Zebra General Data Protection Regulation (GDPR) Addendum

As used in this GDPR Addendum, the following terms shall have the following meanings:

“GDPR” means the General Data Protection Regulation (EU) 2016/679, together with any national implementing laws in any Member State of the European Union, as amended, repealed, consolidated or replaced from time to time including the UK version of the GDPR as defined in Section 10(3) of the Data Protection Act 2018; and

“Personal Data”, “Data Subject”, “Process”, and “Processor” will each have the meaning given to them in Article 4 of the GDPR.

As a Data Controller and Data Processor of data, including Personal Data, we collect, process and use Personal Data fairly and lawfully.

Annex 1 (below) contains the list of Zebra entities in the European Economic Area (“EEA”) that may collect and process your Personal Data.

We are focused on implementing the appropriate technical and organizational measures to ensure that Zebra meets the requirements of the GDPR. Where the GDPR is applicable, we commit to follow all the requirements of the GDPR, including to:

• Only Process your Personal Data in line with your instructions
• Honor your right to withdraw consent at any time
• Maintain the confidentiality of your Personal Data and ensure sufficient staff training on data protection
• Ensure appropriate security of, and access to, your Personal Data
• Provide relevant data retention and deletion policies
• Facilitating Data Subject’s rights and incident notifications
• Utilize Processors, sub-Processors and international data transfers in a GDPR-compliant manner

Zebra’s software solutions may use sub-processors, including Zebra affiliates, for the processing of Personal Data from time to time in accordance with the GDPR. Our current software solutions’ sub-processors can be found under the following links:

• Antuit.ai Sub-processor Schedule
• Reflexis Sub-processor Schedule
• Zebra Retail Solutions Sub-processor Schedule
• Zebra Workcloud Actionable Intelligence Sub-processor Schedule
• Zebra Workcloud Communication Sub-processor Schedule

If you are a member of the Zebra PartnerConnect Program,  please click on the following link to see Zebra’s PartnerConnect Sub-processor Schedule.

For the purposes set out in the Zebra Privacy Policy and any applicable product or solution documentation, your Personal Data may be transferred outside of the country in which it was collected to Zebra Technologies Corporation (“Zebra US”), the parent company of Zebra located in the United States, its subsidiaries, affiliates and third party service providers located in other jurisdictions.

We will ensure that all transfers are lawful and that there are appropriate legal and security arrangements, including implementing supplementary measures to achieve a level of protection equivalent to GDPR.

To meet the conditions of Chapter 5 of the GDPR, we primarily rely on Standard Contractual Clauses approved by the European Commission in its decisions 2004/915/EC and 2010/87/EU or 2021/914/EC and 2021/915/EU for any new agreement entered into with or by Zebra on or after the 28 September 2021 ("SCCs"). This shall ensure the lawful transfer of Personal Data outside of the UK and European Union. Furthermore, Zebra as a group of companies has entered into an intra-group data transfer agreement, which incorporates the SCCs as the GDPR Chapter 5 transfer mechanism. This agreement ensures appropriate and suitable safeguards with Zebra US, Zebra UK, our subsidiaries, affiliates and third party service providers. 

Our sub-processors commit to using approved methods to ensure the controlled transfer of data outside of the EU. Additionally, Zebra’s providers make strong commitments to Zebra related to limiting access to the data that is stored with them.

Zebra products, services and websites are not for use by children under the age of 16 years and Zebra does not knowingly collect, store, share or use the Personal Data of children under the age of 16 years. If you are under the age of 16 years, please do not provide any Personal Data, even if prompted by our website to do so.

Where requested and lawful to do so, we may communicate with you about our products, services and solutions, subject to your consent where required. If you wish to unsubscribe from receiving marketing communications, please visit http://online.zebra.com/Preferences-enu to manage communications preferences. As is common with most websites, Zebra gathers certain information and stores it in log files when you interact with Zebra’s website. Zebra uses this information to personalize information presented to you, to monitor the effectiveness of our website-based marketing campaigns and to improve the functionality of the website. In such cases, we would treat such information in accordance with Zebra’s Privacy Policy.

Please visit the Preference Center page to understand the options available to you regarding unsubscribing to any communications you have subscribed to via our website. To invoke a Data Subject request under GDPR for access to and rectification or erasure of Personal Data or restriction of Processing or to object to Processing and rights to data portability, send an email detailing your specific request to privacy@zebra.com. We also retain Personal Data no longer than is necessary to carry out the purposes described in the Zebra Privacy Policy. In considering how long to keep a particular category of Personal Data we will have regard to the purposes for which it is processed, and any purposes which continue to apply even when we have delivered a product or service (for example, because we need to keep records for audit purposes or in the event of a legal claim or threatened claims). Data Subjects have the right to lodge a complaint with the appropriate supervisory authority if the Data Subject considers that the Processing of Personal Data relating to him or her infringes the GDPR. Please refer to Annex 2 below to find your local supervisory authority in the EEA.

This Zebra GDPR Addendum is subject to change from time to time, so you should check it periodically.

The statutory regulation is:

This policy was last updated on May 19, 2022.