This Privacy Notice is issued by Anker Innovations Technology Co., Ltd and its affiliates collectively referred to as "Anker," "we," "us," and "our." This notice is intended for individuals outside our organization with whom we engage, including customers, visitors to our sites, users of our applications, and recipients of our products or services (referred to as "you"). The terms used in this Privacy Notice are defined in Section (16) below.

Applicable to all Anker brands, including Anker, AnkerMake, AnkerWork, Eufy, Mach, Nebula, Roav, and SoundCore, as well as any specific device, website, or application referencing or linking to this Privacy Notice.

We reserve the right to update this Privacy Notice to reflect changes in our information practices. In the event of material changes, we will notify you through email (sent to the address provided in your account) or via a notice on the Anker Application or Site you previously used. Changes will be effective from the publication date unless stated otherwise. We encourage you to regularly review this page for the latest information on our privacy practices.

You may also have specific rights concerning the information we collect about you. The GDPR rights of Data Subjects are detailed in Section (9) below. Additionally, U.S. residents, including California Residents, can find information about their consumer rights in Section (15) below.

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 Basis for Processing
6. Disclosure of Personal Data
7. International Transfer of Personal Data
8. Data Retention
9. Your Privacy Rights
10. Direct Marketing
11. Details of Controllers
12. Business Information and Links to Other Websites
13. Cookies, Analytics and Tailored Advertising
14. Contact Us
15. Additional United States Privacy Disclosures
16. Definitions

1. Collection of Personal Data
Depending on your interaction with our Sites, Applications, products, or services, we may collect or obtain Personal Data from various sources:

• Data You Provide to Us: We acquire Personal Data when you furnish it to us, such as during account registration, when contacting us via email, telephone, or other means, or when sharing your business card.

• Account Creation Details: Personal Data is collected or obtained when you register or create an account to access our Sites or Applications.

• Relationship Data: In the regular course of our interaction with you, we collect or obtain Personal Data, for instance, when providing services.

• Site or Application Data: When you visit or use our Sites or Applications, or engage with features and resources available on them, we collect or obtain Personal Data.

• Content and Advertising Information: Interaction with third-party content or advertising on our Sites and/or Applications may result in the collection of your Personal Data by the relevant third-party providers. In return, we receive Personal Data related to your interaction with that content or advertising.

• Data You Make Public: We may collect publicly shared content about us from your use of our Apps and platforms, your social media, or other publicly accessible platforms.

• Third-Party Information: Personal Data is collected or obtained from third parties, including single sign-on providers, authentication services, integrated service providers, your employer, other Anker customers, business partners, processors, and law enforcement authorities.

• Data Automatically Collected: We and our third-party partners automatically collect information about your use of our Sites, Applications, products, or services. This includes data provided by you and details on how you access and engage with our offerings. Tracking technologies, such as cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies, and logging technologies, may be employed. Information collected automatically may be combined with other personal information obtained directly from you or from other sources.

For a detailed breakdown of the data collected, please refer to the table in Annex I.

2. Creation of Data

Additionally, we undertake the processing and retention of Personal Data pertaining to you under specific conditions. This includes maintaining records of your engagements with us, documenting details of your prior interactions, and formulating inferences or predictions about your characteristics or interests. Furthermore, we have the capability to link Personal Data gathered from various sources, including our Sites, Applications, products, or services, even when collected from different devices.

3. Categories of Personal Data We Collect and Process

Upon your initial registration for an Anker account, we may gather the following categories of Personal Data: username, password, email addresses, and/or phone numbers. Once your Anker account is successfully created, it can be utilized to log in across various Anker Sites and Applications, eliminating the need to create separate accounts for each.

In the course of using our Sites, Applications, products, or services, we may collect and/or process the following categories of personal data:

• Contact Information: This includes first and last names, preferred names, phone numbers, email addresses, and mailing addresses.

• Account Information: Details encompass first and last names, date of birth/age, alias, user ID, country, language preferences, email addresses, phone numbers, avatars, account credentials or one-time passcodes, single sign-on authentication tokens, loyalty and incentive program credits/rewards, and information about products or services purchased or used.

• Transaction Information: Records of purchases, prices, consignee names, shipping addresses and contact information, shipment tracking details, return details, and warranty information.

• Payment Details: Invoice/payment records, payment amount, payment date, billing address, and payment method. Notably, we utilize third-party payment providers (e.g., Shop Pay, Stripe, Amazon Pay, PayPal, Google Pay) for processing payments, and we do not receive or retain personally identifiable financial information.

• Information from Third-Party Authentication Services: If you choose to log in through third-party social networks or authentication services (e.g., Amazon, Apple, Google, Facebook), we receive tokens rather than login credentials. These tokens help identify you in our system, and you have the option to share certain Personal Data based on the third party's policies and your privacy settings.

• Product-Specific Information: Depending on the product used, we collect or facilitate the processing of specific information related to customer content, entertainment-related services, home-related services, car-related services, baby-related services, health-related services, and biometric services. Refer to Annex 2 for product-specific data details.

• Device and Network Information: Includes device type, operating system, IP address, browser type, user ID, UUID, or network information.

• Usage Information: Details about how individuals use our services, their interaction patterns, and browsing behavior. Third-party technologies are employed to collect comprehensive information about actions taken on our services.

• Event, Contest, Promotion, and Survey Information: Data provided during event sign-ups, contest entries, promotions, survey completions, or testimonials.

• Feedback and Support Information: Includes contents of custom messages, email addresses, photographs, videos, or other contact information provided to customers, along with call recordings (where permitted by law).

For certain Personal Data collection, we may seek permission through your mobile device, with you maintaining control over granted permissions and the ability to adjust settings, although revoking permissions may impact the provision and performance of our Sites, Applications, products, and services.

4. Purposes of Processing

We utilize the Personal Data we collect for various purposes, including but not limited to:

• Fulfilling Contractual Obligations: Meeting our contractual commitments to deliver requested products and services, facilitating communication between users or groups, and managing accounts and contracts, including customer support.

• Communication: Engaging with individuals through various channels such as email, text messages, social media, telephone, and video calls.

• Business Performance Review: Evaluating and reviewing our business performance to enhance and optimize our operations.

• Marketing: Promoting our products and services to businesses and individuals through channels like email, direct mail, phone, text messages, and online advertising, including targeted advertising and retargeting.

• Product and Service Administration: Administering, improving, and personalising our products and services. This involves recognizing individuals, remembering their information for return visits, and analyzing our customer base.

• Payment Processing: Handling payments for our services.

• Market Research: Conducting market research activities.

• Opportunity Tracking and Lead Generation: Tracking opportunities, converting leads, and generating new leads.

• Product and Service Testing and Enhancement: Testing, enhancing, updating, and monitoring products and services. Additionally, diagnosing and addressing technology-related issues.

• Security and Integrity Maintenance: Safeguarding the safety, security, and integrity of our property, products, services, technology assets, and business.

• Enforcement of Contractual Rights: Enforcing our contractual rights, including terms such as the Anker Terms of Service, General Terms and Conditions, Software Terms of Service, and other applicable terms.

• Dispute Resolution: Resolving disputes, fulfilling obligations, enforcing rights, and protecting business interests as well as the rights of third parties.

• Fraud Prevention and Investigation: Preventing, investigating, or providing notice of fraud or unlawful/criminal activity.

• Site and Application Functions: Facilitating various functions of our Sites or Applications, including profile creation, online shopping, and product rating.

• Displaying Functionalities in Connection with Third Parties: Collaborating with third parties to display specific functionalities, such as the trusted shop banner, shipment tracking, or product videos.

• Product Functionality for Users: Enabling users to utilize specific functionalities of our products.

• Discount Offerings: Offering discounts to specific groups, such as students.

• Business Partnership Decisions: Deciding on potential business partnerships, such as the affiliate program or the merchant program.

• Compliance with Legal Obligations: Fulfilling legal obligations in accordance with applicable laws.

For more details on how we process your Personal Data, refer to the table in Annex I.

5. Legal Basis for Processing

We process Personal Data subject to the General Data Protection Regulation (GDPR) for the following purposes and legal bases:

• Performance of Contractual Services or Prior to Contractual Agreement: We utilize your Personal Data to fulfill our contractual obligations when you order products or services, or when you contact us for such requests. This includes providing products or services, managing accounts and contracts, facilitating user benefits and services, offering customer support, and processing payments. This processing is essential for entering into or performing a contract with you.

• Justified by Our Legitimate Interests: Certain uses of your Personal Data are necessary for our legitimate business interests. This includes updating and monitoring services, diagnosing and fixing technology issues, ensuring the safety, security, and integrity of our property, services, and business, enforcing terms, resolving disputes, fulfilling obligations, protecting our business interests, and preventing or investigating fraud or unlawful activities.

• Consent: In specific cases, we may seek your separate consent to process your Personal Data. You have the right to revoke your consent at any time, affecting future processing.

• Compliance with Legal Obligations: We may be required to collect or retain certain Personal Data due to legal obligations, such as tax or commercial laws. Additionally, we may need to provide Personal Data to law enforcement agencies upon their lawful request.

For a comprehensive overview of the legal bases, refer to the table in Annex I.

6. Disclosure of Personal Data

We may engage in sharing, transmitting, disclosing, granting access to, making available, and providing Personal Data with and to various third parties, as outlined below:

• Anker Affiliates: We share Personal Data among the legal entities within the Anker group for legitimate business purposes, ensuring the proper functioning of our Sites, Applications, products, and services, all in accordance with applicable laws. These entities utilize your Personal Data as detailed in this Privacy Notice.

• Legal Obligations and Rights: Personal Data may be disclosed to third parties, including legal advisors, law enforcement agencies, regulators, and other authorities, if reasonably deemed necessary:
  • In connection with establishing, exercising, or defending legal claims.
  • To comply with laws or respond to lawful requests and legal processes.
  • To safeguard our rights, property, and the rights, personal safety, and property of others, enforcing our agreements and policies.
  • To detect, suppress, or prevent fraud or other criminal activity.As otherwise required by applicable law.

• Third-Party Processors: We share Personal Data with third party contractors and service providers subject to reasonable confidentiality terms. The services provided on our behalf by such third-party contractors and service providers may include email service providers; marketing/advertising service providers; call service providers; video shopping support and showroom service providers; text message service providers; venue operators; payment services providers; shipping companies; and postal carriers, 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), (2), and (3), and for the purposes described in Section (4). They only are authorized to process that information as necessary and as directed by us;

• Advertising Networks: To efficiently market our products and services to you, we may share Personal Data with so called advertising networks. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and similar technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. For more information about how these technologies work and certain choices you may have in relation to these technologies, please refer to Section (13) below;

• Business and Marketing Partners: Personal Data may be disclosed to business and marketing partners with whom we jointly offer products or services, or who are part of our partner program. Your consent may be obtained where required by applicable law.

• Third-Party Services Integrated in Our Services: Information may be shared with third-party services integrated into our offerings, such as voice-assisted technologies, based on your direct sharing choices.

• Individuals You Choose: Personal Data can be disclosed to individuals you choose, especially through our device-sharing function, emphasizes sharing with trusted individuals.

• Independent Advisors: Disclosure to independent advisors, including accountants, auditors, consultants, lawyers, and other professional advisors, is possible, subject to binding contractual obligations of confidentiality.

• Corporate Transactions: If Anker undergoes a corporate business transaction, like a merger, acquisition, or sale of assets, Personal Data may be disclosed to a third party during negotiations or as part of the transaction. Users will be notified of changes through email or a prominent notice on our website. In the event of insolvency, bankruptcy, or receivership, Personal Data may also be disclosed.

• Other Third Parties with Consent: Personal Data may be disclosed to other third parties or publicly with your prior consent or direction.

When engaging third-party Processors, contractual obligations are imposed, ensuring the Personal Data is processed in accordance with our instructions and with measures to protect confidentiality and security. Note that third parties and business partners may process Personal Data based on their own privacy policies and terms of service.

7. International Transfer of Personal Data

Given the global nature of our business, we conduct the transfer of Personal Data within the Anker group and to third parties, as outlined in Section (6) above, for the purposes specified in this Privacy Notice. Consequently, Personal Data may be transferred to countries with distinct laws and data protection compliance requirements compared to those in your location, including China, the European Economic Area (EEA), the United Kingdom (UK), and the United States (US).

In the case of Anker-initiated transfers, we ensure that international transfers of your Personal Data comply with appropriate safeguards. These safeguards may include:

• Transfers to Adequate Jurisdictions: Ensuring that Personal Data is only transferred to countries recognized as Adequate Jurisdictions. The current list of adequacy decisions can be found here. Please note that, currently, there is no adequacy decision for the United States and China.

• Standard Contractual Clauses: Making transfers pursuant to appropriate safeguards, such as Standard Contractual Clauses adopted by the European Commission or UK Secretary of State (as applicable), in conjunction with appropriate supplementary measures. The decision and template text for these Standard Contractual Clauses can be found here.

If you have further inquiries about these safeguards or would like details about the specific contracts in use, please contact us using the details provided in Section (14) of this Privacy Notice.

It's important to note that when you directly transfer any Personal Data to an Anker entity established outside the UK, Switzerland, or the EEA (as applicable), this is considered a direct collection. In such cases, the safeguards mentioned in this Section (7) may not apply. Nevertheless, we will process your Personal Data, starting from the point of receipt, in accordance with the provisions outlined in this Privacy Notice.

8. Data Retention

We have established processes to ensure that your Personal Data is processed only for the minimum duration necessary for the purposes outlined in this Privacy Notice. The criteria for determining the retention period for your Personal Data are as follows:

Ongoing Relationship:

• We will retain Personal Data in an identifiable form for as long as:
  • We maintain an ongoing relationship with you (e.g., as a user of our services or a lawful subscriber to our mailing list who has not unsubscribed); or
  • Your Personal Data are necessary for the lawful purposes specified in this Privacy Notice, for which we possess a valid legal basis (e.g., inclusion of your Personal Data in a contract between you and us, where we have a legitimate interest in processing the data for business operations and fulfilling contractual obligations, or where we have a legal obligation to retain your Personal Data).

Duration of Limitation Period:

The retention duration includes:

• Any applicable limitation period under the law of the European Union or an EEA member state, or any period during which a legal claim related to your Personal Data could be brought against us; and
• An additional two (2) months following the conclusion of the applicable limitation period, allowing reasonable time to identify relevant Personal Data in case of a legal claim.

• If legal claims are initiated, we will continue to process Personal Data for the additional periods necessary for those claims.

Restricted Processing During Retention Periods: Throughout the periods mentioned in (1), (2)(a), and (2)(b) above, our processing of your Personal Data will be limited to storage and maintaining data security. Exceptions may occur if data review is necessary in connection with a legal claim or an obligation under applicable law.

Once the relevant periods outlined in (1), (2), and (3) above, as applicable, have concluded, we will undertake one of the following actions:

• Permanently delete or destroy the relevant Personal Data.
• Anonymize or de-identify the relevant Personal Data.

9. Your Privacy Rights

Subject to applicable law, you hold the following rights concerning the Processing of your Relevant Personal Data:

• Right to Withhold Personal Data: The right not to provide your Personal Data to us. However, please note that full access to our services may be limited without the necessary Personal Data.
• Right to Access and Information: The right to request access to, or copies of, your Relevant Personal Data, along with additional details regarding the nature, Processing, and disclosure of that data.
• Right to Rectification: The right to request rectification of any inaccuracies or incompleteness in your Relevant Personal Data.
• Rights to Erasure and Restriction: The right to request erasure of your Relevant Personal Data without undue delay. The right to request restriction of Processing of your Relevant Personal Data, limiting the purposes for which we Process it.
• Right to Data Portability: 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.
• Right to Deletion or Removal: The right to request the deletion or removal of your Relevant Personal Data when there is no other legal basis for us to continue using it. Please note that removal from backup systems may be subject to legal or technological constraints.
• Right to Withdraw Consent: Where we Process your Relevant Personal Data based on your consent, the right to withdraw that consent. Withdrawal does not affect the lawfulness of prior Processing and does not prevent Processing based on other available legal bases.

Additional GDPR Rights:

Under the GDPR, you may also have the following rights:

• Right to Object: The right to object, based on your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where Processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR.
• Right to Object to Direct Marketing: The right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.
• Right to Lodge Complaints: The right to lodge complaints regarding the Processing of your Relevant Personal Data with a competent Data Protection Authority.

To exercise these rights or seek clarification, use the contact details provided in Section (14) below. Note that:

• Proof of identity may be required in some cases.
• Requests involving factual determinations will be reasonably investigated before deciding on action.

This does not affect your statutory rights. We encourage you to contact us first to address any concerns before contacting the relevant Data Protection Authority.

10. Direct Marketing

We process Personal Data to reach out to you through various communication channels such as email, telephone, direct mail, or other formats to share information about Sites, Applications, products, and services that might be of interest. If we deliver Sites, Applications, products, or services to you, we may send or display information, including details about upcoming promotions and other relevant content, using the contact information you've provided or through other suitable means. This is always done with your prior opt-in consent, as required by applicable law.

To manage your communication preferences, you have the option to unsubscribe from specific promotional email campaigns at any time. You can achieve this by clicking the unsubscribe link in every promotional electronic communication we send. Alternatively, you may opt out of all Anker promotional emails by visiting https://passport.anker.com/unsubscribe/?app=ankerus. Following your unsubscribe request, we will cease sending further promotional emails related to the campaigns you opted out of. However, in certain circumstances, we may still contact you for essential purposes, such as providing requested Sites, Applications, products, or services, or in connection with any email campaigns to which you remain subscribed.

Similarly, you can opt out of specific promotional text campaigns by replying STOP via text message to the promotional texts related to the specific campaign you wish to unsubscribe from. After unsubscribing, we will discontinue sending further promotional text messages associated with the campaigns you opted out of. Yet, in some situations, we may continue to contact you for essential reasons, such as delivering requested Sites, Applications, products, or services or in connection with any text campaigns to which you remain subscribed.

11. Details of Controllers

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

• Anker Technology (UK) Ltd.:
  • Address: 205 Kings Road, Fairgate House, Suite B, B11 2AA Birmingham
  • Contact: +49 (0) 69 9579 7960
• Anker Innovations Technology Co., Ltd:
  • Address: Room701, Bldg 7, Zhongdian Software Park, 39 Jianshan Road, Hi-tech Zone, Changsha City, Hunan Province, China
• Shenzhen Oceanwing Smart Innovations Technology Co., Ltd:
  • Address: B701-705, Jianxing Tech Bldg, Xinxing industrial park, 3151 Shahe West Road, Nanshan District, Shenzhen City
• Fantasia Trading LLC:
  • Address: 5350 Ontario Mills Pkwy, Suite 100, Ontario, CA 91764 Delaware

For general inquiries or to exercise any rights as outlined in this Privacy Notice, please contact support@anker.com.

Regarding the Processing of Personal Data through our Site and Applications, the mentioned entities collectively have access to your Personal Data and jointly determine the means and purposes of the Processing. As a result, they share responsibility for the Processing of your Personal Data.

Although you can contact Anker at support@anker.com for all data protection matters, Anker Innovations Technology Co., Ltd. is designated to handle concerns related to your Personal Data. Therefore, for any inquiries, including requests to exercise your rights under Section (9) of this Privacy Notice, you may reach out to Anker Innovations Technology Co., Ltd. using the contact information provided above or in Section (17).

12. Business Information and Links to Other Websites

• Business Information: While utilizing our Sites, Applications, products, and services, we may request business information related to your company. This includes details about your company's practices, policies, processes, and supporting documentation. The business information provided is securely stored in Anker systems and is utilized to deliver the contracted solutions and adhere to the terms and conditions outlined in agreements between Anker and your company.
• Links to Other Websites: This Privacy Notice is specifically applicable to Anker's practices, technologies, and services. Our online properties may contain links to websites and online services operated by companies beyond Anker's control. If you submit Personal Data to those external websites or online services, their respective privacy policies govern the treatment of your Personal Data. We advise you to carefully review the privacy policies of any website you visit.

13. Cookies, Analytics and Tailored Advertising

Anker, along with its third-party partners and providers, utilizes cookies and similar technologies to automatically gather specific Personal Data when you visit or engage with our Sites and services. This is done to improve navigation, analyze trends, administer the Sites, track user movements, collect demographic information about our user base, and support our marketing efforts and customer service. You have the ability to manage cookie usage at the individual browser level; however, disabling cookies may restrict your access to certain features or functions on our Sites and services.

To customize your preferences regarding our use of cookies and similar technologies, you can click on the "Cookie Settings" link in the footer of our Sites. Please note that these cookie preference settings are specific to each website, device, and browser, so adjustments should be made on each device and browser used to interact with a particular Site. Additionally, you can cease all information collection through our web services by refraining from using our Sites and services.

Third-party tools and features may also be employed to further control our use of cookies and similar technologies. Most commercial browsers offer tools to disable or remove cookies, and certain settings may block them in the future. Browser functionalities vary, so adjustments may need to be made separately. You can exercise specific privacy choices, such as enabling or disabling location-based services, by modifying permissions in your mobile device or internet browser. Furthermore, you have the option to opt-out of Google Analytics cookies by downloading the Google Analytics Opt-out Browser Add-on from https://tools.google.com/dlpage/gaoptout. For details on Google Analytics data collection and processing, as well as controlling information sent to Google, refer to Google's website at www.google.com/policies/privacy/partners/.

To opt-out of targeted advertising from companies participating in the Digital Advertising Alliance (“DAA”) AdChoices Program, visit optout.aboutads.info. More information on the DAA AdChoices Program is available at www.youradchoices.com. The Network Advertising Initiative (“NAI”) provides a tool allowing consumers to opt out of tailored advertising from NAI members’ advertising networks; visit https://optout.networkadvertising.org/ for details.

14. Contact Us

If you have questions or concerns with respect to our Privacy Notice or privacy practices, you may contact us at support@anker.com or DPO@anker.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

15. Additional United States Privacy Disclosures

These 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. For a detailed description of how we collect, use, disclose, and otherwise process Personal Data, please read the main body of our Privacy Notice.

Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of certain of your Personal Data. Although we do not currently sell covered data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your Personal Data by emailing us at support@anker.com.

California, Colorado, Connecticut, Utah, and Virginia Residents

If you are a resident of the state of California, Colorado, Connecticut, Utah, or Virginia in the United States the following supplementary disclosures apply to you.

Collection and Use of Personal Data

Personal Data Collection

As detailed in Section (3) above, we collect various categories of Personal Data, including:

• Identifiers: First and last name, preferred name, phone number, email address, unique personal identifiers, and online identifiers.
• Customer Records: Contact information, address book details, and account information.
• Protected Classification Characteristics: Age, gender, and health status.
• Commercial Information: Purchase records, prices, shipping details, returns, consumer histories, and tendencies.
• Biometric Information: Facial, fingerprint, or other biometric recognition technology results processed solely on the user’s device.
• Internet/Network Information: Device type, manufacturer, model, operating system, IP address, browser type, Internet service provider, and unique identifiers.
• Geolocation Data: General geographic location and more precise data when granted access through device settings.
• Audio, Electronic, Visual, Thermal, Olfactory Information: Voice prompts/recordings, security/service images, and video.
• Professional/Employment Information: Employer and job title.
• Sensitive Personal Data: Account credentials, payment card information (handled by third-party payment providers), biometric information (processed solely on the user’s device), health metrics, and precise geolocation data.
• Other Personal Data: Communication preferences, entertainment preferences, home configuration, participation in loyalty and incentive programs, and any other information voluntarily shared.
• Inferences: Consumer preferences, predispositions, and characteristics.

Data Collection Sources

As described in Section (1) above, we collect Personal Data directly from you, automatically during interactions with our Sites, Applications, products, or services, from third parties, and from public third-party platforms such as social media websites.

Purpose of Data Collection

We collect Personal Data for various purposes, including communication, order fulfillment, survey participation, site and application improvement, marketing communications, personalized and non-personalized advertising, and customer service. Refer to Section (4) for more details.

Sensitive Personal Data Usage

Sensitive Personal Data, including account credentials, payment card information, biometric information, health metrics, and precise geolocation data, is only used or disclosed when reasonably necessary for service performance, security, fraud detection, safety, or short-term transient use. We do not sell or process Sensitive Personal Data for targeted advertising.

Deidentified Information

We may receive or process Personal Data to create de-identified information that cannot reasonably be linked to an individual. We use and maintain such information in de-identified form, refraining from attempts to re-identify unless required or permitted by law.

Personal Data Disclosures, Sales, and Targeted Advertising

Disclosure of Personal Data

We may disclose the categories of Personal Data mentioned above to various third parties, including entities within the Anker group, Processors, ad networks, advertising partners, business and marketing partners, third-party providers with services integrating with ours, individuals chosen by you for data sharing, and specific third parties with your consent or as required/permitted by law (refer to Section 6 for details).

Sale of Personal Data

The disclosure or provision of identifiers, customer records, commercial information, internet/network information, and inferences to ad networks and advertising partners may be considered the sale of Personal Data or sharing/processing for targeted advertising. This involves displaying advertisements selected based on Personal Data obtained or inferred over time from individual activities across businesses or distinctly-branded platforms.

Opt-out Choices

Depending on your state of residency, you may have the option to limit or opt out of the sale of Personal Data or processing for targeted advertising purposes (as outlined in the Your Additional U.S. Privacy Choices section below).

Protection of Minors

We do not sell the Personal Data of individuals known to be under 16 years of age or share such information for targeted advertising. Additionally, we refrain from selling Sensitive Personal Data and do not process or share Sensitive Personal Data for targeted advertising purposes.

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.

Your Additional U.S. Privacy Choices

Exercising Privacy Rights

Depending on your state of residence and subject to certain legal limitations, you may have the ability to exercise some or all of the following rights:

Right to Know: Confirm whether we process your Personal Data and, under California law, obtain personalized details about the collected data, including categories, sources, purposes, disclosures to third parties, data shared for targeted advertising, and data sold.

Right to Access & Portability: Obtain access to your Personal Data and, where required, receive a portable copy of the data.

Right to Correction: Correct inaccuracies in your Personal Data.

Right to Control Over Sensitive Personal Data: Exercise control over the collection and processing of certain Sensitive Personal Data.

Right to Opt-Out of Targeted Advertising: Direct us not to use or share Personal Data for certain targeted advertising purposes.

Right to Opt-Out of Sales: Direct us not to sell Personal Data to third parties.

Right to Deletion: Have us delete Personal Data we maintain about you (subject to exceptions).

Rights and Treatment

Depending on your state, you may also have the right to not receive discriminatory treatment for exercising these rights, although differences in product or service quality, price, or features may apply where permitted by law.

Submitting Requests

Please submit a request by completing our online form or calling our toll-free U.S. telephone number. To exercise the right to opt-out related to cookies and similar technologies, adjust preferences through the “Cookie Settings” link or use the Global Privacy Control.

Verification Process

Before processing certain requests, we need to verify your identity and state residency. Requests should include specific information outlined in our online form or toll-free number.

Authorized Agent Requests

Authorized agents can submit requests on your behalf, with proper evidence of authority. We may contact you to confirm authorization and verify your identity.

Appealing Decisions

You may appeal decisions related to privacy rights requests. Submit an appeal by replying to the communication resolving your original request.

Financial Incentives and Loyalty Programs

We offer various financial incentives to our customers, including:

• Discounts, coupons, and special offers via email when signing up for our email lists or creating an account;
• Rewards when referring a friend who purchases our products or services; and
• Loyalty programs, where customers earn / redeem rewards based upon their past transactions with us.

To obtain access to certain of these programs and other offerings, we may ask to collect your Personal Data, including name, contact information, professional information, account information, and transaction information. We consider the value of these programs and other offerings to be reasonably related to the value of the Personal Data to our business, based on our reasonable but sole determination. We estimate the value of the Personal Data by considering the expense incurred by the business related to the collection, storage, and retention of the Personal Data in the context of the financial incentive program and the expenses related to the provision of the financial incentive.

The terms applicable to each program and other offerings are provided at the time an eligible customer is offered an opportunity to participate. Interested customers can opt-in to these programs and offerings by following the instructions presented at the time the offer is made. Participating customers may withdraw from our programs and other offerings at any time by unsubscribing from our emails (for email-based incentives), closing their accounts (for loyalty and reward program incentives), following the instructions provided in connection with each offering, or by emailing us at support@anker.com.

16. Definitions

• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “Application” means any applications operated, or maintained, by us or on our behalf.
• “California Resident” means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why personal data is processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “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.
• “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.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:
  • A consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the provisions of this title. An intentional interaction occurs when the consumer intends to interact with the third party, via one or more deliberate interactions. Hovering over, muting, pausing, or closing a given piece of content does not constitute a consumer’s intent to interact with a third party;
  • The business uses or shares an identifier for a consumer who has opted out of the sale of the consumer’s personal information for the purposes of alerting third parties that the consumer has opted out of the sale of the consumer’s personal information;
  • The business uses or shares with a service provider the personal information of a consumer that is necessary to perform a business purposes if both of the following conditions are met:
  • The business has provided notice that information being used or shared in its terms and conditions is consistent with Section 1798.135 of the CCPA; and
  • The service provider does not further collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose; or
  • The business transfers to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business provided that information is used or shared consistently with Sections 1798.110 and 1798.115 of the CCPA.
• “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.
• “Site” means any website operated, or maintained, by us or on our behalf.

Annex I Details of Processing

 

Annex II Details of Product-specific information

• Customer Content: This includes any files, documents, audio, videos, images, data, or communications you input, upload, or transmit to our Sites, Applications, products, and services. Certain products allow you to process content directly on your device without transferring it to Anker. For instance, voice prompts generated using our voice-assisted technologies may be transferred to third-party voice-assistant service accounts. Depending on your location, surveillance laws, and service configurations, you may need explicit consent before using our products to create and save video or images, ensuring compliance with applicable laws.
• Entertainment-Related Service Information: When using entertainment-related services like Nebula Smart Projectors and SoundCore speakers/headphones, we collect information about your preferences, including audio/video settings and the entertainment services you engage with. With your permission, we may read call status for the SoundCore music player and access your device’s microphone for speech-based features, which you can refuse or withdraw at any time through your mobile device's privacy settings.
• Home-Related Services Information: For home-related services like eufy Clean, eufy Pet, and eufy Security, we collect data about your home, including location, environment details, pet information, occupancy data, and monitoring audio/images/videos. Compliance with surveillance laws, local regulations, and obtaining explicit consent is essential based on your jurisdiction and service configurations.
• Car-Related Services Information: When using car-related services like Roav DashCam, SmartCharge, and Viva, information about your vehicle, including VIN details and driving experience metrics, is collected locally on your device or mobile application.
• Baby-Related Services Information: For baby-related services like eufy Baby Monitor and Smart Sock, we collect information about your baby, including name, gender, birth details, weight, photographs, monitor images, video, sleep patterns, movements, heart rate, and blood oxygen levels.
• Health-Related Services Information: Using health-related services like eufy Smart Scale, eufy Blood Pressure Monitor, and SoundCore health-connected devices, information related to personal health, such as weight, heart rate, body mass index, and sleep metrics, is collected either by us or maintained locally on your device.
• Biometric Services Information: Certain services use biometric technologies, like facial recognition, for features such as login/authentication. We do not store or access this biometric information; the assessment process occurs entirely on your device. Depending on your location, consent from individuals may be required before using our products for biometric processing, ensuring compliance with relevant laws.