一、Data Act Commitment
Respecting the legal rights of EU users to product data under the EU Data Act (Regulation (EU) 2023/2854) is the compliance operation philosophy implemented by NUBIA when designing and providing products and services.
You have the right to understand the details of data generated by these connected products and may require NUBIA to legally safeguard your rights concerning data access, sharing, and transfer. For specific methods and operational guidance on data acquisition, please refer to the "NUBIA Compliance Commitment on EU Data Act". You may obtain the following information therein:
1. Data overview of the entire series of connected products;
2. Specific data types generated by this connected product. (Please understand that different products will generate specific data due to functional differences.)
二、 Data Act Statement
NUBIA Compliance Commitment on EU Data Act
Version: 1.0
Effective Date: 2025-09-12
Introduction
NUBIA Corporation and its subsidiaries (collectively, "NUBIA", "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 NUBIA Privacy Policy.
The following information is provided in accordance with the Data Act.
1. Data Holder or Data Holding Entity
Enterprise Name: NUBIA Corporation and its subsidiaries.
Registered Address: 16th Floor, Building 2, Chongwen Park, Nanshan Zhiyuan, No. 3370 Liuxian Avenue, Nanshan District, Shenzhen, China.
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).
NUBIA provide Smartphones 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 NUBIA; and
(3) The scope of data that NUBIA may hold.
Note: The data fields filled in for the nubia advertisements for space cleanup and browser nubia advertisements are inconsistent. The storage time limits on the server are also inconsistent. Space cleanup is stored for 60 days, while browser advertisements are stored for 7 days.
| 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 mudule | ||||||
| Smart phone | System update | Device IMEI or MEID or SN | No | No | Yes | string format, Less than 64 characters | Storage mode: Germany AWS server is used in Europe. Storage period: The information about the last upgrade of the user equipment is stored for five years. Expiration handling method: Delete |
| Device software version number -curversion | No | No | No | string format, Less than 128 characters | |||
| Device Product Model-subtype | No | No | No | string format, Less than 64 characters | |||
| storagecleanup | Google Advertising ID (GAID) OR iOS (IDFA)） | No | No | Yes | string format, Less than or equal to 32 characters | Stored in Germany for 60 days. | |
| Disable Restriction on Advertisement Tracking ID | No | No | No | string format, Less than or equal to 2 characters | |||
| System ua Information | No | No | No | string format, Less than or equal to 1024 characters | |||
| Client IP | Yes | Yes | Yes | string format, Less than or equal to 64 characters | |||
| Device Model | No | No | No | string format, Less than or equal to 20 characters | |||
| Screen Width | No | No | No | string format, Less than or equal to 10 characters | |||
| Screen Height | No | No | No | string format, Less than or equal to 10 characters | |||
| Device Manufacturer | No | No | No | string format, Less than or equal to 20 characters | |||
| Application Version Number | No | No | No | string format, Less than or equal to 20 characters | |||
| Application Package Name | No | No | No | string format, Less than or equal to 255 characters | |||
| zboard(overseas) | Device Type | No | No | No | string format, Less than 10 characters | Server query data is used and is not stored. | |
| Goper | Device OS Information-Language | No | No | No | string format, Less than 64 characters | Server query data is used and is not stored. |
|
| Device OS Information-Country | No | No | No | string format, Less than 64 characters | |||
| browser | Device Operating system name | No | No | No | string format, Less than 64 characters | Stored in Germany for 7 days. | |
| Google Advertising ID (GAID) | No | No | Yes | string format, Less than 64 characters | |||
| Client IP | Yes | Yes | Yes | string format, Less than or equal to 64 characters | |||
| Device Model | No | No | No | string format, Less than or equal to 20 characters | |||
| App VersionName | No | No | No | string format, Less than 64 characters | |||
| Device OS Information-Language | No | No | No | string format, Less than 64 characters | |||
| Device OS Information-Country | No | No | No | string format, Less than 64 characters | |||
| Device OS Information-Android Version | No | No | No | string format, Less than 64 characters | |||
| Daily Wallpaper | Device Type | No | No | No | string format, Less than 10 characters | Server query data is used and is not stored. | |
| Device OS Information-Language | No | No | No | string format, Less than 64 characters | |||
| Device OS Information-Country | No | No | No | string format, Less than 64 characters | |||
| Application Package Name | No | No | No | string format, Less than or equal to 255 characters | |||
| Device software version number -curversion | No | No | No | string format, Less than 64 characters | |||
| Device OS Information-Android Version | No | No | No | string format, Less than 64 characters | |||
| Device Product Model-subtype | No | No | No | string format, Less than 64 characters | |||
| AIGC | Device Product Model-subtype | No | No | No | string format, Less than 64 characters | Server query data is used and is not stored. | |
| Screen Width | No | No | No | string format, Less than 64 characters | |||
| Screen Height | No | No | No | string format, Less than 64 characters | |||
| Themes | Device Model | No | No | No | string format, Less than 20 characters | Server query data is used and is not stored. | |
| Screen Width | No | No | No | string format, Less than or equal to 10 characters | |||
| Screen Height | No | No | No | string format, Less than or equal to 10 characters | |||
| Device IMEI or MEID or SN | No | No | Yes | string format, Less than 64 characters | |||
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 NUBIA’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 [support@redmagic.com],
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.
NUBIA 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:[support@redmagic.com],or mail us through the following address: Data Compliance Dept. of NUBIA Corporation, 16th Floor, Building 2, Chongwen Park, Nanshan Zhiyuan, No. 3370 Liuxian Avenue, Nanshan District, Shenzhen, China.（ Postcode: 518055）. We may assess your request within reasonable time limit.
7. Update to this statement
NUBIA may update this statement from time to time and we will publish the updated statements in a noticeable place on our official website.
