Live Chat AI Service PRIVACY NOTICE

Effective Date: [February 27, 2026]

This AI Service Privacy Notice (referred to as "Privacy Notice") is issued by Fantasia Trading LLC and its affiliates (together, "Anker", "we", "us" and "our") and is addressed to users of the Anker's website & App who interact with our Live Chat AI Service (together, "you").

This Privacy Notice applies specifically to Live Chat AI Service powered by AI capabilities. This notice complements our general Privacy Notice.

1. Collection of Personal Data

Depending on how you use our Live Chat AI Service, we may collect or obtain Personal Data about you from the following sources:

  • Direct Interaction: Data you voluntarily provide when chatting with our AI assistant.
  • Automated Collection: Data collected automatically regarding your browsing behavior, search history within our store, and interactions with the chat interface.

2. Creation of Personal Data

We create Personal Data records about you in certain circumstances, such as assigning a unique Session ID to your chat session to maintain context, and generating system logs that record the rationale/reasoning behind the products recommended to you by AI.

3. Categories of Personal Data We Collect and Process

To provide an intelligent and personalized shopping assistant experience, we collect and process the following categories of data:

  • Chat Interaction Data:
    • Full Conversation Text: Your questions, prompts, and feedback provided during the chat.
    • Metadata: Timestamps of messages, message duration, and AI response generation time.
  • Browsing & Behavioral Data:
    • Product Interaction: Products you have viewed, clicked on, or added to your shopping cart.
    • Search Context: Keywords you used in the website search bar prior to or during the chat.
    • Engagement Metrics: Time spent on specific product pages and your interaction with AI-recommended product cards (e.g., clicks, dismissals).
  • Technical Identifiers:
    • Session ID & User ID: Unique identifiers to link your chat session with your browsing session (and your account, if logged in) to ensure conversation continuity.
  • Exclusion of Sensitive Data:
    • Please Note: This service is for shopping assistance only. We do not intend to collect sensitive personal information (such as health data, financial account numbers, credit card details, or biometric data) via the Live Chat AI Service. Please do not input such information into the chat box.

4. Purposes of Processing

We use the Personal Data we collect via Live Chat AI Service for the following purposes:

  • Intent Understanding & Response: To analyze your text input and generate relevant, helpful responses regarding Anker products.
  • Personalized Recommendation: To utilize your browsing history, search keywords, and page stay duration to recommend products that match your specific needs and preferences.
  • Cart & Order Assistance: To facilitate actions such as checking inventory or adding items to your cart upon your request.
  • Service Optimization: To analyze user feedback (e.g., acceptance rate of recommendations) to improve the accuracy of our AI logic.
  • Security & Debugging: To monitor logs for system errors, potential cyber threats, or malicious inputs (Prompt Injection).

Important Note on AI Training: We do not use your personal chat content or identifiable data to train the third-party public Large Language Models (LLMs) used to power this service.

5. AI Disclaimer & Limitations of Liability

By using this AI Live Chat AI Service, you acknowledge and agree to the following terms:

  • Nature of Service: The "Live Chat AI Service" is an automated system powered by large language models (specifically Google Gemini). It is not a human.
  • Accuracy of Information: While we strive for accuracy, AI-generated responses may occasionally be incorrect, incomplete, or misleading ("hallucinations"). The AI may misinterpret product specifications or inventory status. You should always verify critical product details (such as price, compatibility, and specs) on the official product detail page before making a purchase decision.
  • No Professional Advice: The AI is designed solely for product consultation. It does not provide legal, medical, financial, or professional safety advice.
  • Decision Making: The AI provides recommendations based on your input, but it does not make decisions for you. You retain full autonomy and responsibility for your purchasing decisions. Anker is not liable for purchases made based solely on AI recommendations that do not meet your expectations due to subjective interpretation.
  • Third-Party Processing: This service utilizes third-party AI technology. While we implement strict data safeguards, data processing involves transmission to third-party providers (as detailed in Section 6).

6. Disclosure of Personal Data

We share necessary data with the following categories of third-party Processors:

  • AI Model Providers: We utilize Google Gemini API (Google LLC) to process your text inputs. Only the necessary conversation context is transmitted; Google is contractually restricted from using this data to train their general public models.
  • Cloud Infrastructure: Your chat logs and behavioral data are stored on secure cloud servers (e.g., AWS) located in the United States.
  • eCommerce Platform: Data interacts with our backend systems (e.g., Shopify) to retrieve real-time product data.

7. Data Security

We attach great importance to the security of your personal data. In accordance with applicable laws and regulations (such as GDPR Art. 32), we implement appropriate technical and organizational measures to protect your data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

  • Encryption: All data transmitted between your browser and our Live Chat service is encrypted using TLS (Transport Layer Security) protocols. Chat logs stored on our cloud servers are encrypted at rest using industry-standard encryption standards (e.g., AES-256).
  • Access Control: Access to your chat logs and associated personal data is strictly restricted to authorized personnel (e.g., customer support agents, technical engineers) who have a legitimate business need to access such information and are bound by confidentiality obligations.
  • Vendor Management: We conduct strict security assessments on third-party service providers (such as Google Gemini and cloud hosting providers) to ensure they maintain a level of security appropriate to the risk.
  • Security Disclaimer: Despite these measures, please be aware that no security system is impenetrable and no data transmission over the Internet can be guaranteed to be 100% secure. We cannot guarantee the absolute security of any information you transmit to us via the Live Chat service.

8. Children's Privacy

Our Live Chat service is designed for and directed towards adults. We do not knowingly collect, use, or disclose personal data from children under the age of 13 (or the equivalent minimum age in your jurisdiction, such as 16 in certain EU member states) without verifiable parental consent.

  • Usage Restriction: If you are under the applicable age of digital consent, please do not use the AI Live Chat or provide any personal information through this service.
  • Deletion Mechanism: If we become aware that we have inadvertently collected personal data from a child under the applicable age, we will take immediate steps to delete such information from our records. If you believe that a child under the age of 13 has provided us with personal data via the Live Chat, please contact us immediately at support@eufy.com or DPO@anker.com.

9. International Transfer of Personal Data

Your data associated with Live Chat AI Service is processed in the United States. If you are accessing this service from outside the US, you acknowledge that your data will be transferred to the US. We ensure appropriate safeguards (such as Standard Contractual Clauses) are in place to comply with applicable cross-border data transfer laws.

10. Data Retention

We have implemented processes designed to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

(1) we will retain Personal Data in a form that permits identification only for as long as:

  • (a) we maintain an ongoing relationship with you (e.g., where you are a user of our services); or
  • (b) your Personal Data are necessary in connection with the lawful purposes set out in this Privacy Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between you and us, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

(2) the duration of:

  • (a) any applicable limitation period under applicable law (i.e., either any statutory retention periods as required by the law of the applicable region (e.g., the European Union or a member state of the EEA), or any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
  • (b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

  • permanently delete or destroy the Relevant Personal Data; or
  • anonymize or deidentify the Relevant Personal Data.

11. Your Privacy Rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

  • the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
  • the right to request access to, or copies of, your Relevant Personal Data, together with additional information, such as information regarding the nature, Processing and disclosure of those Relevant Personal Data;
  • the right to request rectification of any inaccuracies or incompleteness in your Relevant Personal Data;
  • the right to request, on legitimate grounds, restriction of Processing of your Relevant Personal Data (limiting the purposes for which we Process your Personal Data);
  • the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
  • the right to request the deletion or removal of your Relevant Personal Data where there is no other legal basis for us to keep using it. Please note that we may not be able to immediately remove the information from the backup system due to applicable laws and regulations or technological limitations. If this is the case, we will isolate your Relevant Personal Data from any further processing until the backup can be deleted or be anonymized / deidentified.
  • where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent at any time (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal).

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (10) below. Please note that:

  • In some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and
  • where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

For general enquiries, or to exercise any of the rights set out in this Privacy Notice, please contact our Data protection officer via email (DPO@anker.com).

12. Contact Us

If you have questions or concerns with respect to our Privacy Notice or privacy practices, you may contact us at DPO@anker.com.

13. Definitions

  • "Data Protection Authority" means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
  • "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  • "Process", "Processing" or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • "Processor" means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
  • "Profiling" means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  • "Relevant Personal Data" means Personal Data in respect of which we are the Controller.

Annex I - Details of Processing

Processing activity Processing activity and Processed Personal Data Purposes Legal basis for Processing
1. Providing "Live Chat AI Service AI Shopping Assistant" Service (Core Interaction) • Text information: Your dialogue content, inquiries, and prompts entered in the chat box.
• Technical Identifiers: Session ID, User ID (if logged in), and Device/Browser Metadata.
• Metadata: Timestamps of messages and AI generation duration.
• Intent Recognition: Analyzing your text to understand your shopping needs or support questions.
• AI Inference: Transferring your anonymized query context to the AI model (Google Gemini) to generate natural language responses.
• Session Management: Maintaining the continuity of the conversation across different page loads.
• The Processing is necessary for entering or performing a contract with you (responding to your direct requests).
2. Personalization & Product Recommendation (Smart Features) • Browsing Behavior: Page view duration (how long you stay on a product page), specific Product IDs viewed.
• Search Context: Search keywords used within the store before or during the chat.
• Interaction Data: Clicks on recommended product cards, "Add to Cart" actions, and feedback on AI answers (e.g., thumbs up/down).
• Contextual Recommendation: Using your browsing history and search keywords to filter and recommend products that match your preferences.
• Reasoning Generation: Enabling the AI to explain why a specific product fits your needs based on the page duration or features you focused on.
• Inventory Check: Verifying real-time stock and price information for requested items.
• The Processing is based on our legitimate interest in improving your shopping experience and providing accurate recommendations.
• Where applicable, based on your consent (e.g., via Cookie preferences).
3. Security, Optimization & Legal Compliance (Back-end Processing) • All of the above (retained in Logs).
• AI Reasoning Logs: Records of the logic used by the AI to select a recommendation.
• Quality Assurance: Analyzing timestamps and chat logs to debug AI errors ("hallucinations") and optimize response accuracy.
• Security: Monitoring for malicious inputs (Prompt Injection), fraud prevention, and ensuring system stability.
• Legal Defense: Retaining records to exercise, enforce, and defend against legal claims.
• The Processing is necessary for our legitimate interest in ensuring system security, compliance, and service improvement.
• Compliance with legal obligations.