Language
ZTE Commitment to Compliance with the EU Data Act
Version: 2.0
Effective Date: September 12, 2026
Introduction
ZTE Corporation and its subsidiaries (collectively, "ZTE", "us", "we", or "our") respect your rights under the EU Data Act (Regulation (EU) 2023/2854) ("Data Act") and are committed to complying with all applicable requirements set forth therein.
This Commitment is addressed to users of the "connected products" and "related services," as defined under the Data Act, that we place on the EU market, as well as to parties acting on behalf of the users (collectively, "you" or "your"). It provides the necessary pre-contractual information regarding both the connected products and related services for which we act as the manufacturer and service provider, and, where applicable, sets out how we, as the data holder, share product data and related service data upon your request to comply with the Data Act.
Please note that such data may contain personal data, and the processing and sharing of personal data shall comply with the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR"). If you have any questions about the personal data generated through your use of such products and related services, please refer to the ZTE Privacy Policy.
The following information is provided in accordance with the Data Act.
1. Manufacturer, Service Provider, and Data Holder
Enterprises: ZTE Corporation and its subsidiaries.
Registered address: ZTE Plaza, Keji Road South, Hi-Tech Industrial Park, Nanshan District, Shenzhen, P.R. China.
For the registered addresses of our subsidiaries, please refer to: Corporate Information-ZTE.
2. Connected Products and Related Services
ZTE provides smartphones, smartwatches, routers, Set-Top Boxes (STBs), Customer Premises Equipment (CPE), as well as other home information terminals, all of which may be defined as "connected products" under Articles 2 and 3 of the Data Act. The full list of these connected products, their related services, and additional information are described in this Commitment.
3. Product Data and Related Service Data
Unless otherwise expressly stated, "data" in this Commitment refers to ZTE's product data and related service data that fall within the scope of the EU Data Act.
The following table sets out the details of product data and related service data generated when you use ZTE's connected products and related services in the European Economic Area (EEA):
Connected Product and/or Related Service |
Data Type |
Continuous Data Generation |
Real-Time Data Generation |
Personal Data |
Data Format and Volume |
Storage Method and Duration |
|
Product Type |
Related Service/ Business Function |
||||||
Smartphone/ |
System update |
Device IMEI, MEID, or SN |
No |
No |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until next system upgrade |
Device software version number - curversion |
No |
No |
No |
String (max length: 128 characters) |
Stored in Germany and retained until next system upgrade |
||
Device product model - subtype |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until next system upgrade |
||
Basic AI service/Gemini AI service |
Device ID |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained for six months |
|
Device product model - subtype |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained for six months |
||
Application package name - caller |
No |
No |
No |
String (max length: 255 characters) |
Stored in Germany and retained for six months |
||
5G FWA |
System upgrade |
Device software version number - curversion |
No |
No |
No |
String (max length: 128 characters) |
Stored in Germany and retained until the user cancels the account |
Device IMEI or SN - OID |
No |
No |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Device product model - subtype |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until next system upgrade |
||
ZTE Smart Life |
Router - SN (it binds only a single device) |
No |
No |
Yes |
String (max length: 128 characters) |
Stored in Germany and retained until the user cancels the account |
|
Router - MAC |
No |
No |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - IP |
No |
Yes |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - model |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - vendor |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - version |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Smartwatch |
System upgrade |
Device software version number - curversion |
No |
No |
No |
String (max length: 128 characters) |
Stored in Germany; information about the user's most recent device upgrade will be automatically deleted after a retention period of 5 years |
Device IMEI or SN - OID |
No |
No |
Yes |
String (max length: 64 characters) |
Stored in Germany; information about the user's most recent device upgrade will be automatically deleted after a retention period of 5 years |
||
Device product model - subtype |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany; information about the user's most recent device upgrade will be automatically deleted after a retention period of 5 years |
||
Kids watch |
Account management |
Phone number |
No |
No |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
Email address |
No |
No |
Yes |
String (max length: 128 characters) |
Stored in Germany and retained until the user cancels the account |
||
Guardian roles |
No |
No |
Yes |
Enumerated string (father/mother/other) |
Stored in Germany and retained until the user cancels the account |
||
Device information |
Device name |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
|
Device number |
No |
No |
Yes |
String (max length: 32 characters) |
Stored in Germany and retained until device unbinding |
||
Firmware version |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until next upgrade |
||
Contacts |
No |
No |
Yes |
JSON array (max 50 entries, with each including name, phone, and avatar) |
Stored in Germany and retained until the user cancels the account |
||
Location services |
GPS coordinates |
Yes |
Yes |
Yes |
Numeric (latitude/longitude) |
Stored in Germany and retained for 3 days |
|
Positioning accuracy & method |
Yes |
Yes |
No |
String + numeric |
Stored in Germany and retained for 3 days |
||
Call services |
Call logs |
Yes |
No |
Yes |
JSON array (number, duration, type) |
Stored in Germany and retained until the user cancels the account |
|
Health & activity |
Step count records |
Yes |
No |
No |
Numeric + timestamp |
Stored in Germany and retained for 7 days |
|
Safety guardian |
Guardian type & status |
No |
No |
Yes |
Structured JSON |
Stored in Germany and retained until rule deletion |
|
Guardian rules |
No |
No |
Yes |
Structured JSON (time, address, schedule) |
Stored in Germany and retained until rule deletion |
||
Safe zone address |
No |
No |
Yes |
Structured JSON with images (name, coordinates, Wi-Fi) |
Stored in Germany and retained until address deletion |
||
Watch settings |
Call whitelist toggle |
No |
No |
No |
Boolean (on/off) |
Stored in Germany and retained until setting change |
|
Auto-answer toggle |
No |
No |
No |
Boolean (on/off) |
Stored in Germany and retained until setting change |
||
Positioning mode |
No |
No |
No |
Enumerated string (power saving/standard/precise) |
Stored in Germany and retained until setting change |
||
School mode restriction rules |
No |
No |
Yes |
JSON array with time slots |
Stored in Germany and retained until setting change |
||
App management list |
No |
No |
No |
JSON array (app name + status) |
Stored in Germany and retained until setting change |
||
SOS emergency contacts |
No |
No |
Yes |
String (max 3 entries, max 32 characters each) |
Stored in Germany and retained until setting change |
||
Shutdown password |
No |
No |
Yes |
String (max length: 16 characters) |
Stored in Germany and retained until setting change |
||
Router |
ZTE Zlife |
Router - SN (it binds only a single device) |
No |
No |
Yes |
String (max length: 128 characters) |
Stored in Germany and retained until the user cancels the account |
Router - MAC |
No |
No |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - IP |
No |
Yes |
Yes |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - model |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - vendor |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
Router - version |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
IP camera in home network |
ZTE Zlife |
IPC - SN (it binds only a single device) |
No |
No |
Yes |
Text, depending on actual usage |
Stored on the device and retained until the user resets the device to factory settings |
IPC - MAC |
No |
No |
Yes |
Text, depending on actual usage |
Stored in Germany and retained until the user cancels the account |
||
IPC - IP |
No |
Yes |
Yes |
Text, depending on actual usage |
Stored in Germany and retained until the user cancels the account |
||
IPC - model |
No |
No |
No |
Text, depending on actual usage |
Stored in Germany and retained until the user cancels the account |
||
IPC - vendor |
No |
No |
No |
String (max length: 64 characters) |
Stored in Germany and retained until the user cancels the account |
||
IPC - version |
No |
No |
No |
Text, depending on actual usage |
Stored on the device and retained until user modification or the user resets the device to factory settings |
||
CPE |
/ |
CPE - IP |
No |
Yes |
Yes |
String (max length: 39 characters) |
Stored on the device and retained until user modification |
CPE - model |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
CPE - vendor |
No |
No |
No |
String (max length: 4 characters) |
Stored on the device indefinitely |
||
CPE - hardware version |
No |
No |
No |
String (max length: 14 characters) |
Stored on the device indefinitely |
||
CPE - software version |
No |
No |
No |
String (max length: 14 characters) |
Stored on the device until system upgrade |
||
STB/stick/ dongle/smart display |
/ |
Device - SN |
No |
No |
Yes |
String (max length: 128 characters) |
Stored on the device indefinitely |
Device - MAC |
No |
No |
Yes |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
Device - IP |
No |
Yes |
Yes |
String (max length: 64 characters) |
Stored on the device and cleared upon reboot |
||
Device - model |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
Device - vendor |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
Device - version |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
OS information |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
HDMI status |
Yes |
Yes |
No |
String (max length: 64 characters) |
Stored on the device and cleared upon reboot |
||
Storage information |
Yes |
Yes |
No |
String (max length: 64 characters) |
Stored on the device and cleared upon reboot |
||
STB Wi-Fi MAC address |
No |
Yes |
No |
String (max length: 64 characters) |
Stored on the device indefinitely |
||
STB Wi-Fi RSSI |
No |
Yes |
No |
String (max length: 64 characters) |
Stored on the device and cleared upon reboot |
||
LAN connection information |
Yes |
Yes |
No |
Text, depending on actual usage |
Stored on the device and cleared upon reboot |
||
Wi-Fi connection information |
Yes |
Yes |
No |
Text, depending on actual usage |
Stored on the device and cleared upon reboot |
||
App visited |
Yes |
Yes |
Yes |
String (max length: 64 characters) |
Stored on the device and cleared until the user resets the device to factory settings |
||
VCT (Video Conference Terminal) |
Video conferencing system |
Terminal - OID |
No |
No |
Yes |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
Terminal - SN |
No |
No |
Yes |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
||
Terminal - MAC |
No |
No |
Yes |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
||
Terminal - IP |
No |
Yes |
Yes |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
||
Terminal - model |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
||
Terminal - software version |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
||
Terminal - hardware version |
No |
No |
No |
String (max length: 64 characters) |
Stored on the device and the server, and retained until the user deletes it |
||
Energy equipment |
iEMS - device management |
Basic device information |
No |
No |
No |
Text, depending on actual usage |
Stored in Germany and retained until next system upgrade |
Operation logs |
Yes |
Yes |
No |
Text, depending on actual usage |
Stored on the device and retained until cycle coverage or the user resets the device to factory settings |
||
iEMS - device operating status |
Internal electricity meter data |
Yes |
Yes |
No |
Text, depending on actual usage |
Stored on the device and retained until cycle coverage or the user resets the device to factory settings |
|
External electricity meter data |
Yes |
Yes |
No |
Text, depending on actual usage |
Stored on the device and retained until cycle coverage or the user resets the device to factory settings |
||
Interface electricity meter data |
Yes |
Yes |
No |
Text, depending on actual usage |
Stored on the device and retained until cycle coverage or the user resets the device to factory settings |
||
The type of data generated by our connected products and related services may vary depending on the device type, software version, device functionalities, and/or user behavior patterns.
In addition, such data may change from time to time to align with:
1) subsequent delegated acts adopted under the Data Act and other guidance issued by EU agencies.
2) adjustments to ZTE's business strategies or product functionalities.
4. Data Access and Sharing
l Direct Access and Sharing
You may directly access or export the product data and related service data through the methods listed below.
1) Smartphone/Tablet
Path: Settings > System and update > DataExporter.
Some products may require a software update package to enable the data export functionality.
2) 5G FWA/5G MBB/4G FWA/4G MBB/Wi-Fi router
Data can be directly viewed via the device WebUI, or accessed and exported by connecting the device to a computer and using the DataExporter Tool. To export the data, follow the steps below:
i. Download and install the DataExporter tool on your Windows computer. This tool is compatible with the Windows 10 and Windows 11 operating systems only.
ii. Turn on the device and connect it to your computer via USB, Wi-Fi, or Ethernet. Select the connection method supported by your device.
iii. Launch the DataExporter tool, and manually enter the following information on the login interface:
Device model (refer to the device label)
Device gateway address (refer to the device label for the default value; use the current value if the default has been changed)
Account and password (refer to the device label for the default values; use the current values if the default has been changed)
iv. Click Login to access the main interface. You can then view and select the product data you wish to export. Click Export to save the data as a local text file.
Please note that, due to Web API limitations, the device SN and MAC addresses of certain products cannot be viewed or exported via the tool. Please find such information directly on the device label, or contact us at DataPrivacy@zte.com.cn.
3) Smartwatch
Data can be exported via the Z Sports app. Follow the steps below:
i. Open the app and ensure your device is bound, then go to the Me tab.
ii. Select About > Data & Privacy > Export Personal Data.
4) Kids Watch
Data can be exported via the ZTE Kids app. Follow the steps below:
i. Open the app and log in to your account.
ii. Go to the Me page, then select the child profile you wish to export data for from the top of the page.
iii. Select About > Data & Privacy > Export Personal Data.
5) Router & IP Camera in Home Network
You may log in to the Zlife app and access or export the data via Account > User Data.
6) CPE
You may log in to the WebUI and access or export the data via Device Management / Diagnosis > Log Management > System Log > Download.
Please note that data access and export methods may vary across different products. If you are unable to access or export the data through the above-mentioned methods, please contact us at DataPrivacy@zte.com.cn.
7) STB/Stick/Dongle/Smart Display
You may view the data via Settings.
8) VCT (Video Conference Terminal) & Video Conferencing System
You may log in to the WebUI and access or export data via Device Management > Terminal Management > Export.
9) Energy Equipment
You may log in to the WebUI and access or export basic device information via Custom Report Function.
You may log in to the WebUI and access or export operation logs via Power Station List > Station > Operation Logs Function.
You may log in to the WebUI and access or export device operating status data via the Meter Data Query Function.
If you wish to allow others (e.g., a repair shop) to access your data, you may export the data by yourself and share it with a third party of your choice through secure means. Please note that, in accordance with Article 5(3) and Article 6(2)(d) of the Data Act, you shall not provide data obtained under the Data Act to any undertaking designated as a "gatekeeper" under the Digital Markets Act (Regulation (EU) 2022/1925); nor may the data recipient you designate further share the data with any gatekeeper.
If you encounter any difficulties in directly accessing or exporting your data, please contact us at DataPrivacy@zte.com.cn. We will make every effort to ensure your rights under the Data Act.
l Indirect Access and Sharing
If you wish to access and share the data for which we act as the data holder, you may also contact us at DataPrivacy@zte.com.cn. We will review and respond to your request without undue delay.
Please note that, to respond to your request, we may need to collect relevant information to verify your identity as a user (whether as an individual, legal entity, or any other form of entity). You may be required to provide one or more of the following:
1) Your email address.
2) The recipient's email address (for data transmission).
3) Other information that helps us assess your request.
We may need to decline a request in certain circumstances, for example:
1) The information provided is insufficient to verify your identity or assess your request.
2) The request seeks access to another individual's personal data without a legal basis.
3) The data involves trade secrets or IP-protected content, and no necessary measures or contracts are in place to preserve its security and confidentiality.
4) The recipient, or any onward recipient designated by the recipient, is designated as a "gatekeeper" under the Digital Markets Act (Regulation (EU) 2022/1925).
If your request is declined, we will provide you with a response stating the reasons.
5. Restrictions on the Purposes of Data Use
Once you have received data under the Data Act, you may use and share it only for legitimate purposes in accordance with applicable laws and regulations.
Your use of the data obtained shall be subject to the following restrictions:
1) You shall not use the data to develop a product that competes with ZTE's connected products, nor make data available to a third party for that purpose.
2) You shall not use the data to gain insights into our economic situation, assets, production methods, or similar information.
3) You shall not use the data for any other purpose that may contravene the Data Act or other applicable laws and regulatory requirements.
6. Data Security Protection Mechanism
To prevent potential unauthorized access, use, or disclosure, we implement necessary technical and organizational security measures to ensure that data and its sharing are reasonably protected. These measures include, but are not limited to:
1) Encrypted transmission technologies (e.g., TLS 1.3).
2) Access control mechanisms (e.g., role-based permissions).
3) Audit logging for full traceability.
4) Regular review of security practices regarding data collection, storage, and processing, to maintain alignment with industry standard practices.
5) Adoption of other security measures as necessary to comply with applicable laws and regulations.
Data will be shared in machine-readable, commonly used formats (e.g., JSON and XML).
7. Contact Us
For any other inquiries regarding our compliance with the Data Act, please contact:
Email: DataPrivacy@zte.com.cn
Postal address: Data Compliance Dept., ZTE Corporation, No. 55, Hi-Tech Road South, Shenzhen, P.R. China (postcode: 518057)
We will review and respond to your requests without undue delay.
8. Update to this Commitment
ZTE may update this Commitment from time to time. We will publish the updated Commitment in a prominent location on our official website.
9. Declaration
ZTE provides this Commitment in various local languages. Should there be any conflict or inconsistency between a local-language version and the English version, or should any local-language version contain an ambiguity, the English version shall prevail.
In the event of any conflict or inconsistency between the information provided in this Commitment and the pre-contractual information under the Data Act set forth in offline documents (e.g., the product manual or the security manual), the latter shall prevail.
This Commitment shall be interpreted and applied in accordance with the Data Act and other applicable laws and regulations.
The following language versions are available for your reference.
language |
Translation |
Polski |
|
Italiano |
|
Español |
Compromiso de ZTE con el Cumplimiento del Acta de Datos de la UE |
Dansk |
|
Slovenščina |
|
Română |
|
Svenska |
|
Suomi |
|
Eesti |
|
Hrvatski |
|
Nederlands |
|
Slovenčina |
|
Malti |
|
Lietuvių |
|
Latviešu |
|
Gaeilge |
|
Magyar |
A ZTE kötelezettségvállalása az EU adatvédelmi törvényének való megfelelésre |
Ελληνικά |
Δέσμευση της ZTE για Συμμόρφωση με τον Νόμο της ΕΕ για τα Δεδομένα |
Български |
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Deutsch |
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Čeština |
|
Português |
Compromisso da ZTE com a Conformidade com a Lei de Dados da UE |
Français |
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