ABOUT OUR APPROACH TO THE DATA ACT
Kubota Holdings Europe B.V., a company registered under the laws of the Netherlands, having its registered address at Hoofdweg 1264, 2153 LR, Nieuw-Vennep, The Netherlands (hereinafter referred to as “Kubota Holdings Europe”) and its affiliates[1](hereinafter referred to as “Kubota Companies”, together, with Kubota Holdings Europe, referred to as “Kubota”, “We”, “Our” or “Us”) is committed to ensuring that any data generated by Our connected products and/or related services is used fairly, lawfully and securely. We understand transparency and respect are foundational aspects of longstanding relationships and, therefore, We take every reasonable effort to protect the data you provide to Us. At Kubota, your trust matters to us. We believe you should always understand how your machine data is collected, used, and protected.
Kubota Holdings Europe is a company belonging to Kubota Corporation, a company registered under the laws of Japan, having its registered address at 2-47, Shikitsuhigashi 1-chome, Naniwa-ku, Osaka 556-8601, Japan (hereinafter referred to as “Kubota Corporation”).
Kubota Holdings Europe owns the brands “Kubota”, “Kverneland”, “Vicon”, “FEDE” and “ROC”. The brands “Kubota”, “Vicon”, “FEDE”, “ROC” and “Kverneland” are together referred to as the “Brands”.
We collect your product data from the product you use and have bought from Kubota or a Brand (hereinafter referred to as the “Machine”) or any hardware or device interfacing with your Machine (hereinafter referred to as “Product Data”) that is generated through your use of Our connected products and/or related services as defined within the EU Data Act (European Data Act (Regulation (EU) 2023/2854, hereinafter referred to as “EU Data Act”). Product Data is any data considered to be in scope of the EU Data Act generated by, collected by, stored in, or sent from/ to the Machine.
This EU Data Act notice describes to Our users (the user being the owner or user of the connected product or the receiver of the related services, hereinafter referred to as “User”) about their Product Data generated by Our connected products and/or related services that We sell.
In the instances where We are the data holder under the EU Data Act for the Product Data generated through the use of the Machines, We will tell you about the types of Product Data We collect, how Kubota Holdings Europe and/or Kubota Corporation uses the Product Data, how Users can access their Product Data, with whom We share the Product Data, and the choices you can make about Our use of the Product Data. We also describe the measures We take to protect the security of the Product Data and how you can contact Us about. For detailed information on a specific connected product and/or related service, you should consult the specific EU Data Act documentation for this connected product and/or related service.
This EU Data Act notice should be read jointly and conjunction with, and is without prejudice to, the applicable data privacy notice, which shall prevail over this EU Data Act notice in regard to personal data.
This EU Data Act notice is drawn up in English and is, at the discretion of Kubota, translated in several languages for your convenience. In case of inconsistencies, discrepancies or difficulty of application or interpretation between the English version and the translated versions, the English version shall prevail.
WHAT IS PRODUCT DATA
Product Data is referred according to the following definition given in the EU Data Act, i.e. “data generated by the use of a connected product that the manufacturer designed to be retrievable, via an electronic communications service, physical connection or on-device access, by a user, data holder or a third party, including, where relevant, the manufacturer”, being understood that:
- “connected product” means an item that obtains, generates or collects data concerning its use or environment and that is able to communicate Product Data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the User;
- “related service” means a digital service, other than an electronic communications service, including software, which is connected with the product at the time of the purchase, rent or lease in such a way that its absence would prevent the connected product from performing one or more of its functions, or which is subsequently connected to the product by the manufacturer or a third party to add to, update or adapt the functions of the connected product;
As per the EU Data Act.
HOW WE COLLECT PRODUCT DATA
The types of Product Data covered by the EU Data Act can vary depending on your connected product and/or related service. This can then be further varied based on the type of Machine’s series, production year, and installed features. The volume of Product Data is also dependent on these characteristics, and not all connected products and/or related services will have the same Product Data. This can then also depend on the type of settings you have put in place on your connected product and/or related service. The data collection frequency also depends on the system configuration; this can vary from updates every second to summaries captured at longer intervals.
Products connected through Our telematics systems automatically gather this information and securely transmit it to their relevant platforms. Data is stored in Kubota-managed infrastructure located in secure data centers around the world, built to meet high standards of security, reliability, and performance.
The provision of certain connected products and/or related services requires the User to enter into a specific agreement under the EU Data Act. This agreement governs the collection, use, and sharing of data generated by the connected product and/or related service, ensuring that both Kubota and the User clearly understand their rights and responsibilities.
The agreement also specifies how the service can be terminated, and the conditions under which data access, sharing, or processing will end. Entering into this agreement is necessary to enable lawful and secure use of the connected product and/or related service in compliance with applicable data regulations.
TYPES OF DATA COLLECTED
The specific data collected depends on your Machine type and configuration. This includes data from Machine systems, sensors, telematics devices, and User account information.
Below is a non-exhaustive list of the categories and examples of data Kubota may collect:
Machine performance and diagnostic data
- Error messages and fault codes
- Motor speed and engine rotation data
- Engine performance and operating parameters
- Temperatures (i.e., meter, oil, coolant, exhaust, engine, other fluids, and ambient air)
- Fuel consumption and fuel tank information
- Voltage, current, and battery-related data
- Auto stop count, eco-mode, and crane mode status
- Air conditioning use and operating time
- Key on/off accumulation and idle hours (operating and non-operating)
- Lever lock use count and emergency mode activation
- Production time, occupancy rate, and overall use statistics
Machine location and movement data
- GPS position data, including latitude, longitude, and elevation
- Machine movement speed, roll, and pitch angles
- Geofence notifications and related alerts
Telecommunication and connectivity data
- Outbound events and alerts (including mode transitions, tamper alerts, and battery disconnection alerts)
- Telecommunication device accuracy status and number of satellites in use
- Device sent time and communication quality data
- Device connection and performance data, including:
- DCU and IoT Hub connection status
- Telecommunication device logs
- GPS data (e.g., signal-to-noise ratio per satellite)
- LTE data, mobile network code, and mobile network identifiers
- CPU temperature, internal and external battery voltage
Electrical and system data
- Electrical system voltages and power states
- Switch status and control signal readings
User and account information
- User email address
- Organization name and address
- Log-in credentials and account settings
- Peripheral information
- Chassis number and Machine model name
- Telematics pairing time and date
Machine log and notification data
- Machine operation and status logs
- System notifications and event alerts
- Geofence notifications
- Harness disconnection alerts
DATA ACCESS
In accordance with the EU Data Act, Users have the right to access data that is generated by their connected products and/or by related services. Users may also choose to share this data with approved third-party recipients of their choice.
When the User is not the individual to whom the Product Data relates, Kubota will only make personal data accessible where there is a valid legal basis for doing so under Article 6 of the General Data Protection Regulation (Regulation (EU) 2016/679) (hereinafter referred to as the “GDPR”). Where applicable, the conditions under Article 9 of the GDPR and Article 5(3) of Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (hereinafter referred to as the “Directive on privacy and electronic communications”) shall also be met before any personal data can be disclosed.
HOW CAN USERS REQUEST ACCESS TO THEIR DATA?
For some connected products and/or related services, direct access means that the User can immediately access all of their Product Data. However, in some instances, only indirect access or a mixture of direct and indirect access is possible. In these scenarios, Users (or their authorized representatives) may request access to Product Data at any time. Once a valid request is received, Kubota will make the relevant data available without unnecessary delay.
Requests for access should be submitted on the relevant form for each connected product and/or related service (if applicable) or via email to: khe_g.privacy@kubota.com
Kubota may ask for limited additional information to confirm the identity of the requester or to verify that a third party has authorization to act on the User’s behalf. Any such verification will be kept to the minimum necessary to protect User Product Data and privacy.
If the requester is not the data subject, it must clearly state the legal basis for the data processing under Article 6 of the GDPR, and, where applicable, the relevant justification under Article 9 of the GDPR and Article 5(3) of the Directive on privacy and electronic communications.
When a request is validated, Kubota will provide the data through a secure file transfer system. The User will receive an email containing instructions and a secure download link to access the requested data files.
OUR USAGE OF THE DATA
Kubota uses Product Data in a responsible and transparent way. This Product Data is processed only for clearly defined purposes that benefit Our customers, support Machines’reliability, and drive continuous improvement.
- Fulfilling agreements and services
Kubota uses operational data to deliver and manage the Machines and services you rely on. This includes issuing invoices, generating performance reports, conducting analyses, and providing insights that support informed business decisions. Data may also help calculate operational efficiency or staff-related metrics linked to the Machines.
- Support, warranty, and Machines’ assistance
Product Data allows Kubota to provide customer support, handle warranty or guarantee claims, and assess Machines’ performance. By analyzing operational data, Kubota can identify malfunctions, verify claims, and provide faster, more accurate technical support.
- Monitoring functionality, safety and security
Product Data is used to ensure Machines operate safely and reliably. Continuous monitoring helps detect potential issues, maintain quality standards, implement updates, and safeguard system security, while confirming that connected products perform as designed.
- Improving Machines and service performance
Operational insights help Kubota refine existing equipment and services. By understanding usage patterns, Kubota can optimize efficiency, improve controls, reduce maintenance needs, and enhance the overall User experience.
- Developing new Machines and innovations
Product Data supports research and development, guiding the creation of new equipment, digital tools, and connected features. This ensures that future Machines meet customer needs while adhering to strict ethical and data protection standards.
RETENTION OF YOUR PERSONAL DATA
Kubota will retain only the minimal amount of personal data, in accordance with the data privacy notice , necessary to:
- Process and document the User’s access request,
- Maintain the security and reliability of the data infrastructure, and
- Fulfill legal or regulatory record-keeping obligations.
No additional information about the User’s access activity will be stored beyond what is required for these specific purposes.
In case you have specific enquiries regarding the applicable retention period to specific categories of Product Data, you can contact Us as indicated in the section “How to contact us”.
STORAGE AND INTERNATIONAL TRANSFERS OF PERSONAL DATA
The personal data We collect from you is stored in the European Union by Us or Our trusted service providers.
However, We may, at any moment, transfer, access from and store the Product Data collected on your Machine, to recipients in countries other than the country in which the Product Data was originally collected. We go through a detailed due diligence process before selecting the suppliers with whom your Product Data are shared. In the context of intra-group day-to-day business, We may transfer Product Data to Kubota Corporation.
We will always ensure when We share the Product Data that the privacy and security of this data is protected and meets Our security requirements.
RECIPIENTS OF THE PRODUCT DATA
Within Kubota, Kubota Holdings Europe or Kubota Corporation, only those who need access to your Product Data to carry out their activities will have access to your Product Data and only to the extent necessary as set out in this EU Data Act notice.
We may share your Product Data with the following parties:
- Kubota’s affiliates and parent companies: your Product Data may be shared with other Kubota owned affiliates and/or subsidiaries, and Kubota Corporation, as necessary to provide you with the connected product and/or related service as for the other purposes described in this EU Data Act notice. The Product Data will only be processed and accessed in accordance with this EU Data Act notice, as well as, in line with the agreement with the User.
- Kubota dealers: your Product Data may be shared with Kubota dealers, in order for them to provide you with support on your connected product and/or related service. This will only happen with your prior consent. If your consent is not given, it may mean that some functions and support may not be available to you as a result.
- Trusted suppliers and service providers: your Product Data may be shared with trusted Kubota Holdings Europe’s or Kubota Corporation’s suppliers and service providers as necessary to provide you with Our connected products and/or related services. Depending on the connected product and/or related service, these suppliers and service providers include companies that provide the following technology and computing services, including internet and software services: data hosting, and cloud computing capabilities, account management and security, testing, debugging, error reporting, and usage analytics.
- Official disclosures to other third parties: your Product Data may be disclosed to comply with court orders and legal or regulatory requirements; to prevent injury, death, losses, fraud or abuse; to protect Kubota’s rights or to defend Kubota or Kubota Corporation in legal proceedings; and where needed in connection with the sale or transfer of business assets. Product Data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.
SECURITY
The security of your Product Data is important to Kubota. We are committed to protecting the Product Data We collect. We maintain administrative, technical and physical safeguards designed to protect the Product Data you provide, or We collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. These safeguards are intended to protect the confidentiality, integrity and availability of the Product Data you provide to Us. We periodically assess risks to your Product Data and update Our policies, procedures and technology accordingly.
UPDATES TO OUR EU DATA ACT NOTICE
This EU Data Act notice may be updated periodically to reflect changes in Our practices. We will inform you about material changes in the EU Data Act notice insofar required under applicable law.
CLAIMS
If you are concerned as User that We have breached your rights, you can lodge a claim by contacting Us as indicated in the section “How to contact us”. Our Compliance and Data Privacy Department will manage your claim and will give you additional information about how it will be handled. This is without limitation to the User’s rights under Our agreement with the User.
If the User is not satisfied with how We handle the Data, the User is entitled to lodge a complaint with the competent authority, designated in accordance with Article 37(5), point (b) of the Data Act.
HOW TO CONTACT US
If you have any questions or comments about this EU Data Act notice, would like to request access to your Product Data or have technical issues with such access, please contact Us by email at khe_g.privacy@kubota.com or by post to the attention of:
Kubota Holdings Europe B.V.
Compliance Department
Data Privacy Counsel
Hoofdweg 1264
2153 LR Nieuw-Vennep
The Netherlands
All rights reserved – Kubota Holdings Europe B.V.
Last update: January 1st, 2026
Appendix 1: List of Kubota Companies
| Kubota Europe SAS – 19-25 Rue Jules Vercruysse, 95100 Argenteuil, France |
| Kubota Europe SAS Italian branch – SP Nuova Rivoltana 2/A 29, 20054 Segrate, Italy |
| Kubota Europe SAS Netherlands branch – Rietveldstraat 22, 8013RW Zwolle, The Netherlands |
| Kubota Research and Development Europe SAS – 80 Rue du Bois Tillet, 60800 Crépy-en-Valois, France |
| Kubota Farm Machinery Europe SAS – Route de Socx, 59380 Bierne, France |
| Kubota (Deutschland) GmbH – Senefelder Strasse 3-5, 63110 Rodgau/Nieder-Roden, Germany |
| Kubota (Deutschland) GmbH Sp. z o.o. Oddział w Polsce – Baletowa 82, 02-867 Warszawa, Poland |
| Kubota Baumaschinen GmbH – Steinhauser Strasse 100, 66482 Zweibrücken, Germany |
| Kubota Baumaschinen GmbH Netherlands branch – Via Raeka 16, 6003NK Weert, The Netherlands |
| Kubota Brabender Technologie GmbH – Kulturstrasse 49, 47055 Duisburg, Germany |
| Kubota Brabender Technologie Inc. – Kestrel Road 6500, L5T 1Z6 Mississauga, Ontario, Canada |
| Kubota Brabender Technologie (Beijing) Co Ltd – 3rd F,B Section, No 3 Workshop, 2nd Project of Guanglian Industrial
Park, No 2 Kechuang East 5th Rd, 101111 Beijing, China |
| Kubota (U.K.) Ltd – Dormer Road, OX9 3UN, Thame, Oxfordshire, United Kingdom |
| Kubota Gianni Ferrari Srl – Via Vespucci 53, 42046 Reggiolo, Italy |
| Pulverizadores Fede SLU – Polígono industrial Castilla, vial 3, parcela 61G – 61 F, 46380 Cheste, Spain |
| Fede USA LLC – 1444 Biscayne Boulevard, suite 212, 33132 Miami, United States of America |
| Beijing Fengmao Fede Agricultural Machinery Co. Ltd – Workshop 2, No 15, Yanqi North Third Street, Yanqi Economic Development Zone, Huairou District, Beijing, China |
| Ambimetrics SL – Carrer del Mestre Arrieta 53 B, 12006 Castellon de la Plana, Spain |
| Kubota Espana SA – Calle Fernando Alonso 15, 28914 Leganes, Madrid, Spain |
| Kverneland AS – Plogfabrikkvegen 1, 4353 Klepp stasjon, Norway |
| Kverneland Group Operations Norway AS – Plogfabrikkvegen 1, 4353 Klepp stasjon, Norway |
| Kverneland Holding France SAS – 275 Avenue du Ruet, 45760 Marigny-les-Usages, France |
| Kverneland Group France SAS – 275 Avenue du Ruet, 45760 Marigny-les-Usages, France |
| Kverneland Group Metz SAS – 17 Rue des Terres Rouges, 57100 Thionville, France |
| Kverneland Group Les Landes-Genusson SAS – 9 Rue du Poitou, 85130 Les Landes-Genusson, France |
| Kverneland Group Europe BV – Hoofdweg 1278, 2153LR Nieuw-Vennep, The Netherlands |
| Kverneland Group Nieuw-Vennep BV – Hoofdweg 1278, 2153LR Nieuw-Vennep, The Netherlands |
| Kverneland Group Mechatronics BV – Hoofdweg 1278, 2153LR Nieuw-Vennep, The Netherlands |
| Kverneland Group Benelux BV – De Dommel 38-40, 8253PL Dronten, The Netherlands |
| Kverneland Group Benelux BV, Belgium branch – Oude Gentweg 81, 8820 Torhout, Belgium |
| Kverneland Group Holding (DE) GmbH – Coesterweg 42, 59494 Soest, Germany |
| Kverneland Group Deutschland GmbH – Coesterweg 42, 59494 Soest, Germany |
| Kverneland Group Soest GmbH – Coesterweg 42, 59494 Soest, Germany |
| Kverneland Group International GmbH – Coesterweg 45A, 59494 Soest, Germany |
| Kverneland Group Gottmadingen GmbH – Industriepark 312, 78244 Gottmadingen, Germany |
| Kverneland Group Iberica SA – Polígono Industrial Zona Franca, Sector C, Calle F 28, 08040 Barcelona, Spain |
| Kverneland Group Holding (DK) A/S – Taarupstrandvej 25, 5300 Kerteminde, Denmark |
| Kverneland Group Denmark A/S – Taarupstrandvej 25, 5300 Kerteminde, Denmark |
| Kverneland Group Kerteminde A/S – Taarupstrandvej 25, 5300 Kerteminde, Denmark |
| Kverneland Holding (UK) Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Kverneland Group UK Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Vicon Agricultural Holding Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Kverneland Devizes Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Kverneland Group Italia Srl –Via dell’Industria 22/A, 46043 Castiglione delle Stiviere, Italy |
| Kverneland Group Ravenna Srl – Via Alcide De Gasperi 34, 48026 Russi, Ravenna, Italy |
| ROC Srl – Via delle Industrie 2, 47824 Poggio Torriana, Italy |
| ROC America LLC – c/o The Corporation Trust Company, Orange Street 1209, 19801 Wilmington, Delaware, United States of America |
| Kverneland Group Sverige AB – Sätervägen 1, 60597 Norrköping, Sweden |
| Kverneland Group Ireland Ltd – Hebron Industrial Estate, R95 R2TA Kilkenny, Ireland |
| Kverneland Group Polska Sp. z o.o. – Kreta 87, 87-100 Torun, Poland |
| Kverneland Group Hungaria Kft – Karinthy út 63, 5008 Szolnok, Hungary |
| Kverneland Group CIS OOO – Novodmitrovskaya 2/2, 127015 Moscow, Russia |
| Kverneland Agricultural Equipment (Daqing) Co. Ltd – Industrial Park of Petroleum and Petrochemical Equipment Manufacturing, Daqing New High Tech Industrial Development Zone, Plant on the East Side, No 3, 163316 Daqing, China |
[1] Please see the list of Kubota Companies in the Appendix 1