EU Data Act – FlexiSmart

On this page you will find information in accordance with Regulation (EU) 2023/2854
(EU Data Act) for Thermotec electric heaters with integrated
FlexiSmart control and the associated
App and cloud services.

FlexiSmart is an integrated component in Thermotec electric heaters.,
WLAN-enabled control. In addition to direct temperature control, it also allows
they operate and control them via an app.

For remote control, Thermotec recommends the
Smart RM App.

Affected products and control

This information applies to Thermotec electric heaters with integrated
FlexiSmart control.

Control: FlexiSmart
App recommended by Thermotec: Smart RM

The FlexiSmart control unit is part of the respective Thermotec system.
Electric heating and allows for temperature control when in use.
the WLAN function, control via a connected app and
Cloud service.

Product and service data

When using the FlexiSmart control system, data is generated or
Settings processed for the control and operation of the
Heating is required.

These include in particular:

• Room/actual temperature
• set minimum temperature
• Heating or switching status
• Operating mode
• Time and weekly programs
• Wi-Fi connection status
• Device and configuration settings

The FlexiSmart control system supports a programmable
Temperature control as well as operation and remote control via WLAN.

When using the Smart RM app, information about the
Smart devices associated with the user account, as well as settings for
Scenarios and automations are processed.

Which data are actually created or processed depends on the
specific configuration and use of the FlexiSmart control system and the
App off.

App and cloud connectivity

Thermotec recommends the use of the FlexiSmart control for remote control.
Smart RM App.

The FlexiSmart control can be accessed via the app via an internet connection
Can be operated and configured from a distance.

When using the app, the remote control is used to provide the
Processes information from the connected smart device. Additionally
The following app and account data can be processed, among others:

• User account information
• Information about the smartphone or device used
• Device identification
• IP address
• App version
• Smart devices connected to the user account
• Scenario and automation settings

Further details on the processing of personal data are provided in
as described in the privacy policy of the Smart RM platform.

Data format and scope

Thermotec currently has no plans to release a FlexiSmart control unit.
precedes the product-specific information that defines the technical format
and the estimated volume of the generated product data in full
emerge.

Therefore, Thermotec does not make any assumptions or estimates in this regard.

Generation and transmission of data

The FlexiSmart control unit processes current data for its operation.
Temperature, status and setting data.

When using the WLAN and app functions, remote control is
required device information between the FlexiSmart controller
and processed by the associated app/cloud service.

Product-specific technical documentation on which data
Continuously, in real time or event-based to the cloud service
Thermotec is currently not in possession of the transmission.

Storage and storage duration

According to the data protection declaration of the Smart RM platform,
Information stored on servers. For security and
Backup purposes may additionally store information and data on servers.
stored in affiliated companies.

A specific location of the servers used for Smart RM is specified in
The available Smart RM privacy policy is not mentioned.

Smart RM does not specify a fixed period for the storage period.
The information is generally stored for as long as necessary.
is necessary for the purposes stated in the privacy policy,
provided that longer storage is not required by law, or
is permissible.

Data access and deletion

Users can use the Smart RM app to control and
Control provided by the connected FlexiSmart controller
Accessing information.

According to the Smart RM privacy policy, the user account
including the associated information about the following
Fields to be deleted:

Profile → Personal center → Terminate the account

According to Smart RM, the deletion option includes the following:

• Smart RM Account Information
• Information about the device used
• Information about connected smart devices
• Scenario and automation information
• Further information linked to the Smart RM account

Data transmission / Data request

For inquiries regarding access to product and service data, as well as the provision of the data to a third party designated by the user, please contact:

Thermotec AG
Arnsdorf 26
02894 Vierkirchen
Germany
datenzugang@thermotec-ag.de

Thermotec reviews the request and, if necessary, agrees on the technical delivery with the respective technical service provider.

Transmission of data

According to the Smart RM privacy policy, personal data can be
Data shared with affiliated companies and external service providers
be made, insofar as this is necessary for the provision or improvement of the products
and services are required.

For example, providers of data centers, data storage,
Telecommunications and customer service are included.

Smart RM states that it does not use personal data for
To share marketing purposes with these service providers.

Use of the data

According to the Smart RM Data Protection Policy, collected
Information is used in particular to:

• to control connected smart devices,
• To provide products and services,
• to ensure the functionality and safety of the products,
• Continue developing products and services,
• To provide maintenance and support services,
• to investigate technical problems and
• to analyze the use and functionality of the services offered.

EU Data Act and cloud platform

The technical platform used by Smart RM is complemented by
Information available on the implementation of the EU Data Act.

Tuya provides information on the implementation of the EU Data Act at the level of its
IoT and cloud platform ready.

According to Tuya, this was done with the involvement of an external third party
a structured assessment to prepare for the EU Data Act
carried out. Among other things, aspects of data access were examined,
the transparency, data export, and user-authorized
Consideration of data transmission.

The information published by Tuya refers to the
Platform level and does not contain product-specific information regarding
Thermotec FlexiSmart control system.

Tuya – EU Data Act

Information from Tuya about the EU Data Act

Information about the connected service

For the Smart RM app and the underlying technical platform
additional information from the respective providers is available.

Smart RM – Privacy Policy

Open data protection policy

Smart RM App

Smart RM in the Google Play Store

Smart RM in the Apple App Store

Tuya – Information on the EU Data Act

Information from Tuya about the EU Data Act

Note: The currently available privacy policy
The Smart RM platform dates from 2018 and was thus introduced before
The EU Data Act comes into force. It does not constitute an independent
Provides product-specific Data Act information for the FlexiSmart control.

The general data-act information regarding the underlying
The platform does not include product-specific information for FlexiSmart.
Control.

Therefore, Thermotec provides information that is not currently product-specific.
documented, without any own assumptions or estimates.

Note on product assignment

The information above refers to Thermotec
Electric heaters with integrated FlexiSmart control.

What data are actually processed and transferred depends
In particular, whether the FlexiSmart control system is used exclusively locally
operated or connected via WLAN with the app/cloud service.

The information described here FlexiSmart control
are based on the information provided by FlexiSmart Pro / Thermalink Pro
To distinguish these systems, Thermotec provides separate
Data-Act information available.

Back to overview EU Data Act