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ZTE Commitment to Compliance with EU Data Act
Version: 1.0
Effective Date: 2025-09-12
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 comply with the relevant requirements under the Data Act.
Certain products and services that we place on the EU market meet the definition of "connected product and/or related service" under the Data Act. With respect to such products, we may be obliged to make certain product data and related service data accessible to users, their representatives, or their designed data recipients (collectively, "you" or "your"). This statement contains relevant information on how we share such data with users to comply with the Data Act.
Please note that these data may contain personal data, and the processing and sharing of personal data comply with the General Data Protection Regulation (GDPR). If you have any questions about the personal data generated through your use of such products and related processing activities, please refer to the ZTE Privacy Policy.
The following information is provided in accordance with the Data Act.
1. Data Holder or Data Holding Entity
Enterprise Name: 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 Service
"Connected product" means an item that obtains, generates or collects data concerning its use or environment and that is able to communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the user, in accordance with Article 2 (5) of the Data Act. “Related service” means a digital service, other than an electronic communications service, including software, which is connected with the product at the time of the purchase, rent or lease in such a way that its absence would prevent the connected product from performing one or more of its functions, or which is subsequently connected to the product by the manufacturer or a third party to add to, update or adapt the functions of the connected product in accordance with Article 2 (6) of the Data Act.
ZTE provide smartphones, smartwatches, routers, Set-Top Boxes (STBs), Customer Premises Equipment (CPE), as well as other home information terminals that may be defined as "connected products and/or related service" according to the Articles 2 and 3 of the Data Act. The functions of these products and additional information are described in this statement.
3. Product Data and Related service data
Data holders are required to share user-generated data derived from the use of "connected products" and related services. Based on those definitions of Data Act, we have categorized these data in the table below according to the following criteria:
(1) The definitions of “connected product" and/or “Related service " and it’s data;
(2) The types of products provided by ZTE; and
(3) The scope of data that ZTE may hold.
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 |
Business Function Module |
||||||
STB/TV stick |
Configuration |
Version number |
No |
No |
No |
String format, occupying about 10–20 characters |
Stored in local flash memory until the next version update |
Operating system information |
No |
No |
No |
String format, occupying about 15–30 characters |
Stored in local flash memory and retained for a long time until system upgrade |
||
IP address |
Yes |
Yes |
No |
Dot-decimal string, occupying about 15 characters |
Temporarily stored in local memory, retained as the last valid IP address after network disconnection, and updated upon reconnection |
||
MAC address |
No |
No |
Yes |
Hexadecimal string (with colons), occupying about 17 characters |
Stored in the STB's hardware chip (e.g., EEPROM) and permanently retained |
||
Subnet mask |
Yes |
Yes |
No |
Dot-decimal string, occupying about 15 characters |
Temporarily stored in local memory and updated in response to network configuration changes |
||
Gateway address |
Yes |
Yes |
No |
Dot-decimal string, occupying about 15 characters |
Temporarily stored in local memory and updated in response to network configuration changes |
||
DNS server address |
Yes |
Yes |
No |
Dot-decimal string, occupying about 15 characters |
Temporarily stored in local memory and updated in response to network configuration changes |
||
Device name |
No |
No |
No |
String format, occupying about 20–50 characters |
Stored in local flash memory and retained for a long time until the next modification |
||
Hardware model |
No |
No |
No |
String format, occupying about 10–20 characters |
Built into the hardware chip and permanently retained |
||
Network connection status |
Yes |
Yes |
No |
String format, occupying about 10–15 characters |
Temporarily stored in local memory and refreshed in real time |
||
Storage space information |
Yes |
Yes |
No |
String + number format, occupying about 20–30 characters |
Calculated and displayed in real time locally, with no separate storage of historical data |
||
CPU model |
No |
No |
No |
String format, occupying about 15–30 characters |
Stored in local flash memory and permanently retained |
||
Memory capacity |
No |
No |
No |
String + number format, occupying about 10–15 characters |
Stored in local flash memory and permanently retained |
||
CPE |
ZLife/ZLife Lite |
Terminal common user - account |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
Terminal common user - password |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Terminal common user - terminal router SN (it may bind multiple devices and contain multiple SNs) |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - SN (it binds only a single device) |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - MAC |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - IP |
No |
Yes |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - model |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - vendor |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - version |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
5G FWA 5G MBB 4G FWA 4G MBB Wi-Fi router |
System upgrade |
Device software version number - curversion |
No |
No |
No |
String format, with a single field limited to a maximum of 128 characters |
Stored in Germany and retained until the user cancels the account |
Device IMEI or SN - OID |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Device product model - subtype |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany, retained until next system upgrade |
||
ZTE Smart Life |
Terminal common user - account |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
|
Terminal common user - password |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Terminal common user - terminal router SN (it may bind multiple devices and contain multiple SNs) |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - SN (it binds only a single device) |
No |
No |
No |
String format, with a single field limited to a maximum of 128 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - MAC |
No |
No |
Yes |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - IP |
No |
Yes |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - model |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - vendor |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Router - version |
No |
No |
No |
String format, with a single field limited to a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Smartphone/ Tablet |
System update |
Device IMEI, MEID, or SN |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until next system upgrade |
Device software version number - curversion |
No |
No |
No |
String format, occupying a maximum of 128 characters |
Stored in Germany and retained until next system upgrade |
||
Device product model - subtype |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until next system upgrade |
||
Storage cleanup |
Google Advertising ID (GAID) or iOS Identifier for Advertisers (IDFA) |
No |
No |
Yes |
String format, occupying a maximum of 32 characters |
Stored in Germany and retained for 60 days |
|
Disable restriction on advertisement tracking ID |
No |
No |
No |
String format, occupying a maximum of 2 characters |
Stored in Germany and retained for 60 days |
||
System UA information |
No |
No |
No |
String format, occupying a maximum of 1024 characters |
Stored in Germany and retained for 60 days |
||
Client IP |
Yes |
Yes |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained for 60 days |
||
Device model |
No |
No |
No |
String format, occupying a maximum of 20 characters |
Stored in Germany and retained for 60 days |
||
Screen width |
No |
No |
No |
String format, occupying a maximum of 10 characters |
Stored in Germany and retained for 60 days |
||
Screen height |
No |
No |
No |
String format, occupying a maximum of 10 characters |
Stored in Germany and retained for 60 days |
||
Device manufacturer |
No |
No |
No |
String format, occupying a maximum of 20 characters |
Stored in Germany and retained for 60 days |
||
Application version number |
No |
No |
No |
String format, occupying a maximum of 20 characters |
Stored in Germany and retained for 60 days |
||
Application package name |
No |
No |
No |
String format, occupying a maximum of 255 characters |
Stored in Germany and retained for 60 days |
||
ZTE Care (Overseas) |
Device software version number - curversion |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
|
Device OS information - Android version |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
Device product model - subtype |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
App version name |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
App version code |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
Device OS information - language |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
Device OS information - country |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
Zboard (overseas) |
Device type |
No |
No |
No |
String format, occupying a maximum of 10 characters |
Not stored |
|
Smartwatch |
Watch system update |
Device model |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
Device software version number |
No |
No |
No |
String format, occupying a maximum of 64 characters |
Not stored |
||
Device IMEI |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Not stored |
||
Security guard |
Device latitude and longitude |
Yes |
No |
Yes |
String format, occupying a maximum of 10 characters |
Stored in Germany and retained for 7 days |
|
TinyChat |
Voice message |
Yes |
Yes |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained for 3 days |
|
Text message |
Yes |
Yes |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained for 3 days |
||
Call and message |
Message |
Yes |
No |
Yes |
String format, occupying a maximum of 256 characters |
Stored in Germany and retained for 3 days |
|
Movement |
Steps |
Yes |
No |
No |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained for 7 days |
|
Account |
Email address |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
|
Avatar |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Nickname |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until the user cancels the account |
||
Watch contacts |
Contact name |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until the user unbinds or deletes the device |
|
Phone number |
No |
No |
Yes |
String format, occupying a maximum of 64 characters |
Stored in Germany and retained until the user unbinds or deletes device |
||
Please note that these data details may change to align with:
1) any future guidance issued from time to time by EU agencies;
2) ZTE's business strategy or changes in product functionality.
4. Data Sharing and Access Implementation
If you believe you are a user under the Data Act and wish to exercise your rights, you may contact us at DataPrivacy@zte.com.cn.
We will review and respond to your request within a reasonable timeframe.
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); and
3) Other information that helps us assess your request.
ZTE reserves the right to decline requests under the following circumstances:
1) The submitted information is insufficient;
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 there are no necessary measures or contracts in place to preserve its security and confidentiality; or
4) The recipient is designated as a gatekeeper pursuant to Article 3 of Regulation (EU) 2022/1925.
If your request is denied, we will provide you with a response stating the reasons for refusal.
Upon receipt of such data, you may use and share it only for legitimate purposes in accordance with applicable laws.
5. Data Security Protection Mechanism
To prevent potential unauthorized access, use, or disclosure, we implement necessary technical and organizational security safeguards 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; and
5) Adoption of other safeguards as necessary to comply with applicable laws.
Data will be shared in machine-readable, commonly used formats (e.g., JSON and XML) or in other formats.
6. Data Request Mechanism
If you wish to exercise your rights under the Data Act, you may submit your requests via the following channel:
Email: DataPrivacy@zte.com.cn
Mail: 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 within a reasonable timeframe.
7. Update to This Statement
ZTE may update this statement from time to time. We will publish the updated statements in a prominent location on our official website.
8. Declaration
ZTE provides this Statement in various local languages. Should there be any conflict or inconsistency between a local language version and the English version, the English version shall prevail. ZTE reserves the right of final interpretation of this Statement.
The following language versions for your reference
language |
Translation |
Polski |
|
Italiano |
|
Español |
Compromiso de ZTE con el Cumplimiento de la Ley de Datos de la UE |
Dansk |
|
Slovenščina |
|
Română |
|
Svenska |
|
Suomi |
|
Eesti |
|
Hrvatski |
|
Nederlands |
|
Slovenčina |
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Malti |
|
Lietuvių |
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Latviešu |
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Gaeilge |
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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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