Last Update: July 15, 2026
Last Update: July 15, 2026
This info box is for context only and does not form part of the binding legal terms below.
Applicability Notice:
These Additional Terms apply ONLY if you or your End Customers deploy our services on robotics hardware physically located within an EU Member State. If your deployment is outside the EU, this document does not apply to you.
The EU Data Act is a new EU regulation designed to give users greater access and control rights over data generated by connected products (like industrial robots) and related services (like some of Intrinsic’s services). Insofar certain data generated by your operation of robotics hardware running IntrinsicOS is readily available to Intrinsic, the EU Data Act classifies Intrinsic as a ‘Data Holder’ and the party owning or renting the robot (you or your End Customer) as a ‘User’.
What these terms do:
What this document does not do:
- For processing personal data, the Intrinsic Privacy Policy and related data processing terms remain applicable.
- Ownership and license rights to Intrinsic’s services and the solutions you build remain governed by the Intrinsic Platform Terms.
For details on the specific data types generated, how to access or share your data, and other information required by Art. 3(3) EU Data Act, please see the “Pre-Contractual Information on Services offered by Intrinsic Innovation LLC (“Intrinsic”) according to Article 3 (3) EU Data Act” which will be provided to you separately.
These Data Act Additional Terms (the “DA Additional Terms”) are Additional Terms under the Platform Terms and as such part of the Terms. The DA Additional Terms govern the rights and obligations of the Data Holder and the DA User concerning DA Data in accordance with the EU Data Act (Regulation (EU) 2023/2854) (the “EU Data Act”). Capitalized terms used but not otherwise defined in these DA Additional Terms have the meaning set forth in the Platform Terms.
1.1 “Data Holder” means ‘data holder’ as defined in Art. 2(13) EU Data Act.
1.2 “DA User” means ‘user’ as defined in Art. 2(12) EU Data Act.
1.3 “DA Data” means data ‘readily available’ to Intrinsic as defined in Art. 2(17) EU Data Act in connection with In DA Scope Services and Your Connected Product.
1.4 “In DA Scope Services” means only those elements of the Services that are required to deploy, execute Your Solutions on computing hardware running IntrinsicOS, including the cloud-hosted backend services that exchange data with the edge device during runtime, as further described in the Documentation. For clarity, this excludes elements of the Service used to design, develop or test Your Solution, or run Your Solution in simulation. In DA Scope Services shall be considered ‘related services’ as defined in Art. 2(6) EU Data Act.
1.5 “Your Connected Product” means the robotic hardware that is connected to and operated via Your Solutions.
2.1 Applicability in case of your own usage. Insofar as you use In DA Scope Services in connection with Your Connected Product at your own site(s) located in an EU member state, you are considered a DA User and Intrinsic a Data Holder with regards to DA Data. In this constellation, Sections 2 through 7 apply to you.
2.2 Applicability in case of End Customer usage. Insofar as you permit an End Customer to access or use Your Solutions and IntrinsicOS at an End Customer site located in an EU member state, only your End Customer is considered a DA User and Intrinsic a Data Holder with regards to the In DA Scope Services offered to your End Customer. In this constellation, you must agree with such End Customer on the provisions set out in Sections 3 through Section 8 with Intrinsic as named third-party beneficiary. These provisions shall be made part of your End Customer Contract, as defined and further specified in Section 8 of the Robot Operating Terms. In this case, all references to ‘you’ in Sections 3 through Section 8 shall be read as references to the respective End Customer. You may, but are not obliged to, use the template in the Attachment for your agreement with End Customers. You will notify us if an End Customer does not accept such provisions without undue delay, and in any case before you permit an End Customer to access or use Your Solutions and IntrinsicOS.
You declare that you are either the owner of Your Connected Product or contractually entitled to use Your Connected Product under a rent, lease or similar contract.
You agree that Intrinsic and its affiliates may use DA Data that are non-personal data for the following purposes:
i. performing an agreement with you or activities related to such agreement;
ii. providing support, warranty or similar activities or assessing your, Intrinsic’s or third party’s claims related to the Services (e.g. regarding malfunctions);
iii. monitoring and maintaining the functioning, safety and security of the Services and ensuring quality control;
iv. improving the functioning of any product or related service offered by Intrinsic or its affiliates;
v. developing new products or services by Intrinsic, its affiliates, by third parties acting on behalf of Intrinsic, or in collaboration with other parties; and
vi. aggregating DA Data with other data or creating derived data thereof.
With regard to Section 4, it is clarified that Intrinsic shall not use DA Data to derive insights about your economic situation, assets and production methods or about your use of Your Connected Products in any manner that could undermine your commercial position on the markets in which you are active. None of the DA Data uses agreed to under Section 4 may be interpreted as including such DA Data use, and Intrinsic takes reasonable steps to prevent, by appropriate organizational and technical means, that no third party, within or outside Intrinsic’s organization, engages in such DA Data use.
Intrinsic may use processing services, e.g. cloud computing services (including infrastructure as a service, platform as a service and software as a service), hosting services, or other third-party contractors to achieve the agreed purposes under Section 4.
You agree that Intrinsic may share DA Data with third parties, if (a) DA Data is used by the third party exclusively for purposes listed in Section 4, either for assisting Intrinsic or collaborating with Intrinsic, and (b) Intrinsic contractually binds the third party (i) not to use DA Data for any purposes or in any way going beyond the use that is permissible in accordance with Section 4, (ii) not to use DA Data for any purpose limited by Section 5, and (iii) to apply the protective measures required under Section 8. Notwithstanding the foregoing, you agree that Intrinsic may share DA Data with its affiliates without limitation, if (a) DA Data is used by the affiliates for purposes listed in Section 4, and (b) Intrinsic contractually binds the affiliates (i) not to use DA Data for purposes going beyond the use that is permissible in accordance with Section 4, (ii) not to use DA Data for purposes limited by Section 5, and (iii) to apply the protective measures required under Section 8. The third parties may also use processing services as described in Section 6 to achieve the agreed purposes under Section 4.
Intrinsic applies protective measures for DA Data that are reasonable under the circumstances, considering the state of science and technology, potential harm suffered by you as a result of DA Data loss or disclosure of DA Data to unauthorized third parties and the costs associated with the protective measures, as further detailed in Intrinsic’s documentation and technical specification. Intrinsic may also apply other appropriate technical protection measures to prevent unauthorized access to DA Data. You agree not to alter or remove such technical protection measures unless agreed by Intrinsic in advance and in writing.
[Instruction to Provider: This template is a non-binding suggestion on how you can fulfill your obligation under Section 2.2 DA Additional Terms; you may incorporate the text below into your agreement with your customer]