EU Data Act Notice

Version: v1.0

Effective Date: 2026.01.20

This Notice is provided in accordance with the EU Data Act (Regulation (EU) 2023/2854) (the "EU Data Act").

1. Data Holder Information

Data Holder: Shenzhen Firstnum E-commerce Co., Ltd

Registered Address: UNIT A ON 20TH FLOOR WANG CHEONG BUILDING NO.251 RECLAMATION STREET KOWLOON H

We act as the data holder under the EU Data Act for the connected products described below.

2. Connected Products Overview

Connected Product means an item that obtains, generates or collects data concerning its use or environment and that is able to communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the user.

The functions of these connected products, as well as details regarding the data they generate and how it is handled, are described in the following sections of this notice.

3. Data Generated/Collected by Connected Products

Data Name

Data Type

Data Processing Purposes

Data Format

Estimated Volume

Whether generating data continuously and in real time

Intended Retention Period

Storage Location

Data Nature

Data Erasure

Security Measures

Trade secret

Data Sharing Interface

Device identification information (serial number/model/hardware version/wireless MAC)

Connected Product Data - Device Identification

Equipment identification, registration binding, after-sales and compliance traceability; Network interface management

JSON/Key Value Pair

Several tens of bytes - several KB/device

Equipment lifecycle; Unbind/Restore Factory and Clear Binding Copy

Local NVRAM/Flash of the device; Synchronize to cloud bound library if necessary

Personal data

Factory reset: Clear configuration and identification associations; After unbinding from the cloud, delete according to the policy (such as 30 days)

Device side access control (administrator/user roles), minimum permissions; Sensitive configuration encryption/ciphertext storage; Local management and interface use HTTPS/TLS; Key operation audit logs.

YES

Firmware/Software Version and Component List（Firmware/Driver）

Product Data - Software Status

Equipment operation and security maintenance (compatibility, vulnerability repair, upgrade decision)

JSON/Text version

Few KB/device

YES

Local permanent

Device local Flash; Cloud log/asset repository (if enabled)

Non personal data

Restore factory and delete local records; Cloud based deletion or anonymization based on support period/legal deadline

YES

System operational status (startup time/runtime duration/remaining battery)

Product Data - Operational Telemetry

Fault diagnosis, stability improvement, and after-sales analysis

JSON/Log Text

Several tens of bytes per event; 0.1-1MB per day

YES

Local rolling for 7-30 days

Local log area of the device; Optional upload to cloud diagnostic database

Non personal data

Local log scrolling coverage; User triggers log clearing/factory reset; Cloud based automatic deletion based on retention period

YES

LAN parameters (LAN IP/subnet)

Product Data - Network Configuration (User Input)

Provide local network connectivity, address planning, and management

JSON/Key Value Pair

Few KB/device

Device lifecycle or user settings

Local NVRAM/Flash of the device; Optional cloud configuration backup

Non personal data

Reset to factory settings and clear; Cloud backup deleted after unbinding/logging out (e.g. 30 days)

YES

DHCP lease and connected terminal list (MAC/hostname/IP)

Product Data - Terminal Connection Data

Network management, troubleshooting, parental control/visitor network management

JSON/SQLite

As the number of terminals increases: 0.5-2KB per terminal; daily variation of 0.1-5MB

YES

Local rolling for 7-30 days (configurable)

Device local running memory+local database; Optional cloud

Personal data

Clear history/restore factory immediately delete; Cloud based automatic deletion based on retention period

YES

Wireless network configuration (SSID/encryption mode/channel)

Product Data - Wireless Configuration (User Input)

Provide Wi-Fi access and performance optimization; Compliance and Interference Management

JSON

Few KB/device

Device lifecycle or user settings

Local NVRAM/Flash of the device

Non personal data

Restore factory deletion; Users can manually clear/reset

YES

Wireless key/credential (Wi Fi PSK)

Product Data - Security Credentials (User Input)

Identity verification and access control ensure device and network security

Encrypt storage/hash (not saved in plaintext)

Several tens of bytes - several KB

Device lifecycle or user settings

Device local secure storage area (Flash/NVRAM)

Personal data

Restore factory deleted key materials; Support users to modify/reset; Cloud does not save plaintext

Sensitive data is stored only in hashed/encrypted form; implement key isolation; strict identity auth for admin interfaces; brute-force attack resistance enabled; TLS transmission adopted.

YES

Device Health Indicators (CPU)

Product Data - Device Health Telemetry

Stability monitoring

JSON

0.1-2MB/day

YES

Local 7-30 days

Local device; Optional cloud

Non personal data

Restore the factory and clear the local environment; Cloud based deletion by retention period

YES

Time and Time Zone/Synchronization Status (NTP Server)

Product Data - System Configuration/Status

Ensure that the logs are consistent with the security protocol time

JSON

Several tens of KB/device

YES

Local rolling for 30 days

Local device

Non personal data

Restore factory clearance; Rolling overlay

YES

Cellular Network Identity Identification (IMSI/IMEI/ICCID/eSIM Profile ID)

Product Data - Core Network Identification

JSON

Several tens of KB/device

Local permanent

Local device

Non personal data

Restore factory clearance; Rolling overlay

YES

Cellular network connection status and telemetry (signal quality/network type/operator name)

Product Data - Network Telemetry

Network selection and optimization, signal display

JSON

Several tens of KB/device

Local rolling for 7-30 days

Local device

Non personal data

Restore factory clearance; Rolling overlay

YES

SMS function data (inbox/outbox, SMS content, sender number, timestamp)

Product Data - Communication Data

Receive operator SMS (balance, verification code) and service messages

JSON

Several tens of KB/device

Local permanent

Local device

Personal data

Restore factory clearance; Rolling overlay

YES

Contact information (name, phone number)

User Data - Address Book

Used for contact recognition and management in SMS or communication functions

JSON

Several tens of KB/device

Local permanent

Local device

Personal data

Restore factory clearance; Rolling overlay

YES

Reference Knowledge 33/1000 Translation Machine · General Field APN configuration (access point name, username, password, authentication type, protocol, roaming protocol)

Product Data - Cellular Network Configuration

Configure the device to correctly access the mobile data network of the operator and realize Internet access

JSON

Several tens of KB/device

Local rolling for 7-30 days

Local device

Non personal data

Restore factory clearance; Rolling overlay

YES

ESIM card PIN code (PIN, PUK)

Security credentials - card lock

Verify user identity, unlock eSIM/SIM card to enable cellular network and prevent unauthorized use

JSON

Several tens of KB/device

Local permanent

SIM card

Personal data

Restore factory clearance; Do not clear

YES

Data means any digital representation of acts, facts or information and any compilation of such acts, facts or information, including in the form of sound, visual or audio-visual recording.

4. User Data Access, Erasure and Portability

Individuals or legal entities using our Connected Products hereinafter referred to as ("Users") have the right, in accordance with the EU Data Act, to request access to, erasure of, or portability of data generated/collected by Connected Products.

These requests can be submitted via [9. Contact and Data Request Channel]

5. Data Sharing and Compliance with Requests for Data

Data generated by our Connected Products may be shared with third parties under Articles 4 to 7 of the EU Data Act, applicable to the following requesters:

5.1 Business-to-Business (B2B) Access Requests

Exclusively based on the User’s explicit consent;

Contracts shall specify: Purpose limitation, Confidentiality obligations, Data security measures, and Prohibition of misuse.

5.2 Business-to-Government (B2G) Access Requests

Based on Article 14-18 of the EU Data Act, data may be shared with public authorities:

Permitted under Article 15 for emergencies or legitimate public tasks (e.g., natural disasters, public safety, pandemics);

Data transmitted via encrypted secure channels with strict purpose binding;

Government entities must submit formal written requests with access logging;

The data minimisation principle applies to all shared datasets.

5.3 Third Parties Requests Submission

Third parties may submit formal requests through [9.Contact and Data Request Channel].

6. Data Security and Protection Mechanism

To ensure the security of data generated by Connected Products manufactured by Shenzhen Firstnum E-commerce Co., Ltd, we implement the following technical and organizational safeguards throughout the processes of data transmission, storage, and access:

l Implement full security encryption during storage and transmission to prevent data from unauthorised access, use or disclosure (such as by using SSL to encrypt many Services).

l Regularly review practices regarding data collection, storage and processing (including physical security measures) to prevent unauthorised access to or tampering with our various systems and data.

l Establish access rights management mechanism to authorize only necessary personnel to access data.

l Conduct security and privacy protection training, testing and other activities to enhance employee awareness of and proficiency in data protection.

l Use international and industry-recognised standards to protect your data and actively pursue relevant security and privacy protection accreditation.

7. Interoperability Notes

We ensure that the recipient can process the data in a structured, commonly used and machine-readable format in order to comply with the interoperability requirements of Articles 33 of the EU Data Act.

8. Data Use Restrictions and Prohibited Purposes

Without Shenzhen Firstnum E-commerce Co., Ltd’s express written authorization or, unless legally required, data shall not be used for the following purposes:

-Development of competing products;

-Reverse engineering of algorithms;

-Targeted advertising or profiling of users.

Any breach of these restrictions may result in legal consequences and revocation of access.

9. Contact and Data Request Channel

Responsible Person: Rock

Email Address:12745310@qq.com

10. Policy Updates

This policy will be updated regularly based on legal requirements and business needs. All updates will be announced through our official website and related channels.

EU Data Act Notice

EU Data Act Notice

1. Data Holder Information

2. Connected Products Overview

3. Data Generated/Collected by Connected Products

4. User Data Access, Erasure and Portability

5. Data Sharing and Compliance with Requests for Data

5.1 Business-to-Business (B2B) Access Requests

5.2 Business-to-Government (B2G) Access Requests

5.3 Third Parties Requests Submission

6. Data Security and Protection Mechanism

7. Interoperability Notes

8. Data Use Restrictions and Prohibited Purposes

9. Contact and Data Request Channel

10. Policy Updates

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