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ZTE Compliance Commitment on 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 right under the EU Data Act (Regulation (EU) 2023/2854) (the “Data Act”) and are committed to complying with the relevant requirements under the Data Act.

Certain products and services which are placed on the EU market by us satisfy the definitions of connected product under the Data Act, and with respect to such products, we may need to comply with the obligations to make certain product data accessible to users or their representatives or their designed data recipients (collectively, "you", or "your"). This statement contains relevant information on how we share users with such data to comply with the Data Act.

Please note that product data may contain personal data and the processing and sharing of personal data shall also comply with the GDPR. If you have any questions about the personal data generated during the use of such products and their processing activities, please refer to 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.

Regarding registered address of our subsidiaries, please refer to: Corporate Information-ZTE.

2. Connected Products

“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).

ZTE provide Smartphones, Smartwatches, Routers, STBs, CPEs as well as the other home mobile devices that may defined as the “Connected Product” according to the Article 2 and Article 3 of Data Act. Such products functions and further information are described in this statement:

3. Product Data

Data holders are required to share user-generated data derived from the use of connected products and related services. Based on the definitions of connected products and product data, we have categorized our product data according to the following criteria in the table below.

(1) The definition of connected products and product data;

(2) The types of products provided by ZTE; and

(3) The scope of data that ZTE may hold.

Connected Product		Data types	Can the data be generated continuously	Can the data be generated in real time	Is it personal data	Data format and magnitude	Storage method and duration
Product type	Business function module	Data types	Can the data be generated continuously	Can the data be generated in real time	Is it personal data	Data format and magnitude	Storage method and duration
STB/TV stick	Configuration	Version number	No	No	No	String format, occupying about 10-20 characters	Stored in the device's 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, retained for a long time until system upgrade
		IP address	Yes	Yes	No	Dot-decimal string, occupying about 15 characters	Temporarily stored locally, retained as the last valid IP after network disconnection, and updated upon reconnection
		MAC address	No	No	Yes	Hexadecimal string (with colons), occupying about 17 characters	Stored in the set-top box's hardware chip (e.g., EEPROM), permanently retained
		Subnet mask	Yes	Yes	No	Dot-decimal string, occupying about 15 characters	Temporarily stored locally, updated with network configuration changes
		Gateway address	Yes	Yes	No	Dot-decimal string, occupying about 15 characters	Temporarily stored locally, updated with network configuration changes
		DNS server address	Yes	Yes	No	Dot-decimal string, occupying about 15 characters	Temporarily stored locally, updated with network configuration changes
		Device name	No	No	No	String format, occupying about 20-50 characters	Stored in local flash memory, 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, permanently retained
		Network connection status	Yes	Yes	No	String format, occupying about 10-15 characters	Temporarily stored in local memory, 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, no separate storage of historical data
		CPU model	No	No	No	String format, occupying about 15-30 characters	Stored in local flash memory, permanently retained
		Memory capacity	No	No	No	String + number format, occupying about 10-15 characters	Stored in local flash memory, permanently retained
CPE	ZLife/ZLife lite	Terminal common user-Account	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Terminal common user-Password	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Terminal common user-Terminal Router SN( it may bind multiple devices and contain multiple SNs)	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-SN ( Just bind single device)	No	No	No	String format, a single field must be less than 128 characters	Stored in Germany, retained until user cancels the account
		Router-MAC	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-IP	No	Yes	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-Model	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-Vendor	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-Version	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
5G FWA 5G MBB 4G FWA 4G MBB Wifi router	System upgrade	Device software version number -curversion	No	No	No	String format, a single field must be less than 128 characters	Stored in Germany, retained until next system upgrade
		Device IMEI or SN-oid	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until next system upgrade
		Device Product Model-subtype	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until next system upgrade
	ZTE Smart Life	Terminal common user-Account	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Terminal common user-Password	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Terminal common user-Terminal Router SN( it may bind multiple devices and contain multiple SNs)	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-SN ( Just bind single device)	No	No	No	String format, a single field must be less than 128 characters	Stored in Germany, retained until user cancels the account
		Router-MAC	No	No	Yes	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-IP	No	Yes	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-Model	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-Vendor	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
		Router-Version	No	No	No	String format, a single field must be less than 64 characters	Stored in Germany, retained until user cancels the account
Smart phone/ Tablet	System update	Device IMEI or MEID or SN	No	No	Yes	string format, Less than 64 characters	Stored in Germany, retained until next system upgrade
		Device software version number -curversion	No	No	No	string format, Less than 128 characters	Stored in Germany, retained until next system upgrade
		Device Product Model-subtype	No	No	No	string format, Less than 64 characters	Stored in Germany, retained until next system upgrade
	Storage cleanup	Google Advertising ID (GAID) OR iOS (IDFA)）	No	No	Yes	string format, Less than or equal to 32 characters	Stored in Germany, retained for 60 days
		Disable Restriction on Advertisement Tracking ID	No	No	No	string format, Less than or equal to 2 characters	Stored in Germany, retained for 60 days
		System ua Information	No	No	No	string format, Less than or equal to 1024 characters	Stored in Germany, retained for 60 days
		Client IP	Yes	Yes	Yes	string format, Less than or equal to 64 characters	Stored in Germany, retained for 60 days
		Device Model	No	No	No	string format, Less than or equal to 20 characters	Stored in Germany, retained for 60 days
		Screen Width	No	No	No	string format, Less than or equal to 10 characters	Stored in Germany, retained for 60 days
		Screen Height	No	No	No	string format, Less than or equal to 10 characters	Stored in Germany, retained for 60 days
		Device Manufacturer	No	No	No	string format, Less than or equal to 20 characters	Stored in Germany, retained for 60 days
		Application Version Number	No	No	No	string format, Less than or equal to 20 characters	Stored in Germany, retained for 60 days
		Application Package Name	No	No	No	string format, Less than or equal to 255 characters	Stored in Germany, retained for 60 days
	ZTE Care (Overseas)	Device software version number -curversion	No	No	No	string format, Less than 64 characters	Not stored
		Device OS Information-Android Version	No	No	No	string format, Less than 64 characters	Not stored
		Device Product Model-subtype	No	No	No	string format, Less than 64 characters	Not stored
		App VersionName	No	No	No	string format, Less than 64 characters	Not stored
		App VersionCode	No	No	No	string format, Less than 64 characters	Not stored
		Device OS Information-Language	No	No	No	string format, Less than 64 characters	Not stored
		Device OS Information-Country	No	No	No	string format, Less than 64 characters	Not stored
	Zboard (overseas)	Device Type	No	No	No	string format, Less than 10 characters	Not stored
Smart watch	Watch System update	Device Model	No	No	No	string format, Less than 64 characters	Not stored
		Device software version number	No	No	No	string format, Less than 64 characters	Not stored
		Device IMEI	No	No	Yes	string format, Less than 64 characters	Not stored
	Security guard	Device latitude and longitude	Yes	No	Yes	string format, Less than 10 characters	Stored in Germany, retained for 7 days
	TinyChat	Voice message	Yes	Yes	Yes	string format, Less than 64 characters	Stored in Germany, retained for 3 days
	TinyChat	Text message	Yes	Yes	Yes	string format, Less than 64 characters	Stored in Germany, retained for 3 days
	Call and Message	Message	Yes	No	Yes	string format, Less than 256 characters	Stored in Germany, retained for 3 days
	Movement	Steps	Yes	No	No	string format, Less than 64 characters	Stored in Germany, retained for 7 days
	account	email address	No	No	Yes	string format, Less than 64 characters	Stored in Germany, retained until user cancels the account
		avatar	No	No	Yes	string format, Less than 64 characters	Stored in Germany, retained until user cancels the account
		nickname	No	No	Yes	string format, Less than 64 characters	Stored in Germany, retained until user cancels the account
	Watch contacts	contact name	No	No	Yes	string format, Less than 64 characters	Stored in Germany, retained until user unbind or delete device
	Watch contacts	phone number	No	No	Yes	string format, Less than 64 characters	Stored in Germany, retained until user unbind or delete device

Please note that product data details may change based on the following criteria:

1) To be consistent with guidance that may be issued from time to time by EU agencies in the future;

2) To be consistent with 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 request relevant information to verify your identity (individual, legal person or other forms of entity) as a user, and you may need to provide one or more of the following information:

1) Your email address;

2) Recipient's email address (for data transmission); and

3) Other information helps us assess your requests.

ZTE reserves the right to decline requests if:

1) Submitted information is insufficient;

2) The request seeks others’ personal data without legal basis;

3) The data involves trade secrets or IP-protected content without necessary measures and 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 only use and share such data for legitimate purposes in accordance with the applicable law.

5. Data security protection mechanism

To prevent potential unauthorized access, use, or disclosure, we implement necessary technical and organizational security safeguards to ensure data and its sharing are reasonably protected. These 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) Regularly review security practices regarding data collection, storage and processing to keep update with industry-standard practices; and

5) Other safeguards maybe adopted to comply with applicable law.

Data will be shared in machine-readable, commonly used formats (e.g., JSON/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: [DataPrivacy@zte.com.cn] ,or mail us through the following address: Data Compliance Dept. of ZTE Corporation, No. 55, Hi-Tech Road South, Shenzhen, P.R. China (postcode: 518057). We may assess your request within reasonable time limit.

7. Update to this statement

ZTE may update this statement from time to time and we will publish the updated statements in a noticeable place on our official website.

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ZTE Compliance Commitment on EU Data Act