery level or power consumption.
- Diagnostic data: Error messages, status of individual systems.
- User settings and preferences: Profile settings, individual configurations and user preferences.
- Application and content usage: Analytical information on usage of installed applications, content browsing and media access.
- Interaction with the user interface: Behaviour when navigating menus, using search functions and other controls.
- Connectivity and network: Information on internet connectivity, speed, outages and software updates.
- Data from third-party services and voice assistants (if relevant): Use of smart service integrations and voice controls.
- Data from related digital services.
The specific range of data available may vary depending on the type of connected product, its model and specific configuration.
Access to data will be provided to the extent that it is technically available and in accordance with the terms and conditions of the manufacturer of the product in question. The data generated by the connected product is stored, depending on the specific type and model of the device, either directly in the connected product or on a remote server. The volume, format and method of data collection vary according to the type and model of the product. The user can access them either directly via the device interface or the associated application in the relevant settings section, via a link on the ETA a.s. website, or via the contact form below. Requests must include the product type and the product reference identifier.
1.5. Conversely, the Data Act does not apply to:
- Data generated by complex processing, calculations or combination of multiple sources (e.g. predictive analytics),
- Copyrighted content (e.g. audiovisual content),
- Information the disclosure of which would violate the protection of personal data or trade secrets.
1.6. What rights do you have in relation to data from connected products and related services?
The Data Act gives users better control over the data generated from connected products and related services, which means greater transparency and options for managing that data. For ETA a.s. users, this means in particular:
- Enhanced right of access to data from connected products and related services,
- The possibility to use this data on their own, and
- The right to share them with partners of your choice.
1.7. Privacy Policy
The adoption of the Data Act is without prejudice to data protection legislation within the meaning of the General Data Protection Regulation (EU Regulation 2016/679).
All processing of personal data in connection with this Regulation is governed exclusively by the rules of the General Data Protection Regulation, including the principles of lawfulness, transparency and purpose limitation. Personal data may only be processed on the basis of a valid legal ground and with full respect for the rights of data subjects. For more information on the processing of personal data, please refer to the Privacy Policy.
1.8. Contacts and other sources of information
If you have questions or need more detailed information, you can contact us using the contact form on the website Contact.