EnergyEase Privacy Policy

Updated on: October 15, 2024
Effective from: October 31, 2024
Preamble
EnergyEase is a home energy management system provided by MANOS Energy GmbH (registered in Unterhaching, Bavaria, Germany, at Sommerstrasse 23, 82008; Tel.: +49 1743150766; Email: info@manos.ai; hereinafter referred to as "we," "the controller," or "Manos"). This guide explains how EnergyEase collects, uses, and stores your personal information and outlines your rights. The main contents are as follows:

1. We strictly adhere to relevant laws and regulations, including but not limited to the General Data Protection Regulation (GDPR) of the European Union, for data collection and processing activities. We will explain the types of your personal information we collect and their corresponding purposes one by one, so that you can understand the specific types of personal information we collect for specific functions, the reasons for their use, and the collection methods.
2. When you use certain functions, we will collect your personal information after obtaining your consent. If you use the QR code scanner to identify data collectors, we will request camera access; when you use the function to create stations, we will collect your mobile phone's location information. Unless such information must be collected according to relevant laws and regulations, refusing to provide this information will only prevent you from using the specific features concerned but will not affect your normal use of other EnergyEase functions. For details, see the "Instructions on System Permissions Request and Usage."
3. We will not actively share or transfer your personal information to third parties outside of Manos. If there are other circumstances requiring the sharing or transfer of your personal information to third parties outside of Manos, or if you request us to do so, we will directly obtain or confirm that the third party has obtained your consent. Explicit consent for the aforementioned actions, except as otherwise stipulated by laws and regulations or for the purpose of protecting user rights and the security of the EnergyEase business ecosystem, will be subject to our risk assessment before providing information externally.
4. We will not actively obtain your personal information from third parties outside of Manos. If we need to obtain your personal information from third parties for business expansion, we will verify the legality of the information source according to legal provisions or clearly inform you of the source, type, and scope of use of the personal information before obtaining it. If the personal information processing activities required by the EnergyEase business exceed the scope authorized and agreed upon when you initially provided your personal information to the third party, we will obtain your explicit consent before processing your personal information; additionally, we will strictly comply with relevant laws and regulations and require the third party to ensure the legality of the information provided.
5. You can access, modify, copy, delete your personal information, withdraw your consent, delete your account, make complaints and reports, and use other privacy features through the methods listed in this guide.
6. To collect your information according to this guide or provide you with services, optimize our services, and protect your account security, we need to request relevant permissions from you; sensitive permissions (such as location, camera, and photo album) will not be enabled by default, and we will only use them within the scope of your explicit consent when you grant it. For the system permissions you have already authorized to us, you can also query the types and purposes of the system permissions we have invoked or used in "My Account - Settings - System Permissions Management," and you can manage them collectively there.
7. We do not intentionally collect personal information from children under 16 years old, and you must be 16 years old or older to create an account on this website.

It should be noted specifically that obtaining specific sensitive permissions does not mean that we will definitely collect your related information; even if we have obtained sensitive permissions, we will only use them within the necessary scope, i.e., when you use the relevant services or functions and we collect your information according to this guide.

For more detailed information, please read the corresponding chapters based on the following index.

1. Information We Collect and Use
   During your use of EnergyEase, we will collect and use information you actively provide or information generated from the use of our services in the following ways:
   1.1 When you register for EnergyEase, we will collect and use your email or phone number. The purpose of collecting this information is to assist you in completing the EnergyEase registration process and to protect the security of your account. If you do not provide such information, you may not be able to use our services normally. You can also choose to fill in your username and other information based on your needs.
   1.2 During your use of EnergyEase, to ensure the normal operation of services, optimize user experience, and protect the security of your account, we will collect basic information necessary for EnergyEase to provide services to you, including your device model, operating system, device MAC address, unique device identifiers (such as IMEI/MEID/IMSI/Android ID/IDFA/IDFV/OAID/UAID, SIM card IMSI, ICCID information, etc.), WIFI status (such as SSID, BSSID), manufacturer-assigned strings uniquely identifying your device, login IP address, EnergyEase version number, network connection method, type, and status, network conditions, device accelerators (such as gravity sensors), operation logs, service logs (your searches and browses within EnergyEase, service failures, referral links, etc.), installed app list, and other information.
   1.3 When you use the monitoring function, to allow you to view complete monitoring data, we need to collect the serial numbers of data collectors bound to your home and their sub-devices (such as inverters, electricity meters, charging piles, batteries, etc.). At the same time, our monitoring system will collect data uploaded by data collectors and their sub-devices every 5 minutes to complete necessary data statistics and analysis functions. Additionally, to diagnose issues for device manufacturers when devices malfunction, provide timely support and services to you, and quickly resolve issues, we will also collect the following telemetry data, including device serial numbers, device status, and alarm codes.
   1.4 When you create a home, you need to enter information such as the home name, region, and address. This information will be uploaded and stored on our servers so that you can use them when logging in to EnergyEase on other devices. You can also modify this information at any time. During the device networking process, the device itself will store the account and password used to manage the device for credential verification when you manage the device. The account and password are only stored on the device, and the password is stored using an irreversible encryption method.
   1.5 When you contact our customer service, we may require you to provide necessary personal information for identity verification to ensure the security of your account. To provide services as per your requirements and within your authorized scope, customer service personnel need to query or verify your relevant information. We will take technical and management measures to ensure your information security and confidentiality as much as possible and use this information within the necessary scope. We may also save your contact information (such as the phone number, email, or other contact methods you use or provide), your communication records and content with us, and other necessary information to provide and record customer service for you.
   1.6 If in compliance with applicable laws, regulations, and standards, we may collect and use your personal information without obtaining your consent, such as:
   a) Information necessary for personal information controllers to fulfill their obligations in accordance with laws and regulations;
   b) Information directly related to national security or defense;
   c) Information directly related to public safety, public health, or significant public interests;
   d) Information that you have publicly disclosed yourself;
   e) Other situations stipulated by laws and regulations.
   1.7 To ensure the security of our services and help us better understand the performance of our applications, we may record your frequency of using the application, crash data, overall usage, performance data, and application source information. We will not merge the information we store in analysis software with any personally identifiable information you provide in the application.

1.8 If we use your personal information beyond the purpose you authorized, we will notify you again and obtain your explicit consent before using your personal information.
1.9 Currently, EnergyEase does not obtain your personal information from third parties other than Manos. If in the future we need to indirectly obtain your information from third parties to promote business development, we will inform you of the information source, what information we will collect, and the extent to which we will use this information before obtaining the information. If we need to use your personal information collected from third parties beyond the scope authorized by you to the third party, we will seek your explicit consent before processing such information. We will strictly comply with applicable laws and regulations and require third parties to ensure the legality of the information they provide to us.
1.10 To ensure the normal and efficient operation of our website or mobile application, we will store small data files called cookies in your web browser or mobile application. The content of cookies can only be retrieved or read by the server that created them. Each cookie is unique and designed for your web browser or mobile application. Using cookies can help you avoid repeatedly filling in personal information, inputting search content, steps, and processes (e.g., form filling, search history). You can manage or delete cookies based on your preferences. Most browsers or mobile phone operating systems provide users with the ability to clear cache data. You can perform corresponding data clearance operations in browser settings or mobile phone operating system settings. However, you may not be able to fully experience some of our convenient and secure service functions.
1.11 Please understand that the functions and services we provide for you are constantly updated and developed. If a function or service does not inform you about the processing rules for collecting and using your information in the above description, we will notify you separately about the scope, purpose, and method of information collection using page prompts, interactive programs, website announcements, and other methods to obtain your consent.

2. Storage of Information

2.1 Location of Information Storage

Manos, as a global company, has established data centers in Europe for data storage in order to better comply with data protection laws and safeguard personal data. Meanwhile, as we conduct business internationally, this means we may access Manos' European data centers to provide services. If personal data from users within the European Economic Area, Switzerland, or the United Kingdom is transferred to countries or regions that have not been recognized by the European Commission as having an adequate level of data protection, we will ensure that the data transfer is adequately protected through standard contractual clauses approved by the European Commission and, if necessary, adopt other appropriate technical measures.

2.2 Duration of Information Storage

Generally, we will retain your personal information for the necessary period to achieve a specific purpose, such as:

Phone numbers or email addresses: During your use of the EnergyEase service, we will retain your phone number or email address (including those used for registering an EnergyEase account and those associated with the account) to ensure your normal use of the service. Such information will be deleted along with your EnergyEase account.

Household information: When you create a household, we need to save related information to ensure you can normally use the monitoring function. When you delete your household, we will simultaneously delete the corresponding information.

If we cease to provide our products or services, we will notify you by sending notifications, issuing announcements, or other means, and delete or anonymize your personal information within a reasonable time frame ("anonymization" refers to the irreversible erasure or deletion of personal information to ensure that the identity of the information owner cannot be identified. Any anonymized information will not be considered personal information).

3. Information Security

We are committed to protecting user information from theft, misuse, unauthorized access, or disclosure.

We will use various security protection measures within a reasonable security level to safeguard information security. For example, we will use encryption technologies (such as SSL/TLS), de-identification, anonymization, and other means to protect your personal information.

We will continuously upgrade technical means to enhance the security of software installed on devices and prevent personal information leakage. For instance, we will partially encrypt your device's information to ensure the security of data transmission; collect data on installed applications or running processes on the device, or data stored in the device's memory, to prevent attacks from viruses, Trojans, or other malicious programs or websites; analyze and use unique device identifiers, login IP addresses, operation logs, location information, and other data to take measures or issue alerts to prevent illegal activities including cyber fraud, account theft, and impersonation, and conduct security checks.

We have formulated relevant management policies, processes, and teams to ensure information security. For example, we strictly limit the personnel who can access information, require them to comply with confidentiality obligations, and conduct personnel audits.

In the event of an information leak or any other incident related to information security, we will immediately respond to the incident to prevent it from escalating and further affecting more users, and notify you of the incident by sending notifications or issuing announcements.

We will take all possible technical and organizational measures to protect your information, but cannot guarantee that our measures will eliminate all security risks.

4. Information Sharing

4.1 Access to Device Operation Data by Merchants

Merchants may access your device operation data through read and write operations with your authorization. You can view the information of authorized merchants in the operation and maintenance services. If you do not want merchants to see your household, you can uncheck the "Authorize Device Data" button on the page. This will prevent merchants from accessing your household unless you actively authorize them.

4.2 Integration of Third-Party SDKs in Applications

To ensure the realization of certain independent functions and enable you to use and enjoy more services and functions, we will embed third-party SDKs in our applications and carefully evaluate the purpose of using these SDKs. For more information on the purpose, methods, and scope of SDKs' processing of personal information, please refer to the "Third-Party Sharing List".

As our business continues to develop, Manos may undergo mergers, divisions, and other transactions. If this involves the transfer of personal information, we will inform you of the relevant situation and continue to protect or require the new processor to continue protecting your personal information.

5. Your Rights

During your use of EnergyEase, to facilitate your easier access to, copying, correction, deletion of your personal information, and to safeguard your rights to withdraw consent for personal information processing and to deactivate your account, we have provided corresponding operational settings in our product design. You can follow the guidelines below to perform the operations. Additionally, we have established channels for complaints, reports, and requests for explanations, and your opinions and requests will be promptly addressed.
The operational procedures may vary depending on the operating system or EnergyEase version. We may occasionally adjust the operational procedures to optimize the user experience. Therefore, the following procedures are for reference only. If you have any questions about the ways and methods to exercise your relevant rights, you can contact us through the method disclosed in Article 8 of this policy.
5.1 Access and Copy Personal Information
5.1.1 Access to basic information such as avatar, name, etc.

1. Enter EnergyEase and click "Menu";
2. lick the Avatar section;
3. Access your information.

5.1.2 Access to phone number, email, username, and password:

1. Enter EnergyEase and click "Menu";
2. Click the Avatar section;
3. Click "Account & Security";

4）Click "Account Information".
5.1.3 Access and copy personal information:

1. Enter EnergyEase and click "Menu";
2. Click the Avatar section;
3. Click "Account Information";

4）Click "Export Personal Information" to generate a copy of your personal information and send it to your specified email address.
5.1.4 Access to the third-party sharing list:

1. Enter EnergyEase and click "Menu";
2. Click "About EnergyEase";

3）Click "Third-Party Information Sharing List".
5.2 Delete Personal Information
5.2.1 Delete Family:

1. Enter EnergyEase and click "Menu";
2. Click the Avatar section;
3. Click "Family Settings";

4）For the family information you wish to delete, click "Delete".
5.3 Change Personal Information
5.3.1 Change avatar and name:

1. Enter EnergyEase and click "Menu";
2. Click the Avatar section;

3）Click "Account Information".
5.3.2 Change phone number, email, username, and password:

1. Enter EnergyEase and click "Menu";
2. Click the Avatar section;
3. Click "Account Information";

4）Make the changes.
5.4 Function and Permissions Management
5.4.1 Revoke authorization to other merchants:

1. Enter EnergyEase and click "Menu";
2. Click "Operation & Maintenance Services";
3. Click "Delete" for the authorized merchants.

5.4.2 System Permissions:

1) Enter EnergyEase and click "Menu";

2) Click "About EnergyEase";

3) Click "System Permissions Management";

1. Click "Go to System Settings".

5.5 Delete Account
5.5.1 Delete EnergyEase Account:

1)Enter EnergyEase and click "Menu";

2) Click the Avatar section;

3) Click "Account Deactivation".
5.6 Complaints
If you choose to file a complaint with Manos, you can follow these steps:

1) Enter EnergyEase and click "Menu";

1. Click "Feedback".
   You have the right to file a complaint with the relevant data protection supervisory authority. If you believe we have violated applicable data protection laws when processing your personal data, you have the right to file a complaint with the data protection supervisory authority of your EU Member State or the data protection supervisory authority at our principal place of business.
2. Complaint Channels
   File a complaint with the data protection supervisory authority of your EU Member State:
   You can contact the data protection supervisory authority of your EU Member State to learn how to submit a complaint or directly visit the website of the supervisory authority in your country.
   You can also file a complaint with the data protection supervisory authority at our principal place of business:
   Our principal place of business is in the People's Republic of China, so you can also file a complaint with the data protection supervisory authority of the People's Republic of China.
3. Complaint Process
   When filing a complaint with the supervisory authority, please provide the following information:
   Your name and contact information;
   Specific content and reasons for the complaint, including the specific actions you believe we have violated data protection laws;
   Relevant evidence materials, such as our privacy policy, communication records between you and us, etc.
   The supervisory authority will investigate your complaint and take appropriate measures to protect your rights if necessary.
4. Our Commitment:
   We respect your right to file a complaint and will take your complaints seriously. We will actively cooperate with the supervisory authority's investigation and take corrective measures to improve our data processing activities if necessary.
   5.7 Right to Restrict Processing
   In accordance with applicable laws, you have the right to request us to restrict the processing of your personal information in certain circumstances. For example, if you dispute the accuracy of your personal information and we need time to verify its accuracy, you can request us to restrict the processing of that data during this period.
   5.8 Right to Object
   In accordance with applicable laws, you have the right to object to our processing of your personal information. If you decide to object to our processing of your personal information, we will cease processing the personal information related to you.
5. Revisions
   This policy may be periodically updated, revised, modified, or changed as needed and in accordance with legal requirements. If any terms in this policy are updated, changed, or revised, we will display the revised policy to you through push notifications, pop-up windows, or other methods when you log in to EnergyEase or update the app version.
6. Data Protection Officer
   Our Data Protection Officer is registered with the data protection authority in the People's Republic of China. If you have any questions or requests regarding this privacy statement or the Data Protection Officer, you can contact us via the following method:
   Email: jiatong.li@igen-tech.com
7. Other Matters
   For certain specific services or functions of the EnergyEase business, we may inform you of the purpose, method, or scope of personal information processing through interactive text, product interfaces, or pop-up windows. In case of inconsistencies, the separately notified content shall prevail.
8. Contact Us
   We have established a dedicated personal information protection team and a person responsible for personal information protection. If you have any questions, complaints, or suggestions regarding this privacy policy or personal information protection, you can contact us through any of the following methods:
9. Contact us by phone: 0049 1743150766
10. Send your questions to info@manos.ai;
    We will review your questions as soon as possible and respond within 30 days after receiving your request or complaint feedback. The subsequent processing period usually does not exceed 90 days. If we encounter special circumstances, we will inform you of the processing time and reasons for the delay within 30 days after receiving your request.