EU Data Act Transparency Declaration

In accordance with Regulation (EU) 2023/2854 (the “EU Data Act“”), we, Proscenic, provide the following information about our Connected Products and Related Services (“products and services”). This declaration is intended to give customers and users details about the types of data generated by our products or services, how that data is handled, and how access is enabled. It also outlines the nature, volume, and storage of such data, the purposes for which it is used, and the conditions under which it may be accessed or shared, in accordance with the EU Data Act.

Please note: Depending on the specific customizations, add-ons selected, and additional services selected for the products and services, the types, frequencies and amounts of data gathered and processed may vary.

Where information changes during the lifetime of the product or service, this information will be updated accordingly.


1. Connected Product Status

Our products (floor cleaning robots ) are connected products within the meaning of Regulation (EU) 2023/2854 (EU Data Act), as they are capable of collecting data concerning their use, performance, and environment, and transmitting such data via network connections (e.g., Wi-Fi, Bluetooth, etc.). This declaration provides the pre‑contractual information required under Article 3(2) of the EU Data Act.


2. Types and Attributes of Generated Data

2.1 Product Data Attributes

  • Content: Product status data and usage logs.
  • Format: Collected in JSON format; stored in MySQL tables; exportable as XLS.
  • Collection Frequency: Real‑time or event‑triggered.
  • Data Volume: 10 KB to 5,000 KB per day (approx. 0.01 MB – 5 MB).
  • Continuous Generation Condition: Only upon event occurrence or device status change.

2.2 Service Data Attributes

  • Content: User operation logs (e.g., setting changes, device binding/unbinding, power on/off, automation triggers, cleaning control, docking) and service events (e.g., app usage logs, activity timestamps, app crash events).
  • Format: Collected in JSON format; stored in MySQL tables; exportable as XLS.
  • Collection Frequency: Triggered by user interaction with the App or during automation execution.
  • Data Volume: 10 KB to 500 KB per day (depending on usage intensity).
  • Continuous Generation Condition: Only upon user operation or automation trigger.


2.3 Specific Product Data Types and Volumes

Product Type Data Types Daily Data Volume (approx.)
Floor Cleaning Robot Working status/mode, cleaning map/path, battery level, connection status, device information  ~979 KB (increases with frequent use)


3. Data Storage and Use

3.1 Data Storage

  • Data is stored on remote servers located within the EU (Germany). The device only stores data locally on a temporary basis; new status records overwrite old ones, and no historical records are retained.
  • Product logs (data points) and user operation records are retained for 7 days by default and automatically deleted thereafter.
  • Service event logs are retained for a maximum of 1 year and automatically deleted upon expiry.


3.2 Purpose of Data Use

Data may be processed for the following purposes: contract performance, security assurance, troubleshooting, and product improvement (where applicable).


4. User Rights

4.1 Data Access

Device data can be viewed, downloaded, or exported directly through the App interface:

  • View Personal Information: App → “Me” → Personal Avatar → View Personal Information
  • Export Device Information: App → Enter Device Control Panel → Settings (top right) → Device Information → Copy

4.2 Data Deletion

  • Cloud Data: Delete your App account at any time to remove data stored in the cloud.
  • Device Data: Perform a factory reset on the product.
  • Local App Data: Uninstall the App to delete local data.

4.3 Right to Lodge a Complaint

You have the right to lodge a complaint with the supervisory authority in an EU Member State. A list of national supervisory authorities can be obtained from the European Commission.

 

5. Data Sharing

You have the right to share data with third parties:

5.1 One‑time Sharing

Export data via the App yourself and provide it to a third party.

5.2 Continuous Sharing

Continuously share device data with a third party via an authorisation QR code:

  • The third party must register and subscribe to cloud services at https://platform.tuya.com/cloud.
  • The third party applies for an authorisation key and generates an authorisation QR code.
  • You scan the QR code and select the device to authorise in the App.

You can revoke authorisation at any time via App →"Me"→ Devices → Account & Security → Cloud Development Projects.


6. Protection of Trade Secrets

Trade secrets refer to the unique ways we create our products or services and are valuable information that prevents others from competing. Some data may contain trade secrets. Where applicable, we will notify you.


7. Agreement Duration

This notice remains valid for the duration of your account's validity. You may terminate the agreement at any time by deleting your account.