Data Act of the EU Transparency Compliance Statement

Regulatory Basis: EU Data Act (EU) 2023/2854

Applicable Product: Robotic Lawn Mower

 

I. Basic Statement Information

1.1 Corporate Information

Full Corporate Name: Shenzhen Kaiqi Technology Co., Ltd.

Registered Address: 5th Floor, Phase II, Tuobang Industrial Park, Keji 2nd Road, Tangtou Community, Shiyan Subdistrict, Bao’an District, Shenzhen City

Contact Email: support@iroboup.com

Supporting Control App Name: RoboUP

Applicable Product Models: Raccoon 2 SE, T600, T1200pro, etc.

1.2 Statement Scope

This transparency statement fully discloses the rules for data generation, storage, processing, retrieval, portability and third-party sharing of connected robotic lawn mowers under our brand during operation, fully complying with the mandatory transparency compliance obligations set out in the EU Data Act (EU) 2023/2854.

 

II. Types and Descriptions of Data Collected by Robotic Lawn Mowers

This device only collects data necessary for core product functions. No excessive collection, silent background collection or irrelevant background data collection is performed. All collected data is classified into non-personal data and personal data as detailed below:

2.1 Non-Personal Data (Primary Collection Category)

1. Device status data: Battery level, body temperature, motor rotation speed, charging records, firmware version, hardware fault codes, sensor calibration data, blade wear status, waterproof inspection logs;

2. Navigation and lawn mowing map data: Real-time location information, lawn boundary maps, mowing paths, obstacle records, mowing coverage area, working duration, standby status logs;

3. Environmental sensing data: Ambient temperature, rain sensor signals, lawn humidity detection data;

4. Network device data: Wi-Fi connection status, Bluetooth pairing records, anonymized device serial numbers (unlinkable to specific user identities).

2.2 Personal Data (Generated Only After User Logs into the App Voluntarily)

1. User account binding information: App login account ID, email address, nickname, avatar, country code, language preference, time zone information;

2. User device-related data:Smart device information: Device name, device model, device ID, online status, activation time, operating system type and version, device settings, MAC address;Smart device function information: Return base station settings, scheduling settings, map management, work logs, error logs, device passwords, etc.;Device location information: IP address, GPS coordinates;Other data: Wi-Fi name, Wi-Fi password, mobile phone model, operating system, unique device identifier, RoboUP app version number, push notification identifier, log files and mobile network information.

2.3 Prohibited Collection Statement

This robotic lawn mower shall never collect facial images, audio recordings, identity documents, payment information or other sensitive personal privacy data, and no covert privacy collection activities are conducted.

 

III. Data Volume, Real-Time Performance and File Formats

3.1 Daily Average Data Generation Volume

1. Working mode: Maximum daily data volume approx. 15 MB (including map data and sensor operation logs);

2. Standby mode: Daily average data volume below 10 KB (only network heartbeat signals, no continuous map recording);

3. Power-off state: No data generation or data transmission of any kind.

3.2 Real-Time Performance Description

The device generates real-time positioning and sensor data only when operating in mowing mode. All data generation and upload transmission activities are automatically suspended when the device is on standby, in sleep mode or powered off.

3.3 Standard Data Formats

Exportable user data adopts machine-readable structured formats: JSON, CSV; local device logs are stored in TXT format; lawn maps are encrypted binary files (only parsable and viewable via the official App).

 

IV. Data Storage Locations and Retention Periods

4.1 Data Storage Locations

1. Local device storage: Built-in flash memory of the device, temporarily storing temporary operational data such as mowing paths and real-time fault logs;

2. Cloud storage within the EU: Servers deployed in Germany within the EU, complying with GDPR security standards, solely storing user binding information and historical operation records.

4.2 Data Retention Rules

1. Local device data: Automatically erased upon device factory reset; temporary operation logs automatically cleared after 7 days of standby;

2. Non-personal operational cloud data: Retained for a maximum of 24 months for equipment maintenance, firmware upgrades and after-sales fault troubleshooting;

3. User personal account data: Retained only during the validity period of the account. After the user submits a deletion request, all personal data shall be completely erased within 30 calendar days; users may also delete data via account cancellation in the App, which triggers full erasure of personal information;

4. Anonymized device serial number data: Retained throughout the full product lifecycle solely for after-sales warranty traceability, and cannot be linked to specific individual user identities;

5. Mobile phone local data: Erased when the user uninstalls the RoboUP App or clears local data of the RoboUP application.

 

V. Third-Party Data Sharing Rules

5.1 Basic Principles

We shall not sell, rent or trade any user or device data. Personal user data shall only be shared within legal scope and with user consent.

5.2 Compliant Third-Party Processors

1. EU cloud service provider: Only provides data storage services with no independent right to use or disclose data, bound by a compliant data processing agreement complying with GDPR and the EU Data Act;

2. EU authorized after-sales institutions: May only access device fault codes upon user authorization, with no access to lawn maps or user account privacy data.

5.3 Rules for User-Authorized Third-Party Data Access

1. Users may voluntarily initiate or revoke authorization at any time via privacy settings in the App;

2. Authorizable scope is limited to mowing records and device status; users may independently block sensitive data such as historical location records;

3. Customizable authorization validity periods: One-time access, 7 days or 30 days;

4. We reserve the right to immediately terminate third-party data access permissions and pursue compliance liabilities if third parties use data beyond authorized scope.

5.4 General Clause

No undisclosed non-compliant third-party data transmission activities take place.

 

VI. Users' Statutory Rights and Operation Procedures

End users enjoy all legal rights including free data inspection, access, export, deletion and sharing:

6.1 Real-Time Data Inspection Right

Operation Path: Open official App → Device page to view real-time data including device battery level, mowing maps, operation logs and fault information at any time.

6.2 Data Export and Data Portability Right

1. Export via email request: Users send device serial number and bound account to the compliance email; we will deliver full data packages within 7 working days.

6.3 Data Deletion Right

1. Local device data: Execute factory reset via App or physical device button to fully erase local maps and operation logs;

2. Cloud personal data: Submit cancellation request via App privacy portal or compliance email; all personal data will be completely erased within 30 days, with only anonymized hardware traceability records retained.

6.4 Right to File Complaints and Seek Remedies

If users believe our data processing activities violate the EU Data Act, they may contact us via the corporate contact email listed above, or submit a complaint directly to local EU data protection supervisory authorities.

 

VII. Data Security Safeguard Measures

We have established comprehensive technical and organizational security mechanisms to mitigate risks of data leakage, tampering, loss and unauthorized access:

1. Certified to EN18031, all interfaces adopt cryptographic encryption practices;

Isolated independent accounts for cloud data, identity verification required for all data access;

2. Regular security vulnerability patches pushed via firmware to continuously optimize the data security system.

 

VIII. Trade Secret Compliance Statement

Core corporate technical trade secrets including device navigation path algorithms, motor control parameters and obstacle recognition models are protected in accordance with compliant clauses of the EU Data Act. Such restrictions do not impair users’ full legal rights to inspect, export and delete their own usage data, and fully satisfy compliance requirements.

 

IX. Concluding Compliance Statement

The manufacturer hereby solemnly declares that all content contained herein is true, accurate and complete. The full lifecycle of data collection, storage, processing and sharing of our brand’s robotic lawn mower products strictly complies with all requirements of the EU Data Act (EU) 2023/2854. If data processing rules are updated, we will revise this statement promptly, synchronize updated compliance documents to Amazon backend and accept platform and regulatory inspections.