EU Data Act Transparency Notice

Effective date: 5 August 2026 (the EU Data Act has applied since 12 September 2025)

This notice explains the data generated when users in the European Union use TerraMow robotic lawn mowers, the companion App and cloud services, and explains how such data may be accessed and shared. This notice does not replace our Privacy Policy. Where data constitutes personal data, the GDPR and other applicable data protection laws continue to apply.

1. Data holder

Company name: Shenzhen Muxin Intelligent Technology Co., Ltd.

Registered address: RM 1C-B, 2F, BLDG 1C, TINGWEI IP, BAOAN DIST, SHENZHEN, CHINA

Contact: support@terramow.com

2. Data generated by the product

Depending on the product model, feature settings and manner of use, the product and related services may generate the following data:

· Operational and status data: battery, charging, motor and wheel data; operating mode; task time; coverage area; and device status.

· Diagnostic data: error codes, system alerts, connection status, firmware version and maintenance information.

· Navigation and environmental data: virtual boundaries, maps, routes, obstacles, location data, and sensor readings such as rain, tilt and collision data.

· User settings and commands: mowing schedules, cutting height, area selection and remote-control commands.

Readily available data generally includes raw data, pre-processed data and the metadata necessary to interpret and use those data. Content itself and highly inferred or derived data are generally outside the scope of mandatory access; access to and sharing of data remain subject to applicable intellectual property and trade secret protections.

3. Data format, frequency and retention

Data may be stored on the device or uploaded to our cloud servers. Some status data may be generated continuously or near real time, while task records and error information are generally generated when the relevant event occurs. Exported data are generally provided in JSON, CSV or another structured, commonly used and machine-readable format.

Estimated volume: under normal use, each device generates approximately 10–50 MB per day or 0.3–1.5 GB per month; initial mapping or a substantial map update may generate an additional 50–200 MB per event.

Frequency: status data are updated when the user operates the device or when the device status changes; task start and end events, setting changes and error information are recorded when the relevant event occurs; map data are updated after initial mapping, map changes or completion of a task.

Retention: device-side operating and diagnostic logs are generally retained for 30 days; cloud-based task, status and diagnostic data are retained for 24 months; maps and user settings are retained while the related services are in use and are deleted or anonymised within 30 days after account deletion or device unbinding; data access requests and related verification records are retained only for as long as necessary to process the request, maintain security, comply with applicable legal obligations or handle disputes, in accordance with our data retention policy.

4. How to access and download data

Users may view the device status, tasks and settings currently made available through the TerraMow App.

To download data generated by the product or related services, please send a request to support@terramow.com and provide your account information, product serial number, requested data scope and time period. We may request information necessary to verify your identity, ownership or right to use the product.

For readily available data, we will provide eligible users, without undue delay, with data in a secure, comprehensive, structured, commonly used and machine-readable format, free of charge to the user. Where relevant and technically feasible, data may be made available continuously or in real time.

Requests to erase data may also be submitted through the above email address. We will explain which data can be erased and how the request will be handled based on product functionality, contract requirements, device security and applicable law.

The duration and termination conditions of the companion App and cloud services are governed by the applicable service terms. Users may terminate the relevant services through the account functions provided in the App or by contacting support@terramow.com. Data processing after termination will be handled in accordance with this notice, our Privacy Policy and applicable law.

5. How we use data

We use data primarily to provide product functionality, display device status, perform mowing tasks, conduct fault diagnosis, maintain security, provide customer support and deliver necessary software updates.

We use readily available non-personal product data and related service data only on the basis of an applicable contract with the user and for the purposes specified in that contract. Personal data are processed in accordance with applicable data protection laws and our Privacy Policy.

We will not use non-personal product data to derive insights about the user's economic situation, assets, production methods or use in a manner that undermines the commercial position of a business user. Except for fulfilling our contract with the user or responding to a valid request made by the user under the Data Act, we will not make non-personal product data available to third parties.

6. Sharing data with third parties selected by the user

Users may request that we make data available to a qualified third party of their choice, such as a repair provider or smart-home service provider. Please send the request to support@terramow.com and provide the third party's identity, the purpose of sharing, the requested data and the sharing period.

After completing the necessary verification, we will provide the data without undue delay in a secure, structured, commonly used and machine-readable format. Where relevant and technically feasible, data may be made available continuously or in real time. The transmission method will depend on the data type and technical conditions; not all data will be provided through a continuous API.

Making data available to the user is free of charge. A commercial third party may be required to pay reasonable compensation under fair, reasonable, non-discriminatory and transparent conditions; such compensation will not be charged to the user. Users may request that continuous sharing be stopped by contacting support@terramow.com.

An undertaking designated as a gatekeeper under the EU Digital Markets Act is not an eligible third party under Article 5 of the Data Act and may not receive data under that Article.

7. Personal data, security and trade secrets

If a request includes another person's personal data, we may provide the data only where a valid legal basis exists and all applicable data protection requirements are met. We may filter or anonymise data to protect the rights of other individuals.

For data containing trade secrets, we may require users or third parties to adopt reasonable confidentiality and security measures. In circumstances permitted by law, we may restrict, suspend or refuse to provide specific data where sharing would cause serious damage to trade secrets or violate mandatory product safety requirements. Where we restrict, suspend or refuse sharing, we will provide written reasons and notify the competent authority where required by law.

Users must not use data obtained under a data access request to develop a connected product that competes with the connected product from which the data originate, or make the data available to a third party for that purpose. This does not prevent lawful competition in repair, maintenance or other after-sales services.

8. Complaints and contact

If you believe that we have not complied with the EU Data Act, you may lodge a complaint with the competent authority designated under Article 37 of the Data Act in the Member State where you are located. For matters involving personal data, you may also complain to the competent data protection supervisory authority. These rights do not affect your right to seek judicial remedies.

For data access, download, third-party sharing, stopping data sharing or other questions, please contact: support@terramow.com.

Privacy Policy: https://www.terramow.com/pages/privacy-policy

Last updated: 5 August 2026