Effective as of: [11.10, 2025]

Guangdong Wankezi Intelligent Control Technology Co., Ltd. and/or its affiliates and subsidiaries (collectively “we”, “us” or “our”) know how important privacy is to our business customers, business partners, and their employees. We respect your privacy when handling your Personal Data. This privacy notice (“Privacy Notice”) describes the types of data (including Personal Data) we may collect about you, how we process and use such Personal Data, and your rights in relation to our use of such Personal Data, in connection with your use of any of our business-to-business (“B2B”) products and services, and your interactions with us in B2B scenarios.

By visiting our website, using our B2B products and services and/or by providing us with your information in B2B scenarios, you are accepting and consenting to the practices described in this Privacy Notice.

About this Privacy Notice

For the purposes of applicable data protection laws, we are a data controller in respect of your Personal Data.

This Privacy Notice applies to all of our business customers and business partners, and individuals from such businesses acting in their professional capacity in their use of our B2B products and services.

To find out more, click on any of the sections below:

· Personal Data we collect about you

· Use of your Personal Data

· Disclosure of your information to third parties

· Third party links

· International transfers of Personal Data

· Security of your Personal Data

· Retention of your Personal Data

· Your rights

· Use of cookies

· Additional information for individuals in the EEA

· Additional information for individuals in the US

· Contacting us

It is important that you check back often for updates to this Privacy Notice. We may update this Privacy Notice to reflect changes in how we collect and use your Personal Data or changes in relevant laws. When we do so, we will update the Effective Date above. We will notify you by sending a message to you or by prominently posting a notice on our website if we make material changes to our Privacy Notice.

Personal Data we collect about you

We may collect and process the following Personal Data about you. “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you.  

· Information that you provide to us. This includes information about you that you provide to us by filling in forms, submitting requests, creating user accounts, engaging with us at any events or trade shows, ordering our products and services, or by communicating with us (whether face-to-face, by phone, online, e-mail or otherwise). This information may include:

o your full name, company name, and job title;

o your business card;

o your contact information, including your email address, phone number, mobile number and address;

o products that you are interested in;

o project address of your products.

o Log in information: username, password, nickname

o billing information, mailing address, payment information and shipping information; and

o any documents or other communications you provide to us, including but not limited to any information contained in the documents or files uploaded by you onto our products.

· Information we collect or generate about you. This includes:

o details about your usage of the products that we supply to you, such as your device data and usage habits, including:

· Device identifiers: such as Serial Number, IP address and MAC address, IMIS, IMEI, MEID, Android ID;

· Device and system information: device hardware information(device model), system information (such as, setting country/region, system version), and rough city location data derived from IP address；

· Connection information: Bluetooth and Wi-Fi information, such as WLAN name and connection status, SSID, BSSID.

· Usage data: data about your usage of system functions, applications and smart services, and device activation and registration details.

· Equipment  debugging information: installation configuration parameters, installation failure log, basic operation and verification information, user input on configuration, etc.

· Device property data: basic status Information(e.g., power switch status, operating mode, device role configuration, device identifier),  environmental monitoring data(e.g., temperature data), core function settings, scenario-based settings(e.g., vacation mode configuration), Security Verification Information etc.

· Schedule management information: if you opt in for the function of schedule management, we will collect the schedule management information of your device, such as schedule type, schedule name, device involved, scheduled on/off time, target temperature, fan speed.

· Statistical data: aggregated statistical data about our users' activation and usage patterns, such as the total number of device activation, number of new activations, total number of account registrations, number of new registrations, activation rate, registration rate, and application usage ratio within a specific geographic area during a specific time period;

The above information is used for analysis and the further improvement on our products and services. we will not use it to create a specific profile of your habits when using a device.

o error logs, error codes, error descriptions, system operation status of equipment and other information relating to faults that you experienced on your products; and

o where we provide after-sales services to you, recordings of phone conversations between you and our staff.

· Information we obtain from other sources. This includes:

o information from social media networks;

o information obtained from other providers of products, services, websites and applications that we partner with;

o other commercially or publicly available sources; and

o if you take part in market research organized and/or sponsored by/on behalf of us， we may also collect information from your responses, in accordance with the privacy policies applicable for such market research.

· In all cases we will check that the third party is allowed to share the relevant data with us and that our use of that data complies with applicable data protection laws.

· We do not intend to collect any special category of Personal Data or sensitive Personal Data about you.

· You can choose not to provide us with certain information, but please note that you might not be able to use some of our services in respect of parts where you decide not to provide information.

Use of your Personal Data

Your Personal Data may be collected, stored, processed or otherwise used by us in the following ways and for the following purposes:

· to deliver and manage our products and services, including to provide account services, to process and ship your order;

· to provide any after-sales support, software updates, maintenance services, and technical support for our products and services;

· to contact you in relation to our products and services (including to inform you of any update or change in relation to our products and services);

· to keep our products and services secure and prevent crime and fraud;

· to protect against and prevent other legal or information security risks;

· to consider and handle any questions, requests or complaints that you raise;

· to improve or personalise our products and services or develop new ones;

· to conduct market research in relation to our products and services;

· to facilitate internal purposes such as auditing, data analysis, and research to improve our products, services, user experience and customer communications;

· to comply with legal and regulatory obligations and to exercise or defend legal rights; and

· to send you information about our products and services and help to make that information more relevant to you. We may require your consent for some of these marketing activities. In such cases where consent is required, we will only conduct the marketing activity if we have obtained your consent. We will ensure that you can exercise your right to opt out or withdraw your consent at any time.

We do not sell or otherwise disclose Personal Data you have provided to us, except as described in this Privacy Notice, or as disclosed to you at the time of data collection. If you choose not to have your Personal Data disclosed, we will respect your choice.

We are allowed to use your Personal Data in these ways because one or more of the following apply (where such legal basis apply under applicable laws):

· you have given your consent to certain types of processing.

· the processing is necessary to fulfil a contract that we have in place with you, for example, to deliver the products or services you have purchased from us;

· we have legal and regulatory obligations that we must discharge;

· the processing is necessary in order for us to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

· the processing of your Personal Data is in line with our legitimate interests, such as:

o conducting market research in relation to our products and services, whereby legally permissible;

o improving the products and services that we provide;

o making our communications or the content that we provide more relevant to you;

o minimising our risks, for example, in relation to credit or fraud; or

Disclosure of your information to third parties

We may disclose your Personal Data within the affiliates of our company in one or more of the circumstances described below:

· to help us provide our products and services;

· where we market products and services provided by different affiliates of our company; and

· for the purposes for which we have collected your Personal Data or a directly related purpose.

We take steps to ensure that the Personal Data is accessed only by employees of such affiliates that have a need to do so for the purposes described in this Privacy Notice.

We may also share your Personal Data with third parties:

· if we sell any of our business or assets, in which case we may disclose your Personal Data to the prospective buyer for due diligence purposes and on completion of the sale;

· to third-party service providers or contractors (for example, our cloud service providers) for the purposes of providing services to us. We are responsible for their use of your data. They are subject to confidentiality requirements and they will only use your Personal Data as described in this Privacy Notice;

· to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, establish, exercise or defend our legal rights; or

· to professional services providers such as our solicitors and auditors.

Third party links

The website for our products and services may contain links to third party websites. We are not responsible for the privacy practices of such third party or content provided on such other third party websites. If you have any questions about how these third parties use your Personal Data, you should review their policies and contact them directly.

International transfers of Personal Data

Your use of our products or services may involve the transfer, storage and processing of your Personal Data within and outside of your country of residence, consistent with this Privacy Notice.

If you are in the EEA, your Personal Data may be transferred to a third country outside of the EEA in accordance with the requirements under applicable data protection laws. Please refer to the Section “Additional Information for Individuals in EEA” for more details.

Security of your Personal Data

We have adopted security measures that are in line with industry standards to protect your Personal Data, and to prevent unauthorised access, disclosure, use, modification, damage or loss of data.  We will take all reasonable and practical steps to protect your Personal Data.

Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any Personal Data you transmit to us and you understand that any Personal Data that you transfer to us is done at your own risk. If we learn of a security system breach, we will act in accordance with the applicable law.

Retention of your Personal Data

The duration for which we retain your Personal Data will vary. The retention period will be determined by various criteria including:

· the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and

· legal obligations – laws or regulations may set a minimum period for which we have to keep your Personal Data.

Your rights

You have the following rights to your Personal Data:

· the right to be informed of why and how we process your Personal Data;

· the right to access the Personal Data we hold about you and request a copy of such information;

· the right to correct inaccurate Personal Data that we maintain about you;

· the right to withdraw your consent at any time to such processing activities that are based on consent.

Depending on your location, you may have additional rights under applicable data protection laws.

To exercise your rights, please submit your request to us by the contact information listed below in the “Contacting Us” section.

Use of cookies

We use “cookies” and similar technologies to support certain features of our products and services, and related websites and applications operated by us. A cookie is a piece of code deployed on your device. We use cookies that are strictly necessary. These cookies enable us to provide products and services to you, including for certain content management and editing purposes. We do not use any analytics, advertising, or tracking cookies.

Additional information for individuals in the EEA

In addition to the above sections, if you are in the European Economic Area (“EEA”), we provide the below information for you to better understand how we process your Personal Data in compliance with the applicable data protection laws.

This section applies to all Personal Data which are subject to the European Union’s General Data Protection Regulation (2016/679) (“GDPR”).

International transfers of Personal Data

As a global company, we may need to transfer your Personal Data out of the jurisdiction in which it was originally collected. For Personal Data to which the GDPR applies, this may mean transfers outside the EEA. You should be aware that these countries may not have similar data protection laws to the EEA. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Data with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Notice.

Where we transfer your Personal Data from within the EEA to another jurisdiction outside the EEA, we will ensure that it is protected and transferred in a manner consistent with requirements under the applicable data protection laws. For example, this may be done in one of the following ways:

· the jurisdiction that we send the data to is approved by the competent authority as offering an adequate level of protection for Personal Data;

· the recipient has signed up to a contract based on the standard contractual clauses approved by the competent authority, obliging it to protect your Personal Data;

· we have implemented other appropriate safeguards or can rely on derogations in accordance with applicable data protection laws, including the GDPR, such as to provide services requested by you, to conclude or perform a contract in your interest, with your explicit consent, as necessary for important reasons of public interest, and if necessary to establish, exercise or defend legal claims.

In all cases, however, we will ensure that any transfer of your Personal Data is compliant with the applicable data protection laws. You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us as described in the “Contacting Us” section.

Additional rights about your Personal Data

In addition to those rights under the Section “Your Rights”, you are also entitled to the following additional rights about your Personal Data:

· the right to restrict processing - You may limit the amount and type of Personal Data that we collect about you by choosing not to submit such Personal Data to us. You may also request that we restrict our processing of your Personal Data in certain circumstances. Please note that some of our services can only be provided to you if you provide us with the relevant Personal Data;

· the right to erasure – You may request that we erase your Personal Data, under certain conditions. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled or obliged to retain it.

· the right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions. However we may still be legally entitled or obliged to continue processing your Personal Data or deny your request.

· the right to data portability – You have the right to request to receive Personal Data that you have provided to us in a structured, commonly used and machine readable format and/or request that we transmit this information to another organisation where this is technically feasible under certain conditions.

We endeavour to resolve any privacy concerns you may have together with you. Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may lodge a complaint with a supervisory authority. Contact details for all European Union supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

Additional information for individuals in the US

In addition to the above sections, if you are based in the United States of America (“US”), we provide the below information for you to better understand how we process your Personal Data in compliance with the applicable data protection laws.

Data subject rights

Depending on your specific residency, you may have the following data subject rights to your Personal Data:

· the right to know what Personal Data the business has collected about you;

· the right to delete Personal Data that we have collected from or about you, subject to certain exceptions;

· the right to correct inaccurate Personal Data that a business maintains about you;

· the right to opt-out of the sale or sharing of Personal Data by us;

· if we use or disclose sensitive Personal Data for certain reasons, the right to limit the use or disclosure of sensitive Personal Data by us; and

· the right not to receive discriminatory treatment by us for the exercise of your privacy rights; the right to opt out of certain automated profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, although we do not engage in these activities;

· the right to obtain a copy of your Personal Data; and

· the right to additional information about third-party disclosures (e.g., categories or specific third parties, as required by law).

We do not have actual knowledge that it sells or shares Personal Data of data subjects who are minors.    

You or your authorized agent may submit a verifiable data subject request using the contact information listed below. The verifiable data subject request must do the following:

· provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative; and

· describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

· You may submit a verifiable data subject rights request via the contact information in "Contacting Us" session.

Notice at Collection For California Residents

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively the “CCPA”), we are providing you with this Notice at Collection for California Residents (“Notice”) to inform California residents about the Personal Data that we collect and the purposes for that collection, as well as your rights under the CCPA.

This Notice is only for individuals who reside in the State of California.

l Collection of Personal Data

Please see the section on "Personal Data we collect about you" as provided in the Privacy Notice.

l Potential Purposes for which any of the Categories of Personal Data Listed Above May Be Used

Please see the section on "Uses of your Personal Data" for purposes for which categories of Personal Data are collected as provided in the Privacy Notice.

l "Selling" and "Sharing" under CCPA：

As defined by relevant laws, we may sell and share certain online identifiers for the purpose of online advertising and analytics. Specifically, we may disclose online identifiers to advertising partners and analytics providers for online analytics and personalised advertising. You have the right to opt-out of this use of your Personal Data.

l California "Shine the Light"

If you are based in California, US, the California Civil Code Section 1798.83, also known as “Shine the Light” law, permits California residents to annually request information regarding the disclosure of your Personal Data (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2025 will receive information regarding sharing activities in 2024). You may submit your request using the details listed below in the “Contacting Us” section.

Contacting Us

Unless otherwise stated, the following entity will act as the data controller in relation to any  Personal Data subject to this Privacy Notice:

Guangdong Wankezi Intelligent Control Technology Co., Ltd.

No. 22, Keji West Road, Torch Development Zone, Zhongshan City, Guangdong Province,  China.

If you would like any further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed above, please contact our representatives as specified below.

· For EEA: TCL Europe (our EU representative)

Address: 9-15 rue Rouget de L'Isle- 92130 Issy- Les-Moulineaux, France

Contact: privacy_dpo@tcl.com

· For US: TCL US (our US representative)

Address: 189 Technology Drive, Irvine, CA 92618

Contact: privacy.na@tcl.com; +1-877-300-8837 (toll-free number)