Data Act Transparency Declaration
0. Background
The EU Data Act establishes harmonised rules on fair access to and use of data. It entered into force on 11 January 2024 and will apply from 12 September 2025 across EU Member States. It aims to ensure that users of a connected product or related service in the EU can access, in a timely manner, the raw data and pre-processed data generated by the use of that connected product or related service, and that those users can use the data, including by sharing it with third parties of their choice. It imposes an obligation on data holders to make data available to users and to third parties of the user’s choice in certain circumstances. It also ensures that data holders make data available to data recipients in the EU under fair, reasonable, and non-discriminatory terms and conditions, and in a transparent manner.
1.Basic Information:
Manufacturers of connected products: Bestway (Nantong) Recreation Corp.
Address: No.8, West Huimin Road, Rugao Economic Development Zone, Jiangsu, China / No.6 West Jinlun Road, Rugao Economic Development Zone, Jiangsu, China
Providers of related services: Bestway Global Holding Inc.
Address: No.3065 Cao An Road ,Shanghai, Shanghai 201812 China mainland
Connected Product: S100201, S100202, S200202, S300202, S400201, S400202
Related services: APP Name (ios&Andriod) : Bestway Connect(Smartspa)
Version:IOS:2.0.0 Andriod:2.0.0
Data holder: Bestway Global Holding Inc.
Address: No.3065 Cao An Road ,Shanghai, Shanghai 201812 China mainland
Third-party enterprises that receiving data: NA
Third-party enterprises that providing data: NA
2.Details of the product data:
(the connected product is capable of generating)
| Data | Category of Data | Type of Data |
Nature | Format | Purpose of the data use |
Estimated Volume |
Collection Frequency |
Capable of generating data continuously and in real-time |
where the data is stored |
duration of the data retention |
how the user may access the data |
how the user may retrieve the data |
how the user may erase the data |
Exportable |
Export Method |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Deivce Sensor Data | Non-Personal data | Device Operation Data | "Device switch status", "25°C", "Error code 0x01" | CSV | Device Monitoring | 20KB/day | 10 Min, On event trigger | Yes | Cloud Service | 30day | Via the 'After-Sale Info' page in the App | Via the 'After-Sale Info' page in the App | Contact customer service to delete the data. | Yes | Contact customer service to export the data. |
| Wi-Fi RSSI | Non-Personal data | Device Operation Data | -50dbm | CSV | Device Monitoring | 5KB/day | 30 Min | Yes | Cloud Service | 30day | Via the 'After-Sale Info' page in the App | Via the 'After-Sale Info' page in the App | Contact customer service to delete the data. | Yes | Contact customer service to export the data. |
| Device Version | Non-Personal data | Device Operation Data | 04A3RW04 | CSV | Device Monitoring | 1KB/day | On event trigger | Yes | Cloud Service | Permanent | Via the 'After-Sale Info' page in the App | Via the 'After-Sale Info' page in the App | Contact customer service to delete the data. | Yes | Contact customer service to export the data. |
Information on your terms of use:
2.Details of the related services data:
| Data | Category of Data | Type of Data |
Examples/Nature | Format | Estimated Volume |
Collection Frequency |
Purpose of the data use |
where the data is stored |
duration of the data retention |
how the user may access the data |
how the user may retrieve the data |
whether will allow third parties to use the data |
Exportable |
Export Method |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Album | Personal data | User Info | my.PNG | PNG | 0-128 bytes | Depends on the user | 1.Scan to add device 2.Provide pictures for troubleshooting | Devices and servers | The data is only saved before the account is cancelled. | App -> Profile -> Profile photo | App -> Profile -> Profile photo | NO | Yes | Contact customer service to export the data. |
| User Account Info | Personal data | User Info | bestway@gmail.com | CSV | 0-128 bytes | Upon registration | For account authentication | Cloud Server | The data is only saved before the account is cancelled. | App -> Profile -> Settings | App -> Profile -> Settings | NO | Yes | Contact customer service to export the data. |
Identity of the data holder
Trading Full Name: Bestway Global Holding Inc.
Geographical Address: No.3065 Cao An Road ,Shanghai, Shanghai 201812 China mainland
Means of communication with the data holder：bestway-smart-hub@bestwaycorp.com
Information on how the user can request that the data：Contact this email: bestway-smart-hub@bestwaycorp.com for support
-- Users can request data export by emailing privacy@bestway.com.Data will be provided in JSON/CSV format.
Information on how the user can request that the data is shared with a third party
-- Users can request data export by emailing privacy@bestway.com.Data will be provided in JSON/CSV format.
Right to lodge a complaint (the user's right to lodge a complaint alleging an infringement of any of the provisions of this Chapter with the competent authority designated pursuant to Article 37;)
Information on trade secrets (whether a prospective data holder is the holder of trade secrets contained in the data that is accessible from the connected product or generated during the provision of a related service, and, where the prospective data holder is not the trade secret holder, the identity of the trade secret holder;)
-- The data provided to users does not contain trade secrets.
The duration of the contract between the user and the prospective data holder
-- Indefinite, subject to actual conditions
The arrangements for terminating such a contract
-- Users can terminate the service by deleting their account in the App settings.
