privacy policy

1. INTRODUCTION

Dear user,

This privacy policy describes the privacy practices of Haier Energy Technology Co., Ltd and our subsidiaries and affiliates for the processings, services and activities connected to the use of Nahui Intelligent. Haier Energy Technology Co., Ltd., (from now on, for the sake of brevity, “Haier Energy”) with registered office at No.57, No.17, Jiujiang Road, Tongji Street Office, Jimo District, Qingdao City, Shandong Province, is a company part of the Haier Group.

Haier Energy handles services and activities connected to the use of Nahui Intelligent and, it manages activities connected with the use of Nahui Intelligent, its connected experience via its app.

Haier Energy believes that the protection of personal data is a fundamental value for its business activities, and we strive to provide you with all the information that can help you protect your privacy and control the use made of your data in relation to the various services we offer you and the interactions you may have with us. In this Privacy Policy, you will find information regarding how your personal data are managed. We explain which personal data we collect and why, how we use them, if we share them with other companies, how you can exercise control over your data and the measures we enact to protect your privacy.

This policy applies to the personal data we collect when you make use of the services connected to Nahui products, specifically the connected Nahui Intelligent app. On top of that, this privacy policy covers request of assistance from our technician or interaction directly with us or with our partners which act as data processors (through the app, website or over the phone), henceforth referred to jointly as the “Services”. This Notice provides information about the processing and management of your personal data.

2. ABOUT US

Haier Energy will process your personal data in compliance with Regulation (EU) 2016/679 (“GDPR” or the “Regulation”) and regulations in force on the protection of personal data. Our contact information is provided below.

Data Controller

The Data Controller, i.e., the party taking decisions on processing methods and purposes, is Haier Energy, with registered office at No.57, No.17, Jiujiang Road, Tongji Street Office, Jimo District, Qingdao City, Shandong Province.

If you are an individual based in the EU, and you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR) or have any queries in relation to your rights or general privacy matters, please email us at gdpr-representative@redopen.it. We have appointed ReD OPEN S.r.l. to act as our EU representative. Please ensure to include our company name (Haier Energy) in any correspondence you send to our Representative. For all other questions or for non-EU residents, the address is: nahuiprivacypolicy@haier.com

Inquiries can also be submitted via post at the following address:

No.57, No.17, Jiujiang Road,

Tongji Street Office, Jimo District,

Qingdao City, Shandong Province.

f.a.o

Office 308-A, Board Building, Haier Industrial Park

3. WHICH DATA WE PROCESS

When you use our products and services, we process some of your personal data. Information about this is provided below.

Type and source of personal data

When you use our Services, we may process the following personal data (i.e., data relating to identified or identifiable people):

  1. Common personal data and contact information (operator/customer data): first name, surname, e-mail address, UserID.
  2. Data relating to the products purchased, such as code and product line, may be collected once the product is registered. Moreover, in case you require after sales assistance from one of our service centers, the following data may be collected: purchasing invoice or other evidence showing the product’s purchase date, serial number, warranty information and the type of assistance you have requested (including information contained in the space where the user may provide request details and useful pictures).
  3. Data collected to navigate within the app (navigation data), such as your IP address, URI notation addresses, the time of your request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.), and other parameters relating to the user's operating system and IT environment. The transmission of this information derives from the use of internet communication protocols through which the above activities are performed. This information is not gathered to be associated with identified users, but by its very nature, it may be used to identify users through matching and processing with information held by third parties.
  4. Data acquired during the enrollment of the appliance and interaction with the app. Such data are acquired for the sole purpose of enabling mobile app features and/or allowing them to connect their device to connected functionalities. In particular:
    1. System data, i.e., system name, system identifier, date/time of commissioning, company, street, street number, postcode, town, federal state, time zone, longitude, latitude, height above sea level, system performance, manufacturer, module type, system specification, system image.
    2. Geolocation data are required when enrolling the product via wi-fi or Bluetooth and when scanning the QRcode, using camera usage, to connect the product with the app. However, geolocation is not required for the product to function: once the enrolment has been done, consent can be revoked, without affecting the use of the other connected services of the app.
    3. Data collected due to the use and access to the mobile’s camera and gallery are acquired for the sole purpose of scanning the QRCode which allow the user to access to the connected services of the energy product.
    4. Data collected via the activation of the Bluetooth function, required to connect the devices with the local network (for which there is a specific consent) in order to use the IoT functionalities.
  5. Data related to the functioning and status of the connected appliance (such as on/off, any errors), required to monitor the status of the registered device. This allows to display in the app alerts in case of malfunctions in order to protect the product and personal safety.
  6. Data related to the user’s interactions with the app (e.g., usage data), acquired for enriching the user’s experience (e.g., enabling configuration of preferred energy usage scenarios). No direct marketing nor profiling activities are carried out on these data.

The data are provided by you, depending on the case, directly when you register your product, activate your account, request a Service or activate the warranty. If you decide to use Apple or Google login systems in conjunction with Haier Energy products and/or use them to log into the Apps, we invite you to carefully consult, before using them, the privacy policies, and terms of service of each of those services.

4. WHY WE PROCESS YOUR DATA

Your personal data may be processed for the following purposes.

  1. to allow you to use the apps and web app, register the connected appliance and make use of the services and functions offered by its use, for assistance and maintenance purposes, to manage your profile, and thus provide the services you have requested.
  2. to respond to your request for assistance about the functioning, use and maintenance of an appliance or to respond to your questions about our products and services. If we ask you to fill out a form to send us your request, remember that the data entered in the fields marked by an asterisk are required as we would not be able to accept the request or respond to it without this information.
  3. to allow you to take advantage of any additional warranties (ours or those of third parties), receive updates on your appliance and service notices, to enable you to access information regarding registered products and obtain assistance in a more streamlined manner. If to that end we ask you to fill out a form, remember that the personal data entered in the fields marked by an asterisk are required as we would not be able to provide you the service without this information.

    4. (the purposes from letter a) to c) are jointly defined as the “Contractual Purposes”).

  4. to meet the obligations arising from current laws, regulations or EU law (e.g., tax and accounting obligations) (defined as “Legal obligation purposes”).
  5. to enforce and defend the rights of Haier Energy also as part of debt collection procedures and the assignment of receivables to authorised companies, including through third parties, and to prevent and combat any fraud.
  6. for research and development activities aimed at analysing and improving the Services and/or products offered, also proceeding with the anonymisation and/or aggregation of your personal data.
  7. in the case of any corporate transactions, to perform activities functional to such transactions (including disposals, leases, transfers, mergers or corporate demergers).
  8. to transmit the personal data within the business group of which the Controller is part for administrative and accounting purposes.
5. ON WHAT BASIS WE PROCESS YOUR DATA

The processing of your personal data is necessary with reference to the Contractual Purposes given its essential nature in order to:

  1. perform the contract, with regard to the provision of the products and services requested in relation to the cases set forth in Section 4, letters a), b), c).
  2. adjust to provisions of applicable regulations, as set forth in Section 4, letter d).

If you do not provide the personal data required for the Contractual Purposes, it will not be possible to make use of the services (including assistance and other functions described above).

The processing of your personal data for Legitimate Business Interest Purposes is carried out pursuant to article 6, letter f) of the European General Data Protection Regulation 2016/679 (the “Privacy Regulation”) to pursue the interest of Haier Energy which is equally balanced with your interest, as the personal data processing activity is limited to what is strictly necessary for the execution of the economic transactions described. Processing for Legitimate Business Interest is not required, and you may object to that processing with the methods set forth in this disclosure. However, if you object to that processing, your data may not be used for the Legitimate Business Interest Purposes, unless Haier Energy can demonstrate the presence of prevailing compelling legitimate grounds or for the exercise or defence of legal claims.

Finally, the processing regarding section 4, letter i) are based on your consent, and are preparatory to the connection of the appliance, the device can work without internet connection, but it will not have access to whole functionalities.

6. HOW WE PROCESS YOUR DATA

We will process your data primarily using registration, extraction, analysis and archiving tools protected with systems that offer security guarantees in line with sector standards.

In particular, we will process your data using primarily IT systems and analysis tools through authorised personnel appropriately trained by Haier Energy and its data processors. We adopt measures aimed at guaranteeing the application of the principles of accuracy, lawfulness and transparency set forth in applicable regulations on the protection of personal data (including the General Data Protection Regulation i.e., GDPR), protecting your privacy through technical and organisational security measures that guarantee an adequate level of security to prevent the loss or unlawful or improper use of as well as unauthorised access to your data.

7. HOW LONG WE STORE YOUR DATA

Your data will be stored for the period of time strictly required to achieve the purposes for which they were collected. In any event, the following storage terms will apply:

  1. for the Contractual and Legitimate Business Interest Purposes, the data will be stored for a period equal to the duration of the provision of the services you have requested and for the 10 years after that, without prejudice to cases in which storage for a subsequent period is required for any legal actions and, in the case of disputes, requests from the competent authorities or pursuant to applicable regulations.
  2. data collected via your explicit consent will be retained up until the purpose has been achieved and in any case for a period that will not exceed 10 years. Consent will be periodically assessed to verify that its retention is appropriate with the purpose for which it was collected. It is always possible to revoke freely at any time the given consent.
8. WHO WE SHARE YOUR DATA WITH

Communication and dissemination of data

For Contractual Purposes, your data may be communicated to personnel authorised by Haier Energy who have been appropriately informed and trained, or the personnel of third parties who operate on behalf of and based on instructions from Haier Energy as Data Processors, including companies that provide technical and pre/post-sale assistance. The third parties that provide services are included in the following categories: (i) the original equipment manufacturer; ii) providers of assistance and consulting services for the Company, with reference to activities in the (including but not limited to) technological, accounting, administrative, legal and insurance sectors; (iii) providers of IT and maintenance services; (iv) providers that help us with appliance assistance and repair services; (v) providers that provide our e-shop hosting services; (vi) companies of the Haier Group; (vii) parties and authorities whose right to access the data is expressly recognised by law, regulations or measures issued by the competent authorities.

Please note that, if necessary, IT assistance and maintenance may be performed in establishment based outside the EEA, in this case safeguards are in place to guarantee the best possible protection.

For the Legitimate Business Interest Purposes, the data may be communicated to the following categories of recipients: (i) third-party providers of assistance and consulting services for Haier Energy with reference to activities in the (for example but not limited to) technological, accounting, administrative, legal and insurance sectors; (ii) companies of the Haier Group; (iii) potential purchasers of Haier Energy and entities resulting from the merger or any other form of transformation regarding Haier Energy; (iv) the competent authorities.

Furthermore, to activate and take advantage of you warranty your data may be communicated to the following categories of recipients: (i) third parties responsible for the processing of personal data; (ii) companies of the Haier Group.

To obtain more information on the data processors working on behalf of Haier Energy you may write to the office of Haier Energy for the attention of the Data Controller. If you use a Google or Apple login or digital assistants and digital platforms in conjunction with Haier Energy products, your personal data may be shared with the providers of such services. In such cases, these providers will act as autonomous data controllers and will operate in accordance with the provisions set out in their privacy policies and terms of service, which we invite you to consult.

Lastly, Haier Energy as part of the Haier Group may transmit your data within its business group for administrative and accounting purposes. The legal basis legitimising the processing of data for this purpose is that described in art. 6, par. 1, letter f) of Regulation (EU) no. 679/2016, or as the processing is necessary to pursue a legitimate interest of the data controller in the circulation of data for administrative purposes within its business group.

International transfers

Haier Energy Technology Co., Ltd. is a company based in No.57, No.17, Jiujiang Road, Tongji Street Office, Jimo District, Qingdao City, Shandong Province (China).

For specific requirements connected to the location of the servers of Haier Energy and/or its providers, for the provision of services at stake, the servers and databases are located within the EEA.

However, Haier Energy also relies on providers – in their capacity as data processors – located in third countries outside the European Union. Your data may also be communicated between Haier Group companies with registered office in third countries outside the European Union or be transferred to our service providers and third-party providers acting on our behalf, as set forth in this disclosure. In that case, Haier Energy undertakes to guarantee adequate levels of protection and safeguards, also through contractual agreements, including by entering into standard contractual clauses.

9. THE RIGHTS YOU ARE AFFORDED BY LAW AND HOW YOU MAY EXERCISE THEM

The law affords you the right to check how your data are processed and if applicable to restrict their use. You may exercise these rights at any time and free of charge by contacting our company and writing to the addresses specified above. Haier Energy does all that is necessary to facilitate the exercise of your rights.

Information about this is provided below.

Rights of the data subjects

Pursuant to arts. 15 et seq. of the Regulation, you have the right to:

  1. receive confirmation of the existence of your personal data, access their content and obtain a copy of them (right of access);
  2. update, modify and/or correct your personal data (right to rectification);
  3. request the erasure or restriction of the processing of personal data in the cases set forth in the Regulation, including if the data are processed in violation of the law or if it is not necessary to store them in relation to the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction);
  4. withdraw consent, when provided, at any time and without prejudice to the lawfulness of the processing based on consent provided prior to the withdrawal (right to withdraw consent). You can activate this right directly via the app Energy in the privacy section;
  5. within the limits of what is set forth in the Regulation, receive a copy of the data you have provided in a structured, commonly used machine-readable format and ask for this data to be transmitted to another Data Controller if technically feasible (right to data portability);
  6. object to processing in the cases in which this is set forth in the Regulation (right to object).

You may expressly prohibit the exercise of certain rights listed above by those entitled by sending a written statement to the Company at the email address provided below. The statement may be revoked or modified later on using the same procedures. Please note that requests to erase data are subject to current legal and regulatory obligations on the storage of documents.

If you are an individual based in the EU, and you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), please email us at gdpr-representative@redopen.it. We have appointed ReD OPEN S.r.l. to act as our EU representative. Please ensure to include our company name (Nahui) in any correspondence you send to our Representative. For all other questions or for non-EU residents, the address is: nahuiprivacypolicy@haier.com.

In contacting us, please make sure to include your name, email address, postal address and/or telephone number(s) to be sure that we can properly manage your request.

If you believe that your data have not been processed in compliance with the regulation or there are objections with regard to their use, you may submit a complaint to the Supervisory Authority of the Member State in which you reside or work or the place where the alleged violation took place.

Additional information – Links – Minors

For the individual services offered by Haier Energy we invite you to consult the individual privacy policies for all of the details relating to the processing of your data.

Please note that when you access the Website section devoted to product registration and the acquisition after-sales activities on your appliance and you complete the form, your personal data may be processed by partner organizations operating in the field of maintenance and customer care. For more information on the processing activities carried out by our partner organizations, we invite you to view their specific privacy policy.

The app and Smart Cube products are not intended for minors. If you are a minor, you cannot register as a user on the aps, or otherwise provide us with your personal data. If we realise that we have inadvertently obtained the personal data of a minor, we will immediately erase them.

Date of last update: 2025-02-17 10:15:31