Tuya Smart Mobile Privacy Policy

The latest version: 20201228

Tuya Inc., its affiliates and subsidiaries (“we”, “us”, “our”, “Tuya”) are committed to protecting your privacy. This Mobile Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

• Tuya Smart Mobile Application

(For Products version 3.18.0 or later) You may still use numerous Tuya services when you are signed out or without creating an account at all, such as searching and browsing any features on the Products.

Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways to execute your rights of access, update, delete or protect your Personal Data.

When you accept this Policy when you register with your Personal Data, or if you start to use our Products and does not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any question r regarding this Policy, please do not hesitate to contact us via:

Service Department: 400-881-8611 or service@tuya.com

Privacy Office: privacy@tuya.com

For other branded mobile applications powered by Tuya, our Clients control all the Personal Data collected through our Products. We collect the information under the direction of our Clients and the processing of such information shall be limited to the purpose of providing the service for which our Clients has engaged us. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.

*Definitions*

In this Policy, *Personal Data* means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.

*Personal Sensitive Data* includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collection personal sensitive data about you.

*Smart Devices* refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.

*What Personal Data Do We Collect*

In order to provide our Products to you, we will ask you to provide necessary Personal Data that is required to provide those Products. If you do not provide your Personal Data, we may not be able to provide you with the Products.

*1. Information You Voluntarily Provide Us*

• Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.

If you authorize login to the Products with a third party account, we will obtain from such third party your account information (such as portrait, nickname, region, gender, etc.) which may be bound with your Tuya account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.

• Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

*2. Information We Collect Automatically*

• Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

• Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

• Log Information: When you use our app, the system and exception log may be uploaded.

Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information , may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.

• Location Information: When you enable location-based functions through permission settings on your mobile device, we will collect and process your location information to enable certain functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time precise or non-precise geo-location when you use certain Smart Devices or relevant services, such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature on the Products, your location information will be generated and shared with Google Map services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the Products, upon which we will cease to collect and use your location information.

*3. Smart Devices Related Information:*

• Basic Information of Smart Devices: When you connect your Smart Devices with our Products, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

• Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or videos captured by it. Particularly, when you proactively consent to our Products connecting with Apple Health, we will share your health data (exclusively to your BMI, height, weight and body fat%) with Apple Health for the sole purpose of measuring and analyzing heath related indicators about you. We will not disclose such health data to any other third party. You may disconnect the Products with Apple Health at any time by managing your HealthKit settings on your smartphone.

*Purposes and Legal Basis for Processing Personal Data*

The purpose for which we may process information about you are as follows:

• Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,

• Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.

• Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.

• Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

*Who do We Share Personal Data with?*

At Tuya, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

• To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

• To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.

• To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.

• As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

Except for the third parties described above, to third parties only with your consent.

*International Transfer of Information Collected*

To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:

l Agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.

*Your Rights Relating to Your Personal Data*

We respect your rights and control over your Personal Data. You may exercise any of the following rights:

• Via the “Me > Personal Center > Account and Security” or via “Me > FAQ&Feedback” in our Products (for Product version 3.2 and later).

• By emailing us at privacy@tuya.com (for Product version before 3.2)

You do not have to pay a fee for executing your personal rights. According to different data protection laws, your request of personal rights will be handled within 15 business days, or within 30 calendar days due to different response requirement.

If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may:

• Request access to the Personal Data that we process about you;

• Request that we correct inaccurate or incomplete Personal Data about you;

• Request deletion of Personal Data about you;

• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;

• Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated;

• Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

*• Withdrawal of consent*: We will exercise your privacy right to withdraw consent through the following approaches:

1) For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notifications and other related functions;

2) In the marketing communications that you agree to, the information we send to you contains instructions that allow you to withdraw your consent in accordance with the “unsubscribe” method described in the information;

3) Unbind the Smart Device through the app, and the information related to the Smart Device will not be collected;

4) By using product with the visitor mode, we will not collect any personal data about you;

When you withdraw your consent or authorization, we may not be able to continue to provide you with the products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.

About Delete of the Account: You can find the Delete function through “Me > Personal Center(Portrait) > Account and Security > Delete Account” (“Deactivate Account” for the App version under 3.16.5).

*Security Measures*

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Tuya provides various security strategies to effectively ensure data security of user and device. As for device access, Tuya proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing privacy@tuya.com.

*Data Retention*

We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

*Dispute Resolution*

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

*Children’s Privacy*

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information.

*Changes to this Policy Policy*

We may update this Privacy Policy to reflect changes to our information practices, at least on an annual basis. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

*Contact Us*

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

Tuya Inc.

Postal Mailing Address: 75 E Santa Clara St, 6th Floor, San Jose, CA 95113

Email: privacy@tuya.com.

For European Union or United Kingdom data subjects, you have the right to lodge a complaint with a supervisory authority concerning Tuya’s data processing activities. For questions, or to exercise your rights as an EU or UK data subject, please contact our EU/UK Representative here:

Name: Rechtsanwaltsgesellschaft Rickert mbH

Email: datenschutz@rickert.net

Emailing Address: Colmantstraße 15, 53115 Bonn, Germany