Privacy Notice (Global)

Last Updated: 20260424

Effective Date: 20260424

Overview

This Privacy Notice is issued by Anker Technology (SG) Pte., Ltd. and its affiliates (together, "Anker", "we", "us" and "our") and is addressed to individuals outside our organization with whom we interact, including personnel from our partner companies such as installation service providers ("Installers") and their employees ("you"). For details of the Controller(s) responsible for your Personal Data, please refer to Section (13). Defined terms used in this Privacy Notice are explained in Section (18) below.

If you are a resident of the United States or Australia, please pay particular attention to Section 15, which provides additional information about our data processing practices specific to your jurisdiction.

This Privacy Notice applies to the eufy Partner application (the "App"), a mobile application designed to support Installers who are authorized partners of eufy in providing installation, device management, customer management, after-sales service, and related business operations for eufy products. The App is intended for business use by Installers (which are corporations) and their authorized employees, and is not directed at individual consumers.

We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our App prior to the change becoming effective. All changes shall be effective from the date of publication unless otherwise provided. We encourage you to periodically review this page for the latest information on our privacy practices.

List of Contents

  1. Collection of Personal Data
  2. Creation of Personal Data
  3. Categories of Personal Data We Collect and Process
  4. Purposes of Processing
  5. Legal Bases for Processing
  6. Disclosure of Personal Data
  7. International Transfer of Personal Data
  8. Data Storage and Security
  9. Third-Party SDKs and Services
  10. App Launch and Background Services
  11. Data Retention
  12. Your Privacy Rights
  13. Details of Controller
  14. Minors' Privacy
  15. Supplemental Terms – Jurisdiction-Specific
  16. Links to Other Websites
  17. Contact Us
  18. Definitions

Annex I – Details of Processing

1. Collection of Personal Data

We collect Personal Data at different stages during your use of the App:

We do not collect any Personal Data before you have reviewed and agreed to this Privacy Notice.

When you use our App, we may collect or obtain Personal Data about you from the following sources:

1.1 Data you provide to us: We obtain Personal Data when you provide it to us directly through the App. For example, when you register an account on our platform, we collect your account registration information such as your account name, email address, phone number, and password. When you submit business credentials for onboarding as an Installer, we collect the information included in your application. When you provide bank account details for revenue-sharing settlement, we collect the financial information you submit. We principally accept corporate bank account information for settlement purposes. Where an Installer chooses to provide a personal bank account instead, we strongly recommend using a corporate account. We process personal bank account information only where an Installer voluntarily provides it.

1.2 End user information provided by Installers: In the course of using the App for customer management, device registration, and after-sales service, Installers may provide us with certain personal information of end users, such as end users' email addresses. You represent and warrant that, prior to providing any end user personal information to us through the App, you have: (a) clearly informed the relevant end user of the purposes for which their personal information will be collected and used, including that such information will be shared with Anker through this App; (b) obtained all necessary consents from the end user as required by applicable law; and (c) ensured that you are legally entitled to provide such information to us. You shall be solely responsible for any failure to comply with the foregoing obligations, and you agree to indemnify and hold Anker harmless from any claims, losses, or liabilities arising from such failure. We use such end user information for the purposes of device registration, service record management, and providing after-sales support.

1.3 Account creation details: We collect or obtain Personal Data when you register or create an account on the App, such as your account name, email address, phone number, password.

1.4 Relationship data: We collect or obtain Personal Data in the ordinary course of our business relationship with you, which is strictly limited to ordinary business purposes.

1.5 App usage data: We collect or obtain Personal Data when you use the App or its features, such as your customized settings (e.g., language preferences) and interaction data.

1.6 Device and technical information: We automatically collect certain technical information when you use the App, including:

This information is collected to maintain normal App operations, ensure system compatibility, and for security and diagnostic purposes.

1.7 Camera and photo library access: With your permission, the App may access your device camera to scan device QR codes for device registration and to take photos for uploading attachments. The App may also access your photo library to select images for uploading attachments. We do not access your camera or photo library for any other purpose.

2. Creation of Personal Data

We also create Personal Data records about you in certain circumstances, such as records of your interactions with us and details of your past interactions with us. We may also combine Personal Data collected through the App, including where such data are collected from different devices.

3. Categories of Personal Data We Collect and Process

3.1 Installer account information: account name, email address, phone number, password, and the company name you are employed with or represent.

3.2 Installer financial information: bank account details provided for revenue-sharing and settlement purposes. We principally accept corporate bank account information. Personal bank account information is processed only where voluntarily provided by the Installer, and we recommend using a corporate account.

3.3 End user information: end users' email addresses, as provided by Installers for the purposes of device registration, customer management, and after-sales service support.

3.4 Account and identity data: user ID and account creation time.

3.5 Device and technical information: device model, manufacturer, and version; mobile operating system version; device identifiers (including Android ID and device serial number); installed applications list (for system compatibility detection only); IP address; Wi-Fi SSID; and App log data and crash reports.

3.6 Customized settings: language preferences, profile preferences, and other user-configured settings within the App.

3.7 Camera and photo data: photographs taken using the App's camera function (for QR code scanning and attachment uploads) and images selected from your photo library (for attachment uploads). These images are collected solely for the specific function you initiate and are not used for any other purpose.

4. Purposes of Processing

We process your Personal Data as necessary for the provision of features of our App and the performance of our business relationship with you and/or your employer. Specifically, we process Personal Data to enable the following:

4.1 Facilitate Installer onboarding, including processing your application to become an authorized eufy Installer partner, verifying your identity and business credentials, and managing your account registration and login;

4.2 Provide and manage device installation, registration, and related services for eufy products, including recording sales data and managing device information;

4.3 Enable customer management functions within the App, allowing Installers to manage end user records for the purposes of device registration, service tracking, and after-sales support;

4.4 Process revenue-sharing settlements and payments between Anker and Installers, including verifying bank account information and facilitating financial transactions;

4.5 Provide after-sales service and technical support to Installers and, through Installers, to end users, including device maintenance, troubleshooting, and warranty service coordination;

4.6 Operate, maintain, and improve the App, including developing software updates, fixing bugs, analyzing App performance and stability, ensuring system compatibility with your device and operating environment, and ensuring the App functions properly;

4.7 Ensure network and information security, including the prevention, detection, and protection against fraud, unauthorized access, criminal activities, and other security threats;

4.8 Comply with applicable laws, regulations, and legal requirements, including responding to lawful requests from governmental authorities and fulfilling tax and commercial reporting obligations;

4.9 Use device identifiers and installed application information to ensure App compatibility with your device and system environment, to detect and prevent fraudulent activities, and to provide technical support and troubleshooting services;

4.10 Enforce our contractual rights, including the applicable terms of service, and to resolve disputes, carry out our obligations, and protect the rights and interests of Anker and third parties;

4.11 Communicate with you regarding your account, the App, service updates, and other matters related to your use of the App;

4.12 Fulfill any other purpose for which you provide your Personal Data, or for which you have otherwise consented.

We may combine data we obtain about you for the purposes described above.

5. Legal Bases for Processing

The legal bases on which we rely for the Processing of Personal Data are as follows:

5.1 Perform our contractual services or prior to entering into a contract with you: If you use our App or if you contact us to request our services, we use your Personal Data to provide you with these services, including for account and contract management, to facilitate Installer onboarding, revenue-sharing settlements, and customer support, and to process payment for our services or with information that may be relevant for you to decide on whether you want to use our services.

5.2 Justified by our legitimate interests: The usage of your Personal Data may also be necessary for our own business interests. For example, we may use some of your Personal Data to operate, maintain and improve the App, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property and services, technology assets and business; enforce our terms, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.

5.3 Consent: In some cases, we may ask you to grant us separate consent to use your Personal Data. In this case, you can revoke your consent at any time with effect for the future.

5.4 Compliance with legal obligations: We are obligated to collect or retain certain Personal Data because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide Personal Data on request.

You can find more information on the legal bases in the table in Annex I.

6. Disclosure of Personal Data

We may also share, transmit, disclose, grant access to, make available, and provide Personal Data with and to third parties, as described below.

6.1 You and, where appropriate, your appointed representatives.

6.2 Anker affiliates: We share Personal Data amongst the legal entities that make up the Anker group, for legitimate business purposes and the operation of the App for you, in accordance with applicable law. These legal entities may use your Personal Data in the manner described in this Privacy Notice.

6.3 As required by law: We may disclose Personal Data to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe in good faith that such action is necessary:

(1) in connection with the establishment, exercise, or defense of legal claims;

(2) to comply with laws or to respond to lawful requests and legal process;

(3) to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;

(4) to detect, suppress, or prevent fraud or other criminal activity; or

(5) as otherwise required by applicable law.

6.4 Third-party Processors: We share Personal Data with third-party contractors and service providers subject to reasonable confidentiality terms, such as cloud hosting providers and payment service providers, subject to the requirements noted below in this Section (6). These Processors support us in processing the types of Personal Data described above in Sections (1) – (3), and for the purposes described in Section (4). They are only authorized to process that information as necessary and as directed by us.

6.5 Independent advisors: We may disclose Personal Data to our independent advisors such as accountants, auditors, consultants, lawyers, and other outside professional advisors to Anker, subject to binding contractual or statutory obligations of confidentiality.

6.6 Corporate transactions: If Anker is involved in a corporate business transaction, such as a merger, acquisition, or sale of all or a portion of our company assets, we may disclose Personal Data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. If Anker completes such a corporate business transaction, you will be notified via email and/or a prominent notice on our App, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership.

6.7 Other disclosures: We may also disclose your Personal Data to any other third party or publicly with your prior consent or direction.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

Please note that third parties may process your Personal Data in accordance with their own privacy policies and terms of service, over which we have no control.

7. International Transfer of Personal Data

7.1 Because of the international nature of our business, we transfer Personal Data within the Anker group, and to third parties as noted in Section (6) above, in connection with the purposes set out in this Privacy Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements than those that apply in the country in which you are located, including China.

7.2 In the event of a transfer by Anker, we ensure that international transfers of your Personal Data are made pursuant to appropriate safeguards, such as:

(1) Ensuring that the Personal Data is only transferred to countries recognized as Adequate Jurisdictions. The current adequacy decisions can be found here. There is currently no adequacy decision for China; or

(2) The transfer is made pursuant to appropriate safeguards, such as Standard Contractual Clauses adopted by the European Commission or UK Secretary of State (as applicable) in connection with appropriate supplementary measures. The decision and the template text of these Standard Contractual Clauses can be found here.

7.3 If you wish to enquire further about these safeguards, including the specific contracts entered into, please contact us using the details set out under Section (17) of this Privacy Notice.

7.4 Please note that when you transfer any Personal Data directly to any Anker entity established outside the UK, Switzerland, or the EEA (as applicable), this is considered a direct collection, to which the safeguards mentioned in this Section (7) may not apply. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Privacy Notice.

8. Data Storage and Security

8.1 Personal Data collected through the App is stored on servers located in Frankfurt, Germany. For information on transfers of Personal Data outside the EEA, the UK, or Switzerland, please refer to Section 7 above.

8.2 We implement appropriate technical and organizational measures designed to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:

(1) Transmission security: All data transmitted between the App and our servers is encrypted using industry-standard encryption protocols;

(2) Storage security: Sensitive Personal Data stored in our databases is encrypted using industry-standard encryption algorithms;

(3) Access controls: We restrict access to Personal Data to authorized personnel who have a legitimate business need to access such information;

(4) Operational logging: We maintain operational logs for a period of fifteen (15) days for the purposes of security monitoring and incident investigation. Such logs are automatically deleted after the retention period expires.

8.3 While we take reasonable steps to protect your Personal Data, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your Personal Data.

8.4 In the event of a data breach that affects your Personal Data, we will notify you and the relevant supervisory authority in accordance with applicable law, including within 72 hours of becoming aware of the breach where required under applicable law.

9. Third-Party SDKs and Services

Third-Party SDKs and Services

To ensure the proper operation and functionality of the App, we integrate certain third-party software development kits ("SDKs") and services. These third-party technologies may collect and process limited technical data as described below. We take reasonable steps to ensure all third-party SDK providers process data in accordance with applicable law.

The integration of third-party SDKs does not alter our commitments regarding the use, disclosure, or protection of your Personal Data as set forth in this Privacy Notice. We do not permit third-party SDK providers to use data collected through the App for their own independent marketing or advertising purposes.

Where third-party SDK providers transfer Personal Data outside the EEA, UK, or Switzerland, such transfers are subject to appropriate safeguards, including Standard Contractual Clauses or adequacy decisions, as applicable. You may request further details about the specific safeguards in place by contacting us at dpo@anker.com.

10. App Launch and Background Services

10.1 Application Launch

The App will only launch when you actively open it. We do not implement any mechanism that would cause the App to:

You retain full control over when the App is launched on your device.

10.2 Background Services

To provide optimal functionality and ensure efficient use of your device's resources, the App utilizes the following background service:

Google ML Kit Background Task Scheduler (JobInfoSchedulerService)

This background service does not:

This background task scheduler is a standard component of Google ML Kit, widely used across the mobile application industry. It is not a custom implementation developed by Anker.

11. Data Retention

11.1 We have implemented processes designed to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

(1) we will retain Personal Data in a form that permits identification only for as long as:

(a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

(b) your Personal Data are necessary in connection with the lawful purposes set out in this Privacy Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between you and us, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

(2) the duration of:

(a) any applicable limitation period under applicable law (i.e., either any statutory retention periods as required by the law of the applicable region (e.g., the European Union or a member state of the EEA), or any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

11.2 During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

11.3 Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

(a) permanently delete or destroy the relevant Personal Data; or

(b) anonymize or de-identify the relevant Personal Data.

12. Your Privacy Rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

12.1 The right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our services, if you do not provide us with your Personal Data — e.g., we might not be able to process your requests without the necessary details);

12.2 The right to request access to, or copies of, your Relevant Personal Data, together with additional information, such as information regarding the nature, Processing and disclosure of those Relevant Personal Data;

12.3 The right to request rectification of any inaccuracies or incompleteness in your Relevant Personal Data;

12.4 The right to request, on legitimate grounds, restriction of Processing of your Relevant Personal Data (limiting the purposes for which we Process your Personal Data);

12.5 The right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

12.6 The right to request the deletion or removal of your Relevant Personal Data where there is no other legal basis for us to keep using it. Please note that we may not be able to immediately remove the information from the backup system due to applicable laws and regulations or technological limitations. If this is the case, we will isolate your Relevant Personal Data from any further processing until the backup can be deleted or be anonymized / de-identified;

12.7 Where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent at any time (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal).

12.8 Under the GDPR, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

(1) the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR;

(2) the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes;

(3) the right to lodge complaints regarding the Processing of your Relevant Personal Data with a competent Data Protection Authority (in particular, the UK Information Commissioner's Office, or the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred. If you live in Germany, the relevant Data Protection Authority is the "Bayerisches Landesamt für Datenschutzaufsicht", Promenade 18, 91522 Ansbach). However, we encourage you to first contact us so that we can together solve any concerns you may have.

This does not affect your statutory rights.

12.9 To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (17) below. Please note that:

(1) in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and

(2) where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

13. Details of Controller

For the purposes of this Privacy Notice, the relevant joint Controllers are:

Controller entity

Contact details

Anker Technology (UK) Ltd.

205 Kings Road, Fairgate House, Suite B, B11 2AA Birmingham

Anker Innovations Technology Co., Ltd

Room701, Bldg 7, Zhongdian Software Park, 39 Jianshan Road, Hi-tech Zone, Changsha City, Hunan Province, China

Shenzhen Oceanwing Smart Innovations Technology Co., Ltd

B701-705, Jianxing Tech Bldg, Xinxing industrial park, 3151 Shahe West Road, Nanshan District, Shenzhen City

Fantasia Trading LLC

5350 Ontario Mills Pkwy, Suite 100, Ontario, CA 91764

Anker Technology (SG) Pte., Ltd.

112 Robinson Road #03-01 Robinson 112, Singapore

Anker Innovation Australia Pty. LTD.

Suite 103 44 Lakeview Drive Scoresby VIC 3179

Anker Innovations Canada Co., LTD

201, 856 Homer Street, Vancouver, BC

For general enquiries, or to exercise any of the rights set out in this Privacy Notice, please contact dpo@anker.com.

With respect to the Processing of Personal Data through the App, the entities mentioned above can probably both access your Personal Data and decide on the means and purposes of the Processing, subject to the requirements and restrictions of applicable laws. Therefore, they are jointly responsible for the Processing of your Personal Data.

14. Minors' Privacy

The App is not directed at, nor intended for use by, individuals under the age of 18 ("Minors"). We do not knowingly collect or solicit Personal Data from Minors. By using the App, you represent that you are at least 18 years of age.

If we become aware that we have inadvertently collected Personal Data from a Minor without verifiable parental consent, we will take immediate steps to delete such information from our records and terminate the associated account. If you are a parent or guardian and believe that we may have collected Personal Data from a Minor, please contact us immediately using the details provided in Section 17 below.

15. Supplemental Terms – Jurisdiction-Specific

15.1 UNITED STATES

15.1.1 These following disclosures supplement the information contained in the main body of our Privacy Notice by providing additional information about our Personal Data processing practices relating to individual residents of certain states in the United States, including the states of California, Nevada, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia in the United States. For a detailed description of how we collect, use, disclose, and otherwise process Personal Data, please read the main body of our Privacy Notice.

15.1.2 Collection and Use of Personal Data

(1) Personal Data

(A) As described in more detail in Section (3) above, we collect, and have collected in the preceding 12 months, the following categories of Personal Data:

(a) Identifiers, such as account name, phone number, email address, user ID, and online identifiers.

(b) Customer records, such as contact information and account information.

(c) Commercial information, such as transaction records, service records, and revenue-sharing records.

(d) Internet / network information, such as device type, manufacturer, and model, operating system, IP address, device identifiers (including Android ID and device serial number), installed applications list, Wi-Fi SSID, and App log data and crash reports.

(e) Professional / employment information, such as employer and company name.

(f) Sensitive personal data, such as account credentials (email address in combination with a password) and bank account information (where a personal account is voluntarily provided).

(B) As described in Section (1) above, we collect this Personal Data directly from you, and automatically when you interact with the App.

(C) We collect Personal Data from and about you for a variety of purposes. For example, we use Personal Data to facilitate Installer onboarding; to manage device registration, customer management, and after-sales service; to process revenue-sharing settlements; and to operate, maintain, and improve the App. For more information about our use of Personal Data, please refer to Section (4) above.

(2) Sensitive Personal Data

(A) The following Personal Data elements we collect or are otherwise processed in connection with the App may be classified as "sensitive" under certain privacy laws ("Sensitive Personal Data"):

(a) Account credentials (email address in combination with a password).

(b) Bank account information (where a personal account is voluntarily provided by an Installer for settlement purposes; we principally accept corporate bank account information).

(B) We only use or disclose Sensitive Personal Data where reasonably necessary and proportionate, and where permitted by law, for the purposes of performing services you have requested, verifying and improving the services we provide, detecting security incidents, fraud and other illegal actions, and ensuring the physical safety of natural persons. We do not sell Sensitive Personal Data or process or otherwise share Sensitive Personal Data for the purpose of targeted advertising.

(C) Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of Sensitive Personal Data (as described in the Your Additional U.S. Privacy Choices section below).

(3) Deidentified Information

We may at times receive, or process Personal Data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

15.1.3 Keep Your Information Safe and Secure

(1) We implement industry-standard security measures to continuously protect your information. If we detect something risky that we think you should know about, we will notify you and help guide you through steps to stay better protected.

(2) We work hard to protect you and Anker from unauthorized access, alteration, disclosure, or destruction of information we hold, including:

(A) We use encryption to keep your data private while in transit and at rest.

(B) We offer security features to help you protect your account.

(C) We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.

(D) We restrict access to personal information to authorized employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations.

15.1.4 Personal Data Disclosures, Sales, and Targeted Advertising

We do not sell, rent, or share your Personal Data with third parties for their own commercial or marketing purposes, and we have not done so in the preceding twelve (12) months. We do not engage in targeted advertising or cross-context behavioral advertising through the App.

We may disclose Personal Data within the Anker group for internal administrative and operational purposes as described in Section (6). We may also share limited technical data to third-party SDKs and services as described in Section (9).

Please note we do not sell the Personal Data of individuals we know to be less than 18 years of age or share such information for targeted advertising purposes. In addition, we do not sell Sensitive Personal Data, and we do not process or otherwise share Sensitive Personal Data for the purpose of targeted advertising.

15.1.5 Automated Decision-Making and Profiling

We do not conduct automated processing of Personal Data for the purposes of evaluating, analyzing, or predicting an individual's personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.

15.1.6 Your Additional U.S. Privacy Choices

(1) Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

(A) Right to Know: The right to confirm whether we are processing Personal Data about you and, under California and Oregon law only, to obtain certain personalized details about the Personal Data we have collected about you, including: the categories of Personal Data collected; the categories of sources of the Personal Data; the purposes for which the Personal Data were collected; the categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom this Personal Data were disclosed.

(B) Right to Access & Portability: The right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format.

(C) Right to Correction: The right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing.

(D) Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain Sensitive Personal Data.

(E) Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share Personal Data for certain targeted advertising purposes. As stated above, we do not engage in targeted advertising through the App.

(F) Right to Opt-Out of Sales: The right to direct us not to sell Personal Data to third parties. As stated above, we do not sell Personal Data.

(G) Right to Deletion: The right to have us delete Personal Data we maintain about you (subject to certain exceptions).

(2) Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.

(3) Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by sending us an email at: dpo@anker.com.

Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

(4) Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent's authority to act on your behalf. In order to verify the authorized agent's authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your account name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request.

(5) Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.

15.2 AUSTRALIA

The following disclosures supplement the information applicable to residents of Australia. We strictly comply with relevant Australian laws and regulations to ensure transparency in the collection, use, and sharing of your information. These laws include the Privacy Act 1988, the Spam Act 2003, and other applicable privacy and data protection legislation.

15.2.1 How We Protect Your Personal Information

(1) All personal information we hold will be processed and stored in compliance with obligations under the Privacy Act 1988. We take reasonable steps to:

(A) Implement practices, procedures, and systems to ensure legal compliance and address compliance-related inquiries/complaints.

(B) Maintain the accuracy, completeness, and currency of collected personal information.

(C) Secure information against misuse, interference, loss, or unauthorized access through physical and technological safeguards.

(D) Destroy or permanently de-identify information when no longer needed for legal/business purposes.

(2) If you identify any security vulnerabilities, please notify us immediately. We adhere to all mandatory data breach notification requirements outlined in the Privacy Act.

15.2.2 Complaints

To lodge a complaint about our handling of personal information, please submit written details via post or email using the contact information in this Privacy Notice. We will respond to formal complaints within 30 days.

If unsatisfied with our resolution, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC). For additional details about OAIC, you may:

(A) Visit the Office of the Australian Information Commissioner (OAIC) website: www.oaic.gov.au

(B) Call: 1300 363 992 (local call charges may apply)

16. Links to Other Websites

This Privacy Notice applies only to the eufy Partner App. The App may in the future include links to websites or online services that are operated by other companies not under the control of Anker. If you provide or submit Personal Data to those websites or online services, the privacy policies of those websites or online services apply to your Personal Data. We encourage you to carefully read the privacy policies of any website you visit.

17. Contact Us

17.1 If you have questions or concerns with respect to this Privacy Notice or our privacy practices, you may contact us at dpo@anker.com.

17.2 We will review all inquiries and concerns and respond to you within thirty (30) days.

18. Definitions

18.1 "Adequate Jurisdiction" means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

18.2 "App" means the eufy Partner mobile application operated or maintained by us or on our behalf.

18.3 "Controller" means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

18.4 "Data Protection Authority" means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

18.5 "EEA" means the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein).

18.6 "GDPR" means the General Data Protection Regulation (EU) 2016/679.

18.7 "Installer" means a business entity authorized by eufy to provide installation, maintenance, and after-sales services for eufy products, and which has registered an account on the App.

18.8 "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

18.9 "Process", "Processing" or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

18.10 "Processor" means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

18.11 "Relevant Personal Data" means Personal Data in respect of which we are the Controller.

18.12 "Standard Contractual Clauses" means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.

Annex I – Details of Processing

Processing Activity

Personal Data Processed

Purposes

Legal Basis

Account registration and login

Email address, account name, phone number, password

Provision of the App's services and account management

The Processing is necessary for entering or performing a contract with you (Art. 6(1)(b) GDPR)

Identity verification

Email address

Verifying Installer identity and business credentials

The Processing is necessary for entering or performing a contract with you (Art. 6(1)(b) GDPR)

Device registration, customer management, and after-sales service

Installer's name, phone number, email address, company name; end users' email addresses

Providing device installation, registration, customer management, and after-sales support

The Processing is necessary for the performance of a contract (Art. 6(1)(b) GDPR) between Anker and the Installer; the Installer warrants that it has obtained the necessary legal basis to share end user data with Anker, including consent where required

Revenue-sharing settlement

Personal Bank account information (if provided voluntarily by installer)

Processing payments and revenue-sharing between Anker and Installers. However, we strongly recommend installers to provide corporate account for this purpose.

The Processing is necessary for entering or performing a contract with you (Art. 6(1)(b) GDPR)

App operation and improvement

Device model, manufacturer, version, OS version, device identifiers (Android ID, device serial number), installed applications list, IP address, Wi-Fi SSID, App log data, crash reports, customized settings

Operating, maintaining, and improving the App; ensuring system compatibility; diagnosing or fixing technology problems

Our legitimate interests in providing a secure, needs-based App (Art. 6(1)(f) GDPR)

System compatibility and fraud prevention

Device identifiers, installed applications list

Ensuring App compatibility with user devices; detecting and preventing fraudulent activities; providing technical support

Our legitimate interests in ensuring the safety and compatibility of our services (Art. 6(1)(f) GDPR)

Network and information security

Device information, IP address, App log data

Ensuring the security of the App and preventing fraud

Our legitimate interests in ensuring the safety of our services (Art. 6(1)(f) GDPR)

Third-Party SDK processing (React Native)

Device identifiers (Android ID), installed applications list, device model, OS version, App performance data

Core App framework operation and performance monitoring

Our legitimate interests in operating the App (Art. 6(1)(f) GDPR)

Third-Party SDK processing (Google ML Kit)

Device identifiers, scan usage statistics, performance metrics, App usage data

QR code/barcode scanning functionality and performance optimization

Consent (Art. 6(1)(a) GDPR) when you use the scanning feature

Camera and photo library access

Photographs, QR code scans

Device QR code scanning and attachment uploads

The Processing is based on your consent (Art. 6(1)(a) GDPR)

Communication

Email address, account name

Communicating with you regarding your account, service updates, and related matters

The Processing is necessary for entering or performing a contract with you (Art. 6(1)(b) GDPR)

Legal compliance

As required

Compliance with applicable laws, tax and regulatory obligations

The Processing is necessary to fulfil a legal obligation (Art. 6(1)(c) GDPR)