Energy Ease Privacy Policy

Preamble

Energy Ease (hereinafter referred to as "we," "the Controller," or "Manos") is a home energy management system provided by MANOS Energy GmbH.

Manos is committed to protecting and safeguarding your privacy. This Privacy Policy explains how we collect, store, and use your personal information through the app, and applies to all services. Before using this platform, please click the "Agree" button to confirm your acceptance of this Policy. This Policy takes effect once you actively check the consent box and complete registration; if you do not agree with any part of this Policy, please stop using the platform's services immediately. For the non-essential personal information stipulated in this Policy, you have the right to refuse to provide it, and such refusal will not affect your use of the core functions of the platform.

In this Privacy Policy, unless otherwise specified, the following terms have the meanings set out below:

• Personal Information: refers to information recorded in electronic or other forms that can, alone or in combination with other information, identify the identity of a natural person or reflect the activities of a specific natural person, including but not limited to name, telephone number, IP address, location information, etc.
• Sensitive Personal Information: refers to personal information that, once leaked or illegally used, may cause damage to personal reputation or infringement of personal or property safety, including identity document numbers, bank account numbers, whereabouts, etc.
• Processing: refers to operations such as collection, storage, use, transmission, provision, disclosure, and deletion of personal information.
• Third Party: refers to an external organization that is not the subject to which this App belongs or an entity directly controlled by or under the control of such subject.
• Household: a virtual management unit created by the user to facilitate the management of their home energy system.

1. Information We Collect, Use, and the Legal Basis

While you use Energy Ease, the devices you add will be connected to the cloud by default, and your email, telephone number, device data, and household information will be uploaded to the cloud. If you refuse to connect your devices to the cloud, you may be unable to use certain functions.

We collect and use the information you actively provide, or that is generated through your use of the services, in the following ways:

1.1 Registration Information

When you register for Energy Ease, we will collect and use your email, telephone number, and username. The purpose of collecting this information is to help you complete the Energy Ease registration function and to protect the security of your account. If you do not provide such information, you may be unable to use our services normally. After your account is successfully registered, we will collect and store your account password to the cloud; when you log in, you may decide whether to check "Remember Password." If you check it, we will collect and store your account password locally to facilitate your next login; refusing to check it will not affect your normal use of the App. You may also optionally fill in a username and other information according to your needs.

1.2 Device and Service Operation Information

During your use of Energy Ease, to ensure the normal operation of the service, optimize user experience, and protect the security of your account, we will collect the basic information required for Energy Ease to provide services to you, including your device model, operating system, iOS device identifier (IDFV), WiFi status (such as SSID, BSSID), the string assigned to your device by the manufacturer, login IP address, Energy Ease version number, the method, type, and status of network connection, network conditions, device sensors (such as gravity sensors), operation logs, service logs (your searches and browsing within Energy Ease, service failures, referral links, etc.), installed app list, and other information. When you configure your device's network connection, you may decide whether to check the WiFi key storage option; if you check it, we will collect and store your key locally to facilitate your device's reconnection to the network, and refusing to check it will not affect your normal network configuration.

1.3 Device Monitoring and Telemetry Data

When you use the monitoring function, in order for you to view complete monitoring data, we need to collect the serial numbers of the data collectors bound under the household and their sub-devices (such as inverters, electricity meters, charging piles, batteries, etc.). At the same time, our monitoring system will collect the data uploaded by the data collectors and their sub-devices every 5 minutes to complete necessary data statistics and analysis functions. In addition, in order to diagnose problems for the device manufacturer when a device fails, and to promptly provide you with support and services and quickly resolve issues, we will also collect the following telemetry data, including device serial number, device status, and alarm codes.

1.4 Household Information

When you create a household, you need to enter the household name, region, address, and other information. This information will be uploaded and stored on our servers so that you can use it when you log into Energy Ease on other devices. You may modify this information at any time. Subsequently, during the device network configuration 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 stored only in the device, and the password is stored using an irreversible encryption method.

1.5 Customer Service Information

When you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. In order to provide services in accordance with your requirements, within the scope of your authorization, customer service personnel need to query or verify your relevant information. We will take technical and management measures to ensure the security and confidentiality of your information to the greatest extent and use such information within the necessary scope. We may also retain your contact information (such as the telephone number you use or provide, Email, or other contact methods), our communication records and content with you, and other necessary information, in order to provide and record customer service for you.

1.6 App Usage and Performance Analytics

To ensure the security of our services and to help us better understand the operation of our application, we may record information such as the frequency of your app usage, crash data, overall usage, performance data, and app source. We will process such information separately from your other personal information, and will not merge the information stored in the analytics software with any personally identifying information you provide in the application. For details on data sharing with third-party analytics SDKs (such as Google Firebase Analytics, Firebase Crashlytics), please refer to Chapter 4 "Information Sharing."

1.7 Legal Basis for Collecting and Using Information

The legal basis for our collection and use of information depends on the personal information involved and the context of collection. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of us or a third party that are not overridden by your interests in the protection of personal data, or (iii) your consent. Sometimes we may have a legal obligation to collect your information, or may need your personal information to protect your vital interests or those of another person.

1.8 Processing Beyond the Original Purpose

If we use your personal information beyond the purpose for which you authorized it, we will notify you again and obtain your explicit consent before using your personal information.

1.9 Notice of New Functions

Please understand that the functions and services we provide to you are continuously updated and developed. If a function or service does not inform you of the processing rules regarding the collection and use of your information in the above description, we will use page prompts, interactive procedures, website announcements, and other methods to separately notify you of the scope, purpose, and method of information collection, in order to obtain your consent.

2. Information Storage

2.1 Location of Information Storage

To better comply with data protection laws and protect personal data, we have established a data center in Germany for data storage.

2.2 Duration of Information Storage

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

• User account information: While you use the Energy Ease service, we will retain your telephone number or email (including the number or email used to register the Energy Ease account and associated with that account) to ensure your normal use of the service. Such information will be deleted when your Energy Ease account is deleted.
• Household information: When you create a household, we need to retain the relevant information to ensure that you can use the monitoring function normally. When you delete your household or account, we will delete the corresponding information at the same time.
• Local storage data: When you check "Remember Account Password" or "Remember WiFi Password," we will retain the information you need to remember in local storage, and such information will be deleted when you uninstall the App.

If we cease to provide our products or services, we will notify you by sending a notification, publishing an announcement, or other means, and delete or anonymize your personal information within a reasonable time (anonymization refers to the irreversible erasure or deletion of personal information to ensure that the identity of the information owner cannot be identified. Any information that has been anonymized will not be regarded as personal information).

For your deletion instructions, we will respond and execute within 30 days, and no later than 60 days.

3. Information Security

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

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

We will continuously improve technical means to enhance the security of the software installed on devices and prevent the leakage of personal information. For example, we will encrypt part of the information on your device to ensure the security of data transmission; collect applications installed on the device or processes running, or data stored in the device storage, to prevent attacks from viruses, trojans, or other malicious programs or websites; analyze and use data such as unique device identifiers, login IP addresses, operation logs, and other data to take measures or issue alerts to prevent illegal acts including online fraud, account theft, and impersonation, and to conduct security checks.

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

If an information leak or any other event related to information security occurs, we will respond to the event immediately to avoid its escalation and further impact on more users, and notify you of the event by sending a notification or publishing an announcement.

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 Sharing with Technical Service Providers

To provide and continuously optimize the functions of this application, we provide personal data to IT and cloud service providers acting as processors (such as Google, which provides analytics and human verification). If cross-border data transfer is involved, we will refer to Chapter 6 to ensure the secure and compliant transfer of data.

4.2 Transfer of Information in Case of Business Changes

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 circumstances and continue to protect your personal information or require the new processing party to continue to protect your personal information.

5. Your Rights

During your use of Energy Ease, in order for you to more conveniently access, copy, correct, and delete your personal information, and to safeguard your rights to withdraw consent to the processing of personal information and to cancel your account, we have provided corresponding operation settings in the product design. In addition, we have set up channels for complaints, reports, and requests for explanation, and your opinions and requests will be processed in a timely manner.

The operation procedures may vary depending on the operating system or Energy Ease version. We may adjust the procedure procedures from time to time to optimize the user experience. If you still have questions about the method of exercising the relevant rights, you can contact us through the method disclosed in Article 9 of this Policy.

5.1 Right of Access

You have the right to request access to your personal data held by us at any time, and to understand how we collect, use, and process your information. We will respond to your request within the time limit prescribed by law and provide you with the relevant information free of charge.

Accessing personal information in the app:

Accessing basic information such as avatar and name:

Accessing mobile phone number, email, username, and password:

5.2 Right to Data Portability

You have the right to obtain a copy of your personal data held by us and to receive such data in a structured, commonly used, and machine-readable format. You may also request that we transmit such data directly to another controller (where technically feasible).

Exporting personal information in the app:

5.3 Right to Erasure

You have the right to request that we erase your personal data. We will process your request as soon as possible within the scope permitted by law. However, if erasure is impossible due to legal obligations or other legitimate grounds, we will inform you of the specific reasons.

Deleting household information in the app:

5.4 Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data to ensure that your information is accurate. If you find that our data is incorrect, please feel free to contact us to submit a correction request. We will process your request within the time prescribed by law and update your information in a timely manner.

Changing personal information in the app:

Changing avatar and name:

Changing avatar, email, username, and password:

5.5 Right to Withdraw Consent

You have the right to withdraw your consent at any time; the withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Some information collection and processing activities (such as connecting devices to the cloud) rely on your authorization; if you withdraw consent, we will no longer carry out the corresponding data processing, and some functions may therefore be restricted or become unavailable. Withdrawal does not affect the lawfulness of the processing already carried out on the basis of consent before the withdrawal.

Withdrawing authorization to other users in the app:

Managing system permissions in the app:

5.6 Right to Lodge a Complaint

If you are dissatisfied with any of our actions, you may lodge a complaint with Manos through the contact information at the bottom, and you also have the right to lodge a complaint with the relevant data protection supervisory authority. If you believe that we have violated the applicable data protection laws of your country in processing your personal data, you have the right to lodge a complaint with the data protection supervisory authority of the EU Member State in which you are located or of our main place of business. We respect your right to complain and will take your complaint seriously. We will actively cooperate with the supervisory authority's investigation and, where necessary, take corrective measures to improve our data processing activities.

5.7 Right to Restriction of Processing

In accordance with the requirements of applicable law, under certain circumstances you have the right to require us to restrict the manner in which we process your personal information. For example, if you contest the accuracy of personal information, and we need a period of time to verify the accuracy of that personal information, you may require us to restrict the processing of that data during that period.

5.8 Right to Object

You have the right to object, on grounds relating to your particular situation, to our processing of your personal data based on legitimate interests at any time. Once you exercise the right to object, we will cease processing your personal information, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, or the processing is necessary for the establishment, exercise, or defense of legal claims. If we process your personal information for direct marketing purposes, you have the right to object at any time, and upon such objection we will immediately cease processing data for that purpose.

5.9 Account Cancellation

You have the right to cancel your Energy Ease account at any time. After account cancellation, we will cease to provide you with services and will delete or anonymize your personal information in accordance with the storage period rules set out in Section 2.2 of this Policy.

Canceling the account in the app:

6. International Transfers

If your personal data in the EU, EEA, or Switzerland is transferred to a country or region that has not been recognized by the European Commission as providing 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 or other applicable legal frameworks, and (where necessary) take other appropriate technical measures.

7. Amendments

This Policy may be updated, amended, modified, or changed periodically as needed and in accordance with legal requirements. If any provision is updated, changed, or amended in this Policy, we will display the modified Policy to you through push notifications, pop-ups, or other means when you log into Energy Ease or when the app version is updated.

8. Miscellaneous

Under certain specific services or functions of the Energy Ease business, we may inform you of the purpose, method, or scope of personal information processing through interactive copy, product interfaces, or pop-ups. In case of any inconsistency, the separately informed content shall prevail.

9. Contact Us

We have established a dedicated personal information protection team and a Data Protection Officer. If you have any questions, complaints, or suggestions regarding this Privacy Policy or personal information protection, you may contact us through any of the following methods:

We will review the issue as soon as possible and respond within 30 days of receiving your request or complaint. The subsequent processing period generally does not exceed 90 days. If we encounter special circumstances, we will inform you of the processing time and the reason for the delay within 30 days of receiving your request.