EU Data Act Notice

As part of the European data strategy, the Data Act ensures that users of connected products can access the data they generate and share it with third parties of their choice. SEI Robotics, as a leading manufacturer of connected devices (such as Google TV and Android TV boxes), is committed to full transparency and compliance, specifically focusing on Article 3: Access by Design.

1. Connected Products Overview

Connected Product means an item that obtains, generates or collects data concerning its use or environment and that is able to communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the user.

• Dongle/Stick
• STB
• AloT Smart Speaker
• Hybrid Box

The functions of these connected products, as well as details regarding the data they generate and how it is handled, are described in the following sections of this notice.

2. Role and Responsibilities

Under the EU Data Act, roles are clearly defined to ensure accountability.

• Manufacturer: SEI Robotics acts solely as a device manufacturer.
• Data Holder: A Data Holder is an entity with the right or obligation to make data available. SEI Robotics does not act as a Data Holder for device-generated product data because it does not collect or store this data on its own servers; all such data remains stored locally on the device under the user's control.
• User: The natural or legal person who owns or leases the connected product and has the right to access the data it generates. The user is the direct owner of the data.

3. Data Generated/Collected by Connected Products

Because SEI Robotics is not a Data Holder, its primary obligation is to comply with Article 3, ensuring that its products are designed and manufactured so that data is, by default, easily and securely accessible to the user.
In accordance with Article 3(2), the following tables provide detailed descriptions of the data generated by SEI Robotics devices.

Table 1: Core System and Connectivity Data

Table 2: Device State and Operational Data

Table 3: Configuration and Accessibility Data

*Data means any digital representation of acts, facts or information and any compilation of such acts, facts or information, including in the form of sound, visual or audio-visual recording.

**The "Storage location" column refers only to the volume of generated data that can be retained, not to differences in data type or quality. Data can be stored either in the device's internal storage or exported to external media (e.g., USB drive or computer).

Direct on-device access is limited by the circular buffering structure of logcat, which restricts the amount of historical log data that can be retrieved. In contrast, external storage allows for significantly larger datasets to be preserved and accessed over longer periods.

4. User Data Access, Erasure and Portability

Individuals or legal entities using our Connected Products hereinafter referred to as ("Users") have the right, in accordance with the EU Data Act, to request access to, erasure of, or portability of data generated/collected by Connected Products.

SEI does not act as a data holder and does not directly store or control user data generated by the Connected Product. However, to support Users in exercising their rights under the EU Data Act, SEI provides guidance on the available data access methods and procedures implemented by the relevant service providers and platform operators.

Detailed instructions on how to access, export, delete, or transfer data generated by the Connected Product can be found in the document:
"SEI Data Access Manual for a Google TV Connected Device"

5. Data Sharing and Compliance with Requests for Data

In accordance with Articles 4 to 7 of the EU Data Act, Users may have the right to access, use, share, or make available data generated by the Connected Product to eligible third parties.

SEI does not act as a data holder and does not directly store, control, or process user data generated by the Connected Product. Accordingly, requests relating to data access, sharing, portability, or disclosure under Articles 4 to 7 of the EU Data Act must be addressed to the relevant data holder, service provider, platform operator, application provider, or other entity responsible for the data concerned.

Users are responsible for managing permissions and authorizations for data sharing through the applicable services associated with the Connected Product.

6. Data Security and Protection Mechanism

SEI does not act as a data holder and does not directly store, control, or process user data generated by the Connected Products. However, SEI supports the secure design and implementation of data handling processes by applying industry-standard security principles in collaboration with relevant service providers and platform operators.

Appropriate technical and organizational measures are applied to support the protection of data, including encryption during transmission where applicable, access control mechanisms, and regular security reviews to prevent unauthorized access, misuse, or alteration of data.

Access to systems is strictly limited to authorized personnel on a need-to-know basis. Regular training and internal compliance activities are conducted to maintain strong security and privacy awareness.

SEI follows and holds internationally recognized standards to ensure a high level of information security and privacy protection:

• ISO 27001 – Information Security Management System
• ISO 27017 – Cloud Security Controls
• ISO 27701 – Privacy Information Management System

7. Interoperability Notes

Data generated by Connected Products can be made available in a structured, commonly used, and machine-readable format to support interoperability requirements under Article 33 of the EU Data Act.

Unless explicitly authorized by SEI in writing or required by applicable law, the data shall not be used for the following purposes:

• Development of competing products
• Reverse engineering of algorithms or underlying system logic
• Targeted advertising or user profiling

Any unauthorized use of the data may result in suspension or termination of access rights and may lead to legal consequences.

8. Contact and Data Request Channel

This webpage has been prepared for general reference purposes; your specific case may require customized support. For any questions regarding the information provided in this manual or the application of the EU Data Act to your device, please contact us at eu-data-act@seirobotics.net.

9. Policy Updates

This policy will be updated regularly based on legal requirements and business needs. All updates will be announced through our official website and related channels.

Click here to view the official public notice document for the EU Data Act notice page.