EU DATA ACT Notice

To protect consumers rights and interest, as well as to fulfill the obligation under EU Data Act, Best Epoch Technology Co., LTD（Hereinafter referred to as “we”,”us” or “AIRROBO”） has launched this document. It will publish necessary pre-contractual information regarding both connected products and related services that AIRROBO acts as the manufacturer or service provider.

According to the Data Act, the following Robot Vacuum Cleaner / Robotic Pool Cleaner are considered connected products. In general, the product data and related service data processed are as follows. Please note that due to differences in the features provided by our various product models and services, the data generated may vary accordingly.

Product Identification

This section describes the basic information of the product.

Product type	Model Number	Related service name	Description of the service
Robot Vacuum Cleaner	T20/T25/T30/E10	AIRROBO	The AIRROBO app is a mobile application for connecting AIRROBO smart robots. You can use this app to control your smart robot and check its current status and related information through the app.
Robotic Pool Cleaner	PC200/PS100	AIRROBO	The AIRROBO app is a mobile application for connecting AIRROBO smart robots. You can use this app to control your smart robot and check its current status and related information through the app.

Product Data and Related Service Data

This section relates to the data that the product can generate through its integrated services and features.

Data Type	Data Format	Estimated Volume	Frequency of generation and collection	Whether generating data continuously and in realtime	On-device or Cloud Storage	Intended Retention Period	Data Nature
Account information	JSON	0.01MB - 5MB per day	Real-time or event-triggered	Data is only generated when an event occurs or a state changes.	Cloud Storage	Will be retained until the user deletes the device or deletes the App account	Device data
Mobile device information (e.g., mobile phones)	JSON	0.01MB - 5MB per day	Real-time or event-triggered	Data is only generated when an event occurs or a state changes.	Cloud Storage	Will be retained until the user deletes the device or deletes the App account	Device data
Product device information	JSON	0.01MB - 5MB per day	Real-time or event-triggered	Data is only generated when an event occurs or a state changes.	On-device /Cloud Storage	Will be retained until the user deletes the device or deletes the App account	Device data

Data Use and Sharing

Entities with access	Purpose of processing	Third-Party sharing	Contract term; How to terminate it?	Who is the holder of the trade secret (if any)?
Best Epoch Technology Co., Ltd. 22F, Building C1, Nanshan Smart Park, No. 1001 Xueyuan Avenue, Nanshan District, Shenzhen, Guangdong Province, China	Necessary for efficient operation, after-sales maintenance, product improvement	Data storage service provider and development framework service provider (Tuya Global Inc.）；	In general, the contract for providing related services will be valid until consumers terminate it or withdraw their consent for data processing. The general way for terminating the contract is to withdraw consent through the AIRROBO App or by contact us at marketing@air-robo.com.	Best Epoch Technology Co., Ltd.

User Rights

The EU Data Act may give you a number of legal rights in relation to the Connected Product data and Related Service data.

(a) Right to access, retrieve and delete

You can view, retrieve or export data via the App interface, or request data export through the privacy settings. You may also unbind devices and select to delete data within the App, or directly delete your account.

If you are unable to access the data through the above methods or you want to delete the data, you can contact us at marketing@air-robo.com and submit data process requests in detail.

(b) Right to share data with third party

You can share data with third parties by using below methods:

You can export data via the App and manually share it with third parties in one go, or continuously share data with third parties through an authorized QR code. For continuous data sharing, the third party is required to access and register on https://platform.tuya.com/cloud, and complete the continuous sharing process in accordance with the operation guidelines.

If you are unable to share the data through the above methods，You can request that the data are shared with a third party by using below contact marketing@air-robo.com.

You acknowledge and agree that any data obtained pursuant to your request shall not be used to develop any connected product that competes with our connected product, nor shall such data be shared with any third party for the purpose of developing a competitive product. Furthermore, you shall not use such data to derive insights about the economic situation, assets or production methods of the manufacturer or, where applicable, the data holder.

(c)Right to lodge a complaint

As a user, you have the right to lodge a complaint if you believe that any of your rights under the Data Act have been infringed. This right ensures that your concerns regarding potential violations of data access, sharing, or usage provisions are heard and appropriately addressed by the responsible oversight body. If you wish to exercise this right or require further assistance, please contact the relevant authority in your Member State.

Please note:

To the extent permitted by law, we are unable to provide access to data that contains confidential data, trade secrets, intellectual property, or other proprietary information.

If you would like to exercise your rights in relation to the personal data that we hold about you, please contact us using the details set out in the Privacy Policy applicable to your product.

EU DATA ACT Notice – AIRROBO DE