Compliance Commitment on EU Data Act

Effective Date: 2026-01-13

Introduction

Nubia Technology Co., Ltd and its subsidiaries 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 which are placed on the EU market by us satisfy the definitions of connected product under the Data Act. 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' 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 https://redmagic.gg/policies.

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. 

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.gg]

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.gg], 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.