EU Data Act Notification

24 March 2026

In compliance with our obligations under the EU Data Act (Regulation (EU) 2023/2854),  we hereby provide you, as users of our products and services, with this timely notification to clearly inform you about the data collected through our products, as well as other important pre-contractual information relevant to you.

This is to ensure transparency and to support your rights as a user to access and manage the data generated through the use of our products. The data from your devices produced and/or distributed under the Navimow Group and related services, is collected when you use your devices or when your appliances is connected to the Navimow App,  and the data may be shared with the Navimow Service App. Such data is held and managed by Navimow B.V. (address:Teleportboulevard 130, ScaleHub Office B2.01, 1043EJ Amsterdam, The Netherlands),  as Data Holder in accordance with the EU Data Act.

Please note that this notification may contain both personal data and non-personal data. For personal data processing details, please refer to the Privacy Policy, which shall prevail in case of any conflict.The Privacy Policy is available on our official websites (https://navimow.segway.com/policies/privacy-policy) or Navimow App.

By consenting to this notification, you agree to our data processing or usage activities and enter into a contract with us regarding the use of data.

I. INFORMATION ABOUT DATA

A. Specification of Data Points

Product Data

Product Model	Data Points Collected	Data Volume	Collection Frequency
i1	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance	estimated 8GBytes daily	continuously and in real-time
i2 AWD	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance	estimated 8GBytes daily
i2 LiDAR	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · point cloud data from LiDAR · chassis and blade working hours and time to next maintenance	estimated 8GBytes daily
i2 LiDAR Pro	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · point cloud data from LiDAR · chassis and blade working hours and time to next maintenance	estimated 4GBytes daily
H1	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance	estimated 8GBytes daily
H2	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · point cloud data from LiDAR · chassis and blade working hours and time to next maintenance	estimated 8GBytes daily
X3	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance	estimated 4GBytes daily
X4	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance	estimated 4GBytes daily
Terranox	· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance	estimated 4GBytes daily

 

Related Service Data

· Built-in app (APP installed on the vehicle)

Related Service	Data Points Collected	Data volume	Collection Frequency
mapping of surrounding	· user action · spacial and visual information of working environment	estimated 1GBytes per time	Based on user action
mowing on selected regions	· user command · mowing regions · mowing order and time	estimated 1MBytes per time	Based on user action
firmware update over the air	· sw version · error log	estimated 4GBytes per time	Based on user action and when a new sw is uploaded to the cloud
vehicle setting	· user settings · event log	estimated 1MBytes per time	Based on user action
vehicle state monitor	· vehicle working state · mowing progress · fault codes · network/Bluetooth state · ROS messages · debug log	estimated 1MBytes per minute	Continuous and event-based

 

· [Navimow App]

Related Service	Data Points Collected	Data volume	Collection Frequency
Device Activation and Connection	Bluetooth and network data	5 to 10 records	Based on user action and change of device status
Map Recording		2 to 5 records
Map Editing		2 to 5 records
Mowing		5 to 10 records
Advanced Features		2 to 5 records
Safety Settings		2 to 5 records
Component Maintenance		2 to 5 records
Device Management		2 to 5 records
APP Home Page		5 to 10 records

 

· [Navimow Service App]

Related Service	Data Points Collected	Data volume	Collection Frequency
Device connection	Bluetooth data	0 to 5 records	Depending on the device, data collection is triggered when the user connects the device via the after-sales app and is updated when the connection status changes.
Vehicle inspection		10 to 20 records
RMA repair		0 to 5 records
Field test		0 to 5 records
Toolbox		0 to 5 records
OTA	Bluetooth and network data	0 to 5 records

 

B. Duration of Retention

In accordance with our obligations under the EU Data Act, specific retention periods for different types of data collected through connected products are listed below. After the expiration of these periods, the data will no longer be accessible to the user. Upon expiry of the applicable retention period, the data will either be securely deleted or anonymized. Anonymization entails aggregating or converting the data into statistical form in a manner that ensures it cannot be linked to any individual user or device ID.

For more information concerning the retention of personal data, please refer to paragraph 8 and 14 in the privacy policy link: https://navimow.segway.com/policies/privacy-policy.

The non-personal data collected from your connected appliances is retained solely to:

· Ensure the proper functioning, maintenance, and timely troubleshooting of the devices.

· Support energy efficiency and function monitoring, and optimize product performance.

· Analyse usage patterns to develop and offer services that enhance user comfort and convenience.

· Enable users to interact with devices more intuitively and autonomously, simplifying everyday tasks

· Enhance smart usage of the appliances to improve practical day-to-day living

· Drive innovation and the continuous development of our products 

· Provide proactive and personalized customer support based on real-time device status and usage

· Fulfill applicable legal and regulatory obligations, including those under the EU Data Act

· Promote transparency and accountability in the management and use of your data

Retention periods are carefully determined to ensure that data is stored only for as long as necessary to meet these purposes.

Type of Data	Retention Period
· charging status · battery level · sensor signals,such as wheel speed,steering wheel angle, acceleration · blade speed and height · liftup status · temperature of motors, battery, screen · led light status · weather condition · location from GNSS · images from camera · chassis and blade working hours and time to next maintenance · point cloud data from LiDAR	One month
· user action · spacial and visual information of working environment · user command · mowing regions · mowing order and time · user settings · event log · RMA repair · OTA	until modified by the user
· sw version · error log	Three years
· vehicle working state · mowing progress · fault codes · network/Bluetooth state · ROS messages · debug log	One month
· Device Activation	Until the purpose of data processing has been achieved (ie. supporting the full lifecycle monitoring of devices and after-sales traceability).
· Device Connection	Connection data stored until disconnected
· Map Recording · Map Editing	Until map deleted by user
· Mowing · APP Homepage	Until next mowing cycle
· Advanced Features · Safety Settings · Component Maintenance · Device Management	Until users disconnect and remove data, the device will restore to factory default settings.

After the expiration of these periods, the data will no longer be accessible. For data generated through the use of the following related services— Advanced Features, Safety Settings, Component Maintenance, and Device Management—once the user’s account is deleted, this data is no longer stored and is therefore inaccessible, regardless of the retention periods stated above.

Please note the following information about your ability to delete data：

· Retention of Data

All non-personal data including operational logs, settings, usage data, error reports, device identifiers, and firmware/software version logs, shall not be subject to deletion by the User. Such data are considered Residual Data under the Model Contractual Terms and do not qualify as User’s Removable Data.

Retention of this data is necessary to:

· Ensure the safe and proper operation of the appliance;

· Facilitate maintenance, servicing, and repairs;

· Comply with applicable safety, regulatory, or warranty obligations;

· Other necessary purposes specified in this notification.

Users do not have the right to erase non-personal data unless the Data Holder explicitly agrees.

Retention of Residual Data serves the legitimate interests of subsequent users, for example to allow updates, servicing, or repair.

While two subsequent users may agree contractually on deletion or non-deletion of certain data, the Data Holder is not obliged to implement such an agreement unless it has explicitly consented to do so.

· No Right to Erasure 

The User explicitly acknowledges that they have no right to erase any non-personal data stored on or generated by the Product or App. All such data will be retained by the Data Holder for the purposes specified above.

· Exception

In the case of multiple usership (if applicable), users may contact us to erase the data related to them and also to terminate data access, use, or sharing, or submit requests to terminate, in particular taking into account situations in which the ownership or usage of the connected product changes.To exercise the above matters, Users can contact us by sending a written request via email to support-navimow@rlm.segway.com. 

However, to the extent permitted by the Data Act, please note that we reserve the right to determine whether the situation constitutes multiple usership and, accordingly,  whether such deletion is permitted.

 

For information concerning the erasure of personal data, please refer to the Privacy Policy, available on the our website (paragraph 14 in the privacy policy link: https://navimow.segway.com/policies/privacy-policy) and Navimow App.

 

C. Data Availability and Loss

Data may not be collected or retrievable in certain situations, including but not limited to:

· Temporary technical outages or downtime of the services, during which data may not be captured.

· Use of appliances or devices while disconnected from the network, in which case data generated during that period may not be recorded or recovered once the device is reconnected.

· Any other technical or operational issues that result in partial or complete loss of data.

In these cases, the Data Holder cannot guarantee recovery of missing data. Data generated during such periods may be permanently unavailable, and users should not expect to retrieve or claim such data.

 

D. Storage location and security of the appliance and related services data:

Product Data

Data storage	10% remote server and 90%locally
Storage location	End-user device:Depend on device location Cloud based:Frankfurt Germany
Cloud service used	Microsoft Azure
Encryption	AES encryption
Access controls	Role-based; principle of least privilege

 

Related Service Data

· Built-in app

Data storage	End-user device and Cloud based
Storage location	End-user device:Depend on device location Cloud based:Frankfurt Germany
Cloud service used	Microsoft Azure
Encryption	AES encryption
Access controls	Role-based; principle of least privilege

 

· Navimow App

Data storage	Cloud based
Storage location	Frankfurt Germany
Cloud service used	Microsoft Azure
Encryption	AES encryption
Access controls	Role-based; principle of least privilege

 

· Navimow Service App

Data storage	Cloud based
Storage location	Frankfurt Germany
Cloud service used	Microsoft Azure
Encryption	AES encryption
Access controls	Role-based; principle of least privilege

 

E. Data Classification

When you create a profile in our App and connect your household appliance, we collect both your personal and non-personal data.

Personal data is processed in accordance with applicable data protection regulations, including the General Data Protection Regulation (“GDPR”). Please note that for your “obvious” personal data (such as name, surname, email, or user ID) processing details, please refer to the Privacy Policy, which shall prevail in case of any conflict. 

Non-personal data, such as technical information related to product usage (e.g., temperature settings, usage cycles, energy consumption, error logs), is collected as outlined in the sections above, by product category. While this data is considered non-personal by nature, it may become personal data when it is linked to identifiable information you provide to us—such as your name, surname, email, or user ID. In such cases, even seemingly technical, non-personal data is treated as personal data and handled accordingly to ensure full compliance with applicable laws, including both the General Data Protection Regulation and the EU Data Act.

For more information about the processing of personal data, please refer to our Privacy Policy, available on our official websites  (https://navimow.segway.com/policies/privacy-policy).

 

F. Data structure and format

The data is made available in a structured, commonly used, and machine-readable format, specifically: string, number, array form and JSON/XML format.

 

G. Sharing Policy 

In cases where a User wishes to transfer his/her rights to use the Product or Related Services to a Subsequent User, the following rules shall apply:

Type of Data	Rule
· Device Activation and Connection	User can request that the data are shared with a third party and, where applicable, end the data sharing, by binding and unbinding accounts or sending written request via email to support-navimow@rlm.segway.com
· Map Recording · Map Editing · Mowing Advanced Features · Safety Settings · Component Maintenance · Device Management · Device connection · Vehicle inspection · RMA repair · Field test  · Toolbox  · OTA · mapping of surrounding · mowing on selected regions · firmware update over the air · vehicle setting · vehicle state monitor	User can request that the data are shared with a third party and, where applicable, end the data sharing, by sending written request via email to support-navimow@rlm.segway.com

 

However, to the extent that the new User has a legitimate interest in accessing historical data necessary for proper operation, maintenance, updates, or incident handling, such non-personal appliance data (as listed above) may also be made available to the Subsequent User. Personal data of previous users shall never be shared. 

H. Data Usage

We use data only for fulfilling contracts, maintaining device function, security, troubleshooting, product improvement, providing after-sales service, conducting surveys or advertising (where applicable). No data will be permitted to usage by any third party except for data of device activation and connection will be sent to third-party smart home platform, for the purpose of allowing users to operate the lawnmower on third party platform. Users will be required to complete Auth 2.0 authentication and authorization for such third party usage.

 

II. USER RIGHTS

A. Data Access and Data Sharing

You can directly view and access data displayed on application. For accessing of data not displayed on application, downloading data or deletion of data, you can send written request via email to support-navimow@rlm.segway.com.

For data sharing, you can refer to “Part G Sharing Policy” in this notification.You have the right to request that we share your readily available data—along with any metadata needed to interpret it—with a third party. This is subject to the requirements of the Data Act. We will fulfill such requests without undue delay, providing the data at the same quality we use ourselves, in a secure, easy, and free manner, and in a comprehensive, structured, commonly used, and machine-readable format. Where relevant and technically feasible, this can also include continuous, real-time access.

Please note that we may reject your request for reasons that comply with the EU Data Act, such as protecting trade secrets or the personal data of others. In such cases, however, we will provide you with a duly substantiated justification for the rejection.

B. Right to Complain and Question

If you believe that your rights under the EU Data Act have been infringed, you have the right to lodge a complaint with the competent supervisory authority, which will be designated by the respective Member State.

C. Protection of Trade Secrets

Think of a trade secret as the unique way we create a product or service. It is valuable information that we protect so that others cannot use it to compete with us. Some data may contain trade secrets. If applicable, we will notify you, and the trade secrets belong to Navimow B.V. or other entity belonging to the Navimow Group. If we subsequently discover trade secrets belonging to other third parties, we will disclose them to you without undue delay.

D.Contact Information

If you have any questions, or want to exercise any of your rights under the EU Data Act, you are encouraged to contact us at the above-mentioned email address: support-navimow@rlm.segway.com.

 

III.Term of the Notification

This notification remains effective as long as you continue to use our products or services. If you no longer using them (e.g., by delete your APP account, or if we determine that a connected product has been scrapped and withdrawn from the market), the terms of this notification corresponding to the ceased portion of usage will terminate.

This notification will be updated regularly to reflect any changes in our data handling practices or legal requirements arising under the EU Data Act.

You can view this notification on the product packaging, in the app, or on the official website (https://navimow.segway.com/).