Telematics Services
Mitsubishi Heavy Industries Thermal Transport Europe GmbH ("MTTE")
Last updated: 18 August 2026
Mitsubishi Heavy Industries Thermal Transport Europe GmbH ("MTTE") is committed to providing transparent, fair and secure access to data generated through its connected products and related telematics services in accordance with Regulation (EU) 2023/2854 on harmonised rules on fair access to and use of data (the "EU Data Act").
This statement provides information about the data generated through MTTE's telematics services, how such data can be accessed and retrieved, and how users may request that data be made available to third parties of their choice.
This statement applies to the extent that the relevant connected products and related services fall within the scope of the EU Data Act.
1. Scope
This statement applies to product data and related service data generated through MTTE telematics services in connection with covered connected refrigeration products and related telematics services.
The covered product series include, subject to the applicable product configuration and telematics service:
The exact data generated and made available may vary depending on the product model, configuration, installed software, sensors, connectivity, telematics service and applicable contractual arrangements.
This statement does not apply to standalone monitoring devices, temperature recorders, service tools or other equipment or systems that are not connected to the applicable MTTE telematics platform.
2. Connected Products and Telematics Services
MTTE's telematics services enable the transmission, collection and presentation of operational data generated through connected refrigeration units.
Depending on the applicable product and telematics configuration, the connected product and/or related telematics service may generate product data and related service data.
Data covered by the EU Data Act may include data generated automatically through the operation or use of the connected product or related service, together with relevant metadata necessary to interpret and use such data.
3. Categories of Data
Depending on the applicable product, configuration and telematics service, the data generated and/or made available may include:
The availability of particular data categories may vary between product models, configurations, software versions and telematics services.
For product-specific information concerning the data generated by a particular connected product or related service, users may contact MTTE using the contact details in Section 14.
4. Data Format and Volume
Where data are made available under the EU Data Act, MTTE will provide the applicable data in a comprehensive, structured, commonly used and machine-readable format, as required by the Regulation.
The data format may depend on the applicable telematics platform and data category.
Currently, telematics data may be accessed through the following platforms:
Data formats and technical access methods:
The applicable format and access method depend on the relevant telematics service and data category. Information concerning the applicable format and access method for specific data can be obtained from MTTE upon request.
The volume of data generated depends on factors including:
For product-specific information concerning data volume, users may contact MTTE.
5. Frequency and Availability of Data
Data may be generated periodically or, depending on the applicable product and telematics configuration, continuously.
The frequency at which data are transmitted to and made available through the telematics platform depends on the relevant product configuration, telematics service, network connectivity and technical conditions.
Where applicable and technically feasible, data may be made available continuously and/or in real time.
The applicable transmission and availability frequency for a particular product or service can be obtained from MTTE upon request.
6. Access to Data
Customers with an active telematics service subscription may access available telematics data through the applicable telematics platform, including:
Where data cannot be accessed directly through the applicable telematics platform, users may request access to readily available data from MTTE.
Requests may be submitted using the contact details provided in Section 14.
In accordance with the EU Data Act, users may exercise their rights to access readily available product data and related service data, subject to the applicable conditions and safeguards of the Regulation.
Access to data by the user under the EU Data Act is provided free of charge where required by the Regulation.
7. Requesting Data Sharing with a Third Party
A user may request that readily available product data and related service data, together with relevant metadata necessary to interpret and use the data, be made available to a third party of the user's choice.
Upon a valid request, MTTE will make the applicable data available to the designated third party without undue delay and in accordance with the EU Data Act.
Data will be made available:
Requests may be submitted by the user or by a person acting on behalf of the user.
To process a request, MTTE may require information necessary to verify the identity of the requester and their status as a user or the authority of a person acting on behalf of the user. MTTE will not require information beyond what is necessary for this purpose.
The request should identify, where applicable:
8. Personal Data
Some telematics data may constitute personal data or may be capable of being associated with an identifiable individual.
The EU Data Act does not replace applicable data protection legislation, including Regulation (EU) 2016/679 (General Data Protection Regulation – "GDPR").
Where personal data are involved, MTTE will process and make such data available in accordance with applicable data protection law.
In particular, where the user requesting personal data is not the data subject, MTTE will only make such personal data available where the applicable legal requirements under the GDPR and other relevant data protection legislation are satisfied.
The EU Data Act itself does not constitute a legal basis for the collection or generation of personal data.
This statement should therefore be read together with MTTE's applicable Privacy Policy.
9. Data Portability and Interoperability
MTTE supports the portability of applicable telematics data in accordance with the EU Data Act.
Where required, data will be made available in a structured, commonly used and machine-readable format that enables the user or a third party designated by the user to retrieve and use the data.
Where relevant, metadata necessary to interpret and use the data will also be made available.
The applicable technical access method depends on the relevant telematics service and may include access through the applicable telematics platform or another technical mechanism provided by MTTE.
10. Storage and Retention
Telematics data may be stored using infrastructure operated by MTTE and/or its telematics service providers.
The applicable storage location and retention period may vary depending on the telematics service, product configuration and contractual arrangements.
Information concerning the applicable storage arrangements and retention period for a particular telematics service is available from MTTE upon request.
MTTE applies appropriate technical and organisational measures designed to protect stored data against unauthorised access, alteration, loss or disclosure.
11. Protection of Trade Secrets and Security
The exercise of rights under the EU Data Act is subject to the safeguards and conditions established by the Regulation.
MTTE takes appropriate measures to protect confidential information, trade secrets and the security of its systems and data infrastructure.
Where the EU Data Act permits or requires MTTE to take measures to protect trade secrets, cybersecurity or other protected interests, MTTE will apply the relevant safeguards in accordance with the Regulation.
12. Costs
Where the EU Data Act requires MTTE to provide data to a user, the exercise of the user's applicable right to access the data will be free of charge.
Where the EU Data Act permits compensation or charges in connection with a particular data-sharing arrangement, any such compensation or charge will be determined and applied in accordance with the applicable provisions of the Regulation.
Users will be informed of any applicable charge before the relevant service is provided.
13. User Rights and Complaints
Subject to the conditions established by the EU Data Act, users may have the right to:
Users should first contact MTTE regarding questions or concerns concerning access to or sharing of telematics data.
In Germany, the Bundesnetzagentur (Federal Network Agency) is the competent authority for implementation and enforcement of the EU Data Act.
Further information and the complaint portal are available from the Bundesnetzagentur.
14. Contact
For questions concerning telematics data, data access, data sharing, data portability or the exercise of rights under the EU Data Act, please contact:
Mitsubishi Heavy Industries Thermal Transport Europe GmbH
Hannoversche Straße 49
49084 Osnabrück
Germany
Contact form:
https://mhi-tte.com/contact
15. Relationship with Other Legal Notices
This statement complements and does not replace:
Where mandatory provisions of applicable law apply, those provisions prevail.
16. Updates
MTTE may update this statement from time to time to reflect changes to its connected products, telematics services, technical access methods, data availability or applicable legal requirements.
Last updated: 18 August 2026
Mitsubishi Heavy Industries Thermal Transport Europe GmbH