Information pursuant to Regulation (EU) 2023/2854 (“Data Regulation”) for connected products with regard to Coffee Grinders (Part A), the Espresso Machine “Xenia Brew-By-Sync” (Part B) and to the related services “Mahlkönig Sync / MahlkönigCloud” (Part C)
This document provides information on product data and related-service data in accordance with Article 3(2) and Article 3(3) of Regulation (EU) 2023/2854 (Data Act). The information below describes the data that the products and related service are capable of generating, how those data are stored and accessed, and how the related service uses and manages data.
I. Part A – Information to Coffee Grinders (Article 3(2) Data Act)
1. Products covered
This information applies to the following connected Mahlkönig products:
- E80W GbS
- E80T GbS
- E65W GbS
- E64 WS
2. Product data generated
Depending on the model, configuration and use, the connected product may generate the following product data:
| Data category | Specific product data |
| Usage | Number of grinding operations |
| Grinding operation | Time / timestamp of a grinding operation |
| Grinding parameters | Selected grind setting / grind size |
| Dosing | Dosing value |
| Device status | Device on/off status and operating status |
| Maintenance / operation | Operating hours and maintenance-related information, where generated by the relevant model |
| Software | Firmware version |
| Events and errors | Device events and error information, including event records generated during operation |
| Recipes and settings | Recipes and settings relevant to product operation and synchronisation, where applicable |
3. Data formats and estimated volume
The formats identified for the product data and related technical records are:
- JSON for cloud communication.
- CSV for machine logs accessible via local Wi-Fi.
- XML.
- SQLite database for data accessible via local Wi-Fi.
The current estimate for cloud communication is less than 1 MB per day.
4. Continuous and real-time generation
The product can generate data continuously and in real time. The frequency depends on the data category and the product’s operation. For example, grinding events and associated values are generated when a grinding operation occurs, while device-status information may be generated at start-up and updated continuously.
5. Storage location and retention
Product data may be stored locally on the product and, where the user enables and configures the cloud connection, on remote infrastructure used for the Mahlkönig Sync / MahlkönigCloud service.
Local product storage is described as having a technical capacity of up to the most recent 512 MiB of data. Data stored in the cloud are retained for the duration of the service; no fixed retention period is specified. Account and profile data are retained until the relevant user account is deleted. Company, household and store-structure data are retained until the relevant company or household is deleted.
6. Access, retrieval and deletion
a. Local access
The product can operate using its own Wi-Fi access-point mode or by joining an existing Wi-Fi network. To retrieve data through the product’s web interface, the user must first set up a login password on the device user interface or configure the interface for use without a password. A user account and internet access are not required for local retrieval. Local data access remains available when the product is operated offline, provided the user can connect to the product or local network.
b. Cloud access
If internet access is available and the user has accepted the applicable terms of use, product data are transmitted to the cloud. A cloud account is optional for the intended use of the product. Registered users can view device data, such as grinding events, device status, recipes and statistics, through the Mahlkönig Sync app. Company users can also access data through the Mahlkönig Sync web dashboard. Access to company data is limited according to the user’s invitation, approval and assigned role.
c. Retrieval and export
Depending on the data and configuration, product data may be accessed directly through the product’s interface, through the Mahlkönig Sync app or through the Mahlkönig Sync web dashboard. The available format and retrieval method depend on the data category and access route.
d. Deletion
Local product data can be deleted by using the factory-reset function available through the product user interface. Cloud account data can be deleted by the user through the Mahlkönig Sync app or website. Account deletion is permanent and cannot be undone. Company administrators may also delete user accounts belonging to their company. A data-deletion request may also be sent to support@mahlkoenig.com.
e. Technical requirements and service quality
Local retrieval requires a Wi-Fi connection and completion of the product-interface login setup described above. Internet access and a cloud account are not required for local retrieval but are required for cloud functionality. Local access is available during operation of the product; no minimum availability level is contractually guaranteed. No scheduled local maintenance windows, local service outages or maximum retrieval delay are specified. Cloud access requires a registered user account and authentication and is subject to the applicable service terms and the availability of internet connectivity.
II. Part B – Information to Xenia Brew-By-Sync (Article 3(2) Data Act)
1. Product covered
This information applies to the following connected Mahlkönig product: Xenia Brew-by-Sync
2. Product data generated
Depending on the machine’s operation and configuration, the Xenia Brew-by-Sync generates and/or makes available the following product data:
| Data category | Specific product data |
| Usage | Operating hours and number of extractions. |
| Extraction | Data relating to the last extraction, including extraction time and beverage weight; the extraction curve is held temporarily in RAM. |
| Live sensor readings | Brew-group temperature, boiler temperature, boiler pressure and live extraction readings, including flow rate where displayed by the machine. |
| Device status | Machine on/off status. |
| Machine settings | Machine settings, on/off timer schedule, language, timezone and serial number. |
| Network information | Wi-Fi network name, machine IP address and MAC address; Wi-Fi connection/disconnection events. |
| Diagnostic events | Grinder connection lost/restored, last grinder request time, clock changes and recent entries in the Wi-Fi event log. |
| Wi-Fi credentials | Wi-Fi connection credentials and related network settings are stored locally on the machine. |
The machine does not collect user names, user accounts or location data. The machine does not transmit telemetry data to a cloud. If internet access is available, it is used only for time synchronization via NTP.
3. Data formats and estimated volume
The product data are available locally through the machine’s web interface. Relevant data relating to the last extraction can also be retrieved by API calls from devices on the same local network.
The machine’s web interface uses standard web technologies. The local HTTP REST API returns data in JSON format, and live status updates are transmitted over a WebSocket connection.
The service page provides an “Export Settings” function that downloads a file named settings.xenia. Although the file uses a proprietary filename extension, its contents are in plain JSON format and can be opened with a text editor. The file contains controller parameters, including machine settings, calibration values and counters, but does not include Wi-Fi settings.
The regular user pages do not provide a dedicated download or export function. There is no dedicated export function for historical data, logs or sensor data, and no CSV or other export formats are supported. Data returned by the API can be displayed in a browser and copied manually. The API response relating to the most recent coffee extraction is small; no dedicated download or save function is provided for that response.
The volume of stored product data is small and limited. Settings and counters are updated in place rather than accumulated over time. Persistent data consist primarily of machine parameters, settings, calibration values, counters and network settings. Transient data include live sensor readings, recent pressure and temperature curves, and temporary diagnostic and Wi-Fi event logs. These transient data are held in RAM and are lost when the machine is switched off or restarted. No usage data are written to the Wi-Fi module’s file system during normal operation.
4. Continuous and real-time generation
The machine provides live sensor readings, including temperatures, boiler pressure and extraction-related readings. Extraction time and beverage weight are available for the last extraction, and the machine displays extraction data in real time. Operating hours and the number of extractions are maintained as usage counters. Network and diagnostic events are generated when the relevant event occurs.
Live sensor data, the last extraction curve and buffered logs are held only in RAM and are lost when the machine is powered off or restarted. No logs are stored permanently.
5. Storage location and retention
Product data are stored locally on the machine. No product data are stored outside the machine in a cloud service or in the Mahlkönig Sync app.
The machine controller’s external EEPROM permanently stores usage counters, settings and the timer schedule. A battery-backed clock retains the date and time. The Wi-Fi module’s internal flash memory stores Wi-Fi credentials and preferences. Live sensor data, the last extraction curve and buffered logs are held in RAM and are lost when the machine is powered off or restarted.
The service page provides a password-protected “Load default settings” function. This function resets certain controller parameters to their factory defaults, including machine, brew-group, boiler, pump and switch settings, start-up timers and operating hours. The extraction counter, scale calibration factor and temperature sensor offsets are retained.
The function does not delete all data stored on the machine. In particular, Wi-Fi settings and credentials are retained and can be deleted separately using the “Forget network” option in the web interface. Certain previously stored controller parameters may also remain in the machine’s internal memory until overwritten.
6. Access, retrieval and deletion
a. Local access
The Xenia provides its own Wi-Fi access point, which users can join using a standard password. The machine’s web interface is then accessible over Wi-Fi. The machine can also be connected to an existing local network, such as the user’s home Wi-Fi network, in which case the web interface can be accessed from other devices connected to that network.
The web interface allows users to view available sensor readings, counters, settings, the Wi-Fi network name, IP/MAC address and diagnostic information. Relevant data relating to the last extraction, including extraction time and beverage weight, can also be retrieved through API calls by devices on the same local network. A compatible grinder, such as the E64, may use this interface to retrieve those values.
Internal technical interfaces are intended solely for machine development and technical or service purposes. They are not designed or documented as regular user-facing means of retrieving product data.
b. Cloud access
The Xenia is not designed to transmit telemetry data to a cloud. The manufacturer cannot obtain the machine’s product data remotely without access to the user’s local network. Internet access, if available, is used only for time synchronization via NTP.
c. Retrieval and export
Users can view available data through the machine’s local web interface. Devices connected to the same local network can retrieve data relating to the last extraction through the API. No cloud-based retrieval or export of Xenia product data is available.
The regular user pages do not provide a download or export function. The only dedicated export function is “Export Settings” on the service page. It downloads a file named settings.xenia, containing plain JSON with controller settings, calibration values and counters. Wi-Fi settings are not included.
Data displayed in the web interface can also be retrieved by devices on the local network through the HTTP REST API in JSON format. The API response relating to the most recent coffee extraction can be displayed in a browser and copied manually, but there is no dedicated download or save function for that response.
There is no dedicated export function for historical data, logs or sensor data, and no CSV or other export formats are supported.
d. Deletion
The following reset and deletion functions are available:
-
- “Load default settings”: This function is available on the service page and is protected by a service password. It resets the controller’s machine, brew-group, boiler, pump and switch settings, start-up timers and operating hours to their factory defaults. The extraction counter, scale calibration factor and temperature sensor offsets are retained. Wi-Fi settings and credentials are retained. Certain previously stored controller parameters may remain in internal memory until overwritten.
- “Forget network”: This function deletes the stored Wi-Fi credentials. All other data remain stored.
- Switching the machine off: This deletes all transient data held in RAM, including live sensor readings, pressure and temperature curves, diagnostic logs and Wi-Fi event logs. All persistent data remain stored.
e. Technical requirements and service quality
Local access requires a Wi-Fi connection to the machine’s access point or to the local network to which the machine is connected. Access to extraction data through the API requires the requesting device to be connected to the same local network.
No cloud connection is required for local access to Xenia product data. No contractual minimum availability level, maximum retrieval delay or scheduled maintenance windows for local data access are specified.
III. Part C – Information on the related services “Mahlkönig Sync / MahlkönigCloud” (Article 3(3) Data Act)
1. Related service and provider
The related digital service is Mahlkönig Sync / MahlkönigCloud. It supports connected-product functions including Grind-by-Sync, which enables automatic grind adjustment based on data from compatible coffee machines or scales. The service also provides cloud-based functions and software/firmware updates. The user initiates the cloud connection during onboarding if cloud functionality is desired; the cloud connection is optional for the intended use of the product.
Provider of the related service: Hemro International AG, Thurgauerstrasse 80, 8050 Zürich, Schweiz.
2. Product data obtained by the related service
When the user enables the cloud connection and accepts the applicable terms of use, the related service may (depending on the product) receive the following product data:
- Number of grinding operations.
- Time / timestamp of grinding operations.
- Grind size or selected grind setting.
- Dosing data.
- Device status.
- Operating hours and maintenance-related information, where generated.
- Software or firmware information.
Xenia-specific clarification: Unlike the coffee grinders described in Part A, the Xenia is not designed to transmit product telemetry to Mahlkönig Sync / MahlkönigCloud. Xenia product data remain on the machine and are not received by the cloud service. The Xenia can make selected extraction data, including extraction time and beverage weight, available to a compatible grinder through the local network/API; this local data exchange does not in itself mean that those data are transmitted to the cloud.
3. Collection frequency and estimated volume of product data
Product data may be collected during each use, on an event basis and continuously, depending on the data category, user settings and product configuration. Device-status information may be generated at start-up and continuously; recipes may be synchronized at start-up; settings may be transmitted when changed; and error records and grinding events may be generated when the relevant event occurs. For Xenia, the product data described in Part B are generated locally.
4. Related-service data generated
Use of the related service may generate data representing user actions and events, including:
- User account creation, including email address, name/profile data and account-creation time.
- Login and authentication events, including authentication data and login time.
- Joining or invitation to a company or household, including membership, role, invitation/approval status and relevant timestamps.
- Creation or modification of company, region or store structures and the time of change.
- Device onboarding and assignment, including device serial number or identifier and time of assignment.
- Pairing of a grinder with a compatible scale or coffee machine, including partner identifier (for example, MAC address or partner token) and pairing time.
- Creation, publication, duplication, modification or archiving of recipes, including recipe parameters, status and time of change.
- Changes to settings, including the new setting and time of change.
- System notifications, including notifications relating to firmware updates and associated device push tokens.
- Device synchronisation and other use of specific service functions.
The estimated volume of related-service data is low, typically a few kilobytes per user action. The total volume depends on usage.
For Xenia, use of the Mahlkönig Sync app may involve app/service events relating to device onboarding, local network setup, recipe creation or modification, access to machine settings and software-update requests.
5. Storage of related-service data and retention periods
Related-service data are stored in the cloud infrastructure of the external hosting provider OVH, in a data centre in Gravelines, France (European Union), including an operational database and an analytics data store. Some data are also stored locally on the connected product or end-user device.
| Storage location | Retention period / rule |
| End-user device | Login-session data are retained only for the session and removed on logout or app deletion. |
| Connected product | Recipes and settings synchronised to the product are retained until overwritten or the product is factory-reset. |
| Cloud / server | Account and profile data are retained until account deletion. Company, household and store-structure data are retained until deletion of the relevant company or household. Device event data have no fixed retention period and are retained for the duration of the service. |
The cloud storage and retention information above applies to data actually received and stored by Mahlkönig Sync / MahlkönigCloud. Xenia product data are not stored in the cloud.
6. User access to and retrieval of related-service data
Registered users can view device data, including grinding events, device status, recipes and statistics, in the Mahlkönig Sync app (household and company versions). Company users can additionally access data through the Mahlkönig Sync web dashboard. Access requires a user account and login. Company data are visible only to users invited to and approved by the company, according to their assigned role (company, region or store level).
For Xenia, users access product data locally through the machine’s web interface, including when they use the Mahlkönig Sync app to reach that interface. Xenia product data are not available through the cloud dashboard unless they are separately transmitted to the service.
7. Use of data by the data holder and third parties
The data holder intends to use readily available data for the following purposes:
- Error analysis.
- Maintenance and servicing.
- Technical support.
- Firmware or software updates.
- Statistical analyses.
The current information is that the data holder does not intend to allow third parties to use the data for purposes agreed with the user.
Xenia-specific limitation: Because the Xenia is not designed to send telemetry data to the cloud, the data-holder uses listed above (error analysis, maintenance and servicing, technical support, software/firmware updates and statistical analyses) should not be understood to include automatic remote use of locally stored Xenia product data.
8. Data holder and contact details
Prospective data holder: Hemro International AG
Address: Thurgauerstrasse 80, 8050 Zürich, Schweiz.
Contact for data-related requests: support@mahlkoenig.com
9. Sharing data with third parties at the user’s request
Where a user wishes to enable data sharing with a compatible third party, the user initiates the connection by pairing the grinder with the relevant coffee machine or scale. For example, a connection with a compatible coffee machine may be initiated in the coffee machine’s app and confirmed in the Mahlkönig Sync app. The user can terminate the pairing in the Mahlkönig Sync app at any time. Once the pairing is removed, data transmission to the cloud for that pairing stops.
For Xenia, selected extraction data (including extraction time and beverage weight) can be retrieved by a compatible grinder through the local network/API. This is a local machine-to-machine data exchange and should be distinguished from transmission to the Mahlkönig Sync / MahlkönigCloud service.
10. Right to lodge a complaint
Users in the European Union may lodge a complaint concerning an alleged infringement of their rights under Chapter II of the Data Act with the relevant competent authority in the Member State of their habitual residence, place of work or establishment, in accordance with Article 38 of the Data Act.
In Germany, the competent authority is the Bundesnetzagentur (Federal Network Agency). Further information and access to the complaint portal are available at: https://www.bundesnetzagentur.de/DE/Fachthemen/Digitales/DataAct/Beschwerdeportal/start.html
For users in other EU Member States, information on the competent authority and the applicable complaint procedure can be obtained from the relevant national data coordinator.
This information concerns complaints under the EU Data Act. The applicability of the EU Data Act and the availability of complaint mechanisms in countries outside the European Union, including Switzerland, the United Kingdom and Türkiye, depend on the applicable legal framework and the circumstances of the relevant product and transaction.
11. Trade secrets
The data may contain trade secrets of Hemro International AG. Hemro International AG may deny access to data that constitutes a trade secret, unless the user can demonstrate that the user needs this data to exercise is/her rights under the Data Act and has taken appropriate measures to protect its confidentiality. In the event of such a denial, Hemro International AG is required to provide a justification and notify the user accordingly.
12. Contract duration and termination of the related service
The related-service contract continues for as long as the user maintains their user account and uses the Mahlkönig Sync app. The user may terminate the related-service contract at any time by deleting their user account. Deleting the Mahlkönig Sync app also ends the user’s use of the related service.
Upon deletion of the user account, access to the related service and to data made available through the service ends.
For Xenia, local product functionality and access to the machine’s web interface do not require product data to be uploaded to the cloud.
13. Personal data
The data generated or processed in connection with the related service may include personal data, such as email addresses and user profile data, company or household membership and role information, device assignments linked to users, and time-stamped usage events associated with a user’s devices. The processing of personal data remains subject to applicable data-protection law, including the GDPR.
Please note our privacy policy on our website.
Xenia-specific personal data note: The machine itself does not collect user names, user accounts or location data.