eufy Business Partner Privacy Notice

1. Scope of This Notice

This Business Partner Privacy Notice (“Notice”) explains how eufy, a brand of Anker Innovations (“we,” “us,” or “our”), collects, uses, discloses, and protects the personal information of individuals who apply to become a business partner through our Partner Program page (the “Partner Enrollment Form”). For the avoidance of doubt, the specific entity acting as the data controller for your personal information under this Notice is the same entity identified in our general Privacy Notice and Terms of Use.

This Notice applies to:

• Prospective business partners who submit information through the Partner Enrollment Form, including sole proprietors, small and medium-sized business owners, installers, dealers, and authorized company representatives;
• Current business partners with whom we maintain an ongoing commercial relationship;
• Individuals whose personal information is provided in connection with a business application, including legal representatives and business contacts.

This Notice does not apply to consumers using our products or services for personal, family, or household purposes. Our consumer data practices are described separately in our general Privacy Notice, which is accessible via the footer at the bottom of our website. While this Notice operates independently to govern your business relationship with us, your general navigation and use of our website remain subject to our Terms of Use and general Cookie Notice. This Notice also applies to personal information we process in connection with orders placed by our business partners, including where products are shipped directly to an end customer designated by the partner (“drop shipment”). In such cases, the partner remains responsible for compliance with its own privacy obligations toward that end customer, as further described in Section 9.

2. Legal Bases and Purposes of Processing

We process personal information only for the specific, lawful purposes described in Section 4, and we do not use it for purposes incompatible with those described. Where required by applicable law, we rely on the following lawful grounds to process your personal data:

• Contractual Necessity: Processing is necessary to take pre-contractual steps at your request and to perform a contract with you once entered into, including evaluating your application, managing your partner account, processing and fulfilling product orders, arranging shipment and delivery (including to third-party recipients designated by you), and administering payments and commissions.
• Legitimate Interests: Processing is necessary for our legitimate interests in evaluating and managing business partnerships, communicating with business contacts, improving our Partner Program, and protecting our legal rights, where such interests are not overridden by your data protection rights and freedoms.
• Consent: Where you have opted in to receive marketing communications. You may withdraw consent at any time without affecting prior lawful processing.
• Legal Obligation: Compliance with applicable legal and regulatory requirements, including tax reporting and anti-fraud obligations.

Automated decision-making. We do not make decisions concerning you that are based solely on automated processing and produce legal or similarly significant effects, except where permitted by law.

Providing information marked as required (*) on the Partner Enrollment Form is necessary for us to evaluate your application. Failure to provide required information may prevent us from processing your partnership application.

3. Categories of Personal Information

We collect the following categories of personal information when you complete the Partner Enrollment Form. The specific fields we request may vary depending on the nature of your application and our screening requirements. We will only collect information that is relevant and proportionate to evaluating a potential business partnership.

In addition to the information you provide directly, we may automatically collect certain technical information when you visit our website, such as IP address, browser type, and device identifiers, as described in our general Cookie Notice.

4. How We Use Your Information

We use the categories of information described above for the following business purposes:

4.1 Partner Qualification & Verification

To evaluate your business profile, verify the accuracy and validity of submitted information and supporting documents (including tax and business registration certificates), and determine eligibility for our Partner Program.

4.2 Account Setup & Administration

To create and manage your partner account, process your enrollment, and administer the Partner Program, including commission payments, tier assignments, and ongoing partner support.

4.3 Order Fulfillment & Logistics

To process orders you place, arrange shipment and delivery of products (including drop shipment directly to your end customers), manage returns and exchanges, and communicate with you regarding order status and delivery updates. Where delivery is made to an end customer or other third party, you are responsible for ensuring that the necessary disclosures have been made and, where required, consent has been obtained from the data subject prior to providing their personal information to us for fulfillment purposes.

4.4 Business Communication

To contact you via email or telephone regarding your application, provide information about our products and partnership opportunities, and respond to your inquiries.

4.5 Marketing (With Consent)

To send you business updates, partnership opportunities, and marketing communications about our products and services, where you have opted in. You may unsubscribe at any time.

4.6 Legal & Compliance

To comply with applicable laws and regulations (including tax reporting obligations), respond to lawful requests from government authorities, prevent fraud and misuse, and protect our legal rights.

5. How We Share Your Information

We do not sell your personal information or “share” it for targeted advertising purposes. We may share your information in the following circumstances:

• Service Providers: We engage trusted third-party vendors to perform services on our behalf, including email delivery, CRM platforms, cloud hosting, document verification, payment processing, and analytics. These providers are contractually bound to process data only per our instructions and for no other purpose.
• Affiliated Entities: Within the Anker Innovations corporate group, including our parent company in China and our U.S. operating entity, Fantasia Trading LLC, for purposes consistent with this Notice.
• Legal Obligations: When required by law, court order, or governmental regulation, or to protect the rights, property, or safety of our company, our partners, or others.
• Business Transactions: In connection with a merger, acquisition, reorganization, or sale of assets, subject to standard confidentiality arrangements.

6. Cross-Border Data Transfers

Your personal information, including supporting documents and tax information, may be transferred to, stored, and processed in countries other than the country in which you reside. This includes China, the United States and Singapore, where our parent company, Anker Innovations, and certain affiliated entities and service providers are located.

These jurisdictions may have data protection laws that differ from those in your country of residence, and in some cases may not provide the same level of protection. When we transfer personal information across borders, we implement appropriate safeguards in accordance with applicable data protection laws, including:

• Standard Contractual Clauses (“SCCs”) approved by the European Commission, and the UK International Data Transfer Addendum where applicable;
• Contractual obligations on data recipients to ensure a level of protection consistent with this Notice;
• Technical and organizational measures designed to protect your information during transit and at rest, including encryption and access controls;
• Data minimization principles, ensuring only information necessary for the stated purposes is transferred.

Certain jurisdictions where our entities or service providers are located may not have received an adequacy decision from relevant regulatory authorities as of the effective date of this Notice. Transfers of personal data from the EEA or UK to our parent company and affiliated entities are governed by the SCCs referenced above. You may request a copy of the applicable safeguards by contacting us using the information in Section 12.

Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure the recipient does not breach applicable data protection principles in relation to that information, unless you consent to the disclosure after being informed that we will not be accountable for the overseas recipient’s handling of the information.

7. Cookies and Tracking Technologies

Our website uses essential cookies and similar technologies to ensure the functionality and security of the Partner Enrollment Form. We may also use analytics cookies to understand how visitors interact with our business pages. Depending on applicable laws in your jurisdiction, we will either obtain your prior consent before deploying non-essential cookies, or provide you with the right to opt out of their use. For comprehensive details regarding the specific cookies we deploy, how we use tracking technologies, and how you can manage your preferences (including how to exercise your opt-out rights), please refer to our general Cookie Notice, which is accessible via the footer at the bottom of our website.

8. Data Retention

We retain your personal information and supporting documents for as long as reasonably necessary to fulfill the purposes described in this Notice, including:

• For the duration of our business relationship, plus a reasonable period thereafter to comply with legal obligations (including tax record-keeping requirements), resolve disputes, and enforce our agreements;
• If your application is not approved or no business relationship is established, your information will be retained for up to 24 months from the date of your last interaction, after which it will be deleted or de-identified, unless a longer retention period is required by applicable law.

9. Third-Party Data & Order Fulfillment

9.1 Provision of Third-Party Data

If you provide us with personal information of any third party—including your end customers, employees, contractors, or other individuals—in connection with your account, orders, or use of our services (for example, recipient name, delivery address, telephone number, or email address for drop shipment), you represent and warrant that you have:

• Provided the individual with all notices required by applicable data protection laws, including notice that their data will be shared with us for order fulfillment and related purposes;
• Obtained all necessary consents, where required by applicable law, before sharing their personal information with us;
• Provided complete and accurate information, and will promptly update any information that changes.

9.2 Prohibition on Unauthorized Use of Third-Party Data

You must not use third-party personal information provided to us, or obtained through our services, to subscribe any individual to our marketing communications, newsletters, websites, or other promotional services without that individual’s explicit prior consent. You must not impersonate any third party or submit their information for any purpose other than legitimate business transactions with us.

9.3 Roles and Responsibilities

For purposes of applicable data protection laws, when you provide us with third-party personal information for order fulfillment:

• You act as an independent data controller with respect to the personal information of your end customers and other third parties. You are solely responsible for the lawfulness of your collection, use, and disclosure of such information, and for honoring the data protection rights of those individuals.
• We act as an independent data controller with respect to the information we receive, for the purposes described in this Notice (including order fulfillment, fraud prevention, and legal compliance).

9.4 Third-Party Rights Requests

If an end customer or other third party whose personal information you have provided to us contacts you to exercise their data protection rights, you are responsible for responding directly to that individual in accordance with applicable law, including by honoring access, correction, deletion, and objection requests to the extent required.

9.5 Our Commitment to Support

If an end customer or other third party contacts us directly to exercise their data protection rights, and we are able to identify you as the partner through whom their information was provided, we will:

• Promptly notify you of the request (unless prohibited by law);
• Provide reasonable assistance and information necessary for you to respond to the request;
• Refrain from acting on the request independently, except to the extent required by applicable law (for example, where we process the data for our own independent purposes as a controller).

10. Your Privacy Rights

Depending on your jurisdiction, you may have the right to exercise some or all of the following:

• Access: Request confirmation of whether we process your personal information, obtain a copy of the data we hold about you, and receive related details about how and why we process it.
• Correction: Request correction of inaccurate or incomplete personal information.
• Deletion: Request deletion of your personal information, subject to legal exceptions (such as ongoing contractual relationships, legal claims, or regulatory retention obligations).
• Restriction: Request that we limit processing of your personal information in certain circumstances, such as while we verify its accuracy or assess an objection.
• Portability: Request a copy of your personal information in a structured, commonly used, and machine-readable format, and where technically feasible, have it transmitted directly to another organization.
• Objection: Object to processing based on our legitimate interests, including an absolute right to object to direct marketing at any time.
• Consent Withdrawal: Withdraw any previously given consent without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us using the information in Section 12. We will respond within the timeframes required by applicable law and may request verification of your identity before processing your request. If we decline your request, you may have the right to appeal our decision, and to lodge a complaint with the relevant supervisory authority. Depending on your location, this may be the data protection authority in your country or state of residence, place of work, or where the alleged infringement occurred. We encourage you to contact us first so we can attempt to resolve your concerns directly.

These rights may vary in scope, availability, and applicable exemptions depending on your country or state of residence. Not all rights are available to all individuals or in all circumstances. We do not discriminate against individuals who exercise their legal rights.

11. Security

We implement and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures are regularly reviewed and updated to address evolving threats and industry best practices.

• Administrative Safeguards: We maintain internal policies and procedures governing the collection, use, and protection of personal information. Our personnel with access to personal information are subject to confidentiality obligations and receive regular privacy and security training. Access to personal information is restricted to authorized employees and contractors who have a legitimate business need, based on the principle of least privilege.
• Technical Safeguards: We deploy industry-standard technical measures designed to protect personal information, including encryption of data in transit and at rest, network security controls, and access management mechanisms. Our systems undergo regular security testing and assessments. We maintain audit logs of access to personal information and monitor for anomalous activity.
• Physical and Environmental Safeguards: Our data is hosted on leading cloud infrastructure platforms that maintain robust physical and environmental security controls at their data center facilities, including access restrictions, surveillance, and environmental monitoring. While we rely on our cloud service providers for physical security, we implement administrative and logical access controls to govern access to our cloud environments and data.
• Incident Response: We maintain a documented incident response plan to address security events involving personal information. In the event of a data breach, we will notify affected individuals and relevant regulatory authorities in accordance with applicable law and contractual obligations.
• Vendor Management: When we engage third-party service providers who may access personal information, we conduct security due diligence and require contractual commitments to implement and maintain appropriate security measures consistent with this Notice and applicable law.

Notwithstanding these measures, no method of electronic transmission, storage, or processing is 100% secure. We cannot guarantee absolute security of your personal information, and you submit your information at your own risk. We encourage you to take steps to protect your own information, including using strong passwords and keeping your login credentials confidential.

12. Contact Us

If you have questions about this Notice or wish to exercise your privacy rights, please contact us:

Email: dpo@anker.com (our Data Protection Officer / privacy contact point)

We will respond to all inquiries within the timeframes required by applicable law (generally within one month, or 30 days, extendable where permitted).

13. Changes to This Notice

We may update this Notice from time to time to reflect changes in our practices or legal obligations. The updated version will be posted on our website with a revised effective date. We encourage you to review this Notice periodically.