Data Access and Sharing Notice

Published: September 4, 2026

A. Introduction

This statement is intended to inform you about your rights and choices regarding the access to and sharing of data generated through the use of our connected products and services. You will learn what data is collected, how to request or share this data, and the applicable safeguards and procedures. Through this statement, you will clearly understand how your data is protected under Regulation (EU) 2023/2854, the EU Data Act.

This Data Access and Sharing Notice (hereinafter referred to as the “Notice”) is provided by Gree Spain Corporation, SL (hereinafter referred to as “we”, “us” or “our”) acting as data holder, pursuant to Regulation (EU) 2023/2854 (the “EU Data Act”).

B. Purpose

In accordance with Article 3(2) of the EU Data Act, this Notice informs you (hereinafter referred to as “you” or the “user”) of the following before you conclude any contract with us or use our connected products and related services:

• The types of data generated by your use of our connected products and related services;

• How you can access, use and share such data, including with third parties of your choice;

• The procedures for requesting data access or sharing;

• Any restrictions or exclusions that may apply (see also the “Restrictions and Safeguards” and “Trade Secrets and Intellectual Property” sections).

C. Scope of Application

This Notice applies to all users of our connected products and related services — including business users (B2B) and consumer users (B2C).

This Notice covers data generated through the use of our connected products and related services, including but not limited to (hereinafter referred to as the “Data”):

Connected products:

Physical products that acquire, generate or collect data concerning their use, performance or environment, and that are able to communicate such data via electronic communication services, physical connection or on-device access.

Household appliances, such as air conditioning equipment, air purification equipment, heating systems, ventilation equipment, refrigeration equipment, control panels and smart sensors, etc.

Related services:

All digital services (including software) that are embedded in or inter-connected with a connected product, that are necessary for the product to perform its functions, or that enable the user to access, collect or use data generated by the connected product.

D. Data Types

The following categories of data may be generated and collected through the use of our connected products and related services:
Status data—for example: firmware version

Sensors or measurement data—such as: temperature, humidity
Usage data—such as: feature usage

Operating data-e.g. operating mode

Diagnostic data-e.g. error codes

User feedback data-for example, feedback voluntarily submitted through an app or platform to improve product features

Metadata-for example: data about data-such as timestamps, data source identifiers, and delivery logs

E. Your Rights under the EU Data Act

Rights	Description
Right of Access (Access)	You may obtain the data generated by your use of the connected products and related services.
Right to Data Portability (Portability)	If you wish, your data can be transferred to another provider.
Third-party sharing (Third-party sharing)	You may authorise third parties to access your data.
Non-discrimination (Non-discrimination)	You are entitled to fair and equal conditions when accessing and using data.
Transparency (Transparency)	You have the right to know how your data are used and shared.

F. Data Access — Rights and Procedures

1) Subjects of Access

You (the data user):

◦ As a user, owner or lessee of a connected product (or related service), you are entitled to:

◦ Access free of charge all data generated by your use.

◦ Request your data in a structured, commonly used and machine-readable format (CSV/PDF).

Authorised third parties:

You may authorise third parties (such as service providers, data analytics companies or insurers) to access data generated by your use of our connected products and related services. Data access is granted only with your explicit consent and is limited to the categories of data you specify. Third parties must enter into a data use agreement and may not use your data to develop competing products or services. You will be informed when your data are shared with third parties, and you may withdraw your consent to third-party access at any time by notifying us.

We (the data holder):

We may access and use the data for the following purposes:

◦ Product functionality and support (e.g.: diagnostics, software updates)

◦ Service optimisation (e.g.: improving efficiency and security)

◦ Predictive maintenance (e.g.: alert generation, failure prevention)

◦ Aggregated analysis (e.g.: usage trend insights, non-personal data)

◦ Business management and customer management

◦ Product distribution and supplier management

◦ Direct marketing (where permitted)

◦ Improving the quality of products and services

◦ Bookkeeping and accounting

◦ Handling complaints and legal disputes

◦ Prevention of fraud or crime
◦ Corporate affairs and administration

Public sector bodies:

Certain public sector bodies or organisations may request access to data for crisis response, public safety, environmental protection or law enforcement purposes (subject to strict legal requirements). We will respond to valid and proportionate requests in accordance with Article 21 of the EU Data Act.

2) How to Request Access

You may request access by sending an email to privacy@cn.gree.com from the email address registered with the Smart Home APP.

Please specify your connected product and the types of data requested. Please indicate whether the data should be provided to a third party, or whether you are a third party acting on behalf of a user. We may require proof of identity and proof of authorised use.

Once your request has been verified, we will prepare and confirm the data. You will receive the data in a structured, commonly used format (CSV/PDF) within 60 days, together with download instructions.

3) Fees, Format and Frequency

As a user of connected products, your access to data is free of charge.

If you request that your data be shared with a third-party data recipient, we may request reasonable compensation from the data recipient in accordance with Article 9 of the EU Data Act, for providing the access or sharing service. The level of compensation will reflect the costs and value of providing the data. This does not affect your right to receive data free of charge under the GDPR data portability rules.

Data will be provided in a structured, commonly used and machine-readable format (CSV/PDF).

The volume and frequency of data provision depend on the connected product and the use scenario. Data may be provided as a one-off download.

4) Restrictions and Safeguards

In certain exceptional circumstances, we reserve the right to restrict or prohibit access to, use of, or further sharing of data generated by you, in order to ensure compliance with security requirements under EU or national law.

No information about your economic situation or assets will be inferred from the use of the data. The data will not be used in any manner that causes substantial harm to your legitimate interests.

We have implemented appropriate organisational and technical measures to protect the generated data, in particular against unlawful and unauthorised access by third parties.

Users and recipients authorised by users to obtain the data may use the data obtained for all lawful purposes, provided that they comply with the following statutory restrictions that protect the data holder's innovation investments:

 

1. No competing use: The data must not be used to develop connected devices that compete directly with our connected products; nor may the data be shared with third parties having such development intent, or with “gatekeeper platforms” as defined in Regulation (EU) 2022/1925.

2. No commercial espionage: The data must not be used to probe our business condition, corporate resources or production process information.

3. No unlawful acquisition: Data access must not be obtained unlawfully, whether by coercion or by exploiting vulnerabilities in our technical systems.

 

5) Direct and Real-Time Access by Design

With effect from 12 September 2026, our connected products will ensure, at the design and manufacturing stage, that users can access product data and related service data directly, by default and in real time, free of charge, and in a comprehensive, structured, commonly used and machine-readable CSV/PDF format. This obligation only entails providing access; it does not require us to actively transmit the data to you.

G. Sharing of Non-Personal Data

We may share data generated through the use of our connected products and related services with third parties for commercial and non-commercial purposes, such as research institutions (for research related to connected products) or application developers (for maintenance, updates, analysis and improvement). When we share data, adequate safeguards will be implemented to ensure confidentiality and compliance with applicable laws.

Data recipients may be required to implement adequate safeguards to maintain confidentiality. If adequate protection cannot be ensured, sharing may be suspended or refused.

For general safeguards and restrictions, please refer to the “Restrictions and Safeguards” section.

For restrictions concerning trade secrets and intellectual property, please refer to the “Trade Secrets and Intellectual Property” section below.

You may withdraw your request for sharing data with third parties at any time by sending a written notice to privacy@cn.gree.com. After withdrawal, we will stop providing access to the relevant data to the designated third parties without undue delay.

If the data recipient acts in a professional capacity, a separate agreement must be concluded on fair, reasonable and non-discriminatory terms prior to the sharing, in accordance with the requirements of Chapters III and IV of the EU Data Act.

H. Data Storage and Retention

Data generated by your use of our connected products and related services is stored on secure servers located in the European Economic Area (EEA), for a maximum retention period of three months, unless applicable law or regulatory obligations require a longer retention period, or unless a longer period is necessary for the establishment, exercise or defence of legal claims.

I. Trade Secrets and Intellectual Property

Certain data may be protected as trade secrets under Directive (EU) 2016/943, or protected by intellectual property rights. Under the EU Data Act, we will only refuse or restrict access to such data where disclosure would genuinely undermine these rights. Where possible, we will take reasonable measures (such as entering into confidentiality agreements) to enable data sharing while protecting trade secrets and intellectual property. If access is restricted for these reasons, we will notify you and, where feasible, provide partial access to the data or a summary of the data.

J. Changes to this Notice

We may update this Notice to reflect regulatory changes or improvements in our data practices. All updates will be published on our website.

K. Your Right to Complain

For disputes relating to access to or sharing of the generated data, you have the right to lodge a complaint with the competent national authority designated pursuant to Article 37 of the EU Data Act, or to submit the dispute to a certified dispute resolution body.

L. Fair Contract Terms

According to Chapter IV of the EU Data Act, we will not unilaterally impose unfair contract terms on users (especially micro, small, and medium-sized enterprises).

Data Holder and Contact Information

Gree Spain Corporation, SL

Carrer Camps i Fabres 3-11, 3-7, 08006 Barcelona, Spain

Contact information：gree_spain@greespain.com