UniEnergy App Privacy Policy

Last Updated: June 30, 2025
Effective Date: June 30, 2025

Preamble

The UniEnergy App (hereinafter referred to as "we", "controller", "processor", or "Manos") is a home energy management system provided by MANOS Energy GmbH.

Manos is committed to protecting and safeguarding your privacy. This Privacy Policy explains how we collect, store, and use your personal information through the app, and applies to all services. By using our services, you agree to the terms of this Privacy Policy and consent to our use of the information you provide in accordance with this Privacy Policy.

Registered address: Sommestraße 23, Unterhaching, Bavaria, Germany

Postal code: 82008

Phone: 0049 1743150766

Email: info@manos.ai

To explain how the UniEnergy App collects, uses, and stores your personal information and what rights you have, we will explain the relevant matters through this Privacy Policy, with the main contents as follows:

Part One: Personal Information We Collect and Process as Data Controller and Legal Basis

1. Information We Collect and Use

We will collect and use the information you actively provide or information generated from using the services in the following ways:

1.1 When you register on the UniEnergy App, we will collect and use your email address and username. The purpose of collecting this information is to help you complete the registration function of the UniEnergy App and to protect the security of your account. If you do not provide such information, you may not be able to use our services normally.
Legal basis: Pursuant to Article 6(1)(b) of the GDPR, this is necessary for the performance of the contract between you and us. Processing your email and username is necessary for completing account registration and identity verification.

1.2 To optimize our services, we collect service logs (your searches and browsing within the UniEnergy App, service failures, referral links, etc.), installation lists, your app usage frequency, crash data, overall usage, performance data, and app sources.

1.3 When you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. To provide services according to your request, within your authorized scope, customer service personnel need to query or verify your relevant information. We will take technical and administrative measures to ensure your information's security and confidentiality as much as possible and use this information only within the necessary scope. We may also keep your contact information (such as phone numbers, emails, or other contacts you use or provide), communication records and content, and other necessary information to provide and record customer service.
Legal basis: Pursuant to Article 6(1)(f) of the GDPR: We collect and process such data based on our legitimate interests in ensuring service security, maintaining system functions, optimizing product experience, and providing customer service.

1.4 If we use your personal information beyond the purposes you authorized, we will notify you again and obtain your explicit consent before using your personal information. Please understand that the functions and services we provide are continuously updated and developed. If any function or service does not inform you of the collection and use rules described above, we will notify you separately via page prompts, interactive programs, website announcements, or other means to obtain your consent regarding the scope, purpose, and methods of information collection.

1.5 According to Article 6(1) of the GDPR, we may collect and use your personal information without your consent, for example:
a) As necessary to perform a contract to which the data subject is party or at the data subject’s request prior to entering into a contract;
b) As necessary for the controller to comply with a legal obligation under EU or Member State law;
c) For performing a task carried out in the public interest or official authority;
d) To protect vital interests of the data subject or another natural person (e.g., emergency medical situations);
e) For the legitimate interests pursued by the controller or a third party, provided such interests do not override the fundamental rights of the data subject.

2. Information Sharing

To ensure the realization of certain independent functions and allow you to use and enjoy more services and features, we embed third-party SDKs in the app and carefully evaluate the purposes of using these SDKs. For more information on the purpose, method, and scope of personal data processing by SDKs, please refer to the "Third-Party Sharing List."
As our business develops, Manos may undergo mergers, splits, or other transactions. If this involves the transfer of personal information, we will inform you accordingly and continue to protect or require the new processor to protect your personal information.

3. Your Rights

While using the UniEnergy App, to facilitate your access, copying, correction, and deletion of your personal information, and to protect your rights to withdraw consent and delete your account, we provide corresponding operational settings in product design. Additionally, we set up channels for complaints, reports, and requests for explanation, and your opinions and requests will be handled timely. If you have questions about how to exercise these rights, you may contact us through the contact details disclosed below the agreement.

3.1 Right of Access

You have the right to request access to your personal data held by us at any time, to understand how we collect, use, and process your information. We will respond to your request within the legally prescribed period and provide the relevant information free of charge.

3.2 Right to Data Portability

You have the right to obtain a copy of your personal data we hold, in a structured, commonly used, and machine-readable format. You may also request that we directly transfer these data to another data controller (to the extent technically feasible).

3.3 Right to Erasure

You have the right to request deletion of your personal data. We will process your request as soon as possible within the scope permitted by law. If deletion is not possible due to legal obligations or other legitimate reasons, we will inform you of the specific reasons.

3.4 Right to Rectification

You have the right to request correction of any inaccurate or incomplete personal data to ensure the accuracy of your information. If you find errors in our data, please feel free to contact us to submit correction requests. We will process your request within the legally prescribed period and update your information timely.

3.5 Right to Withdraw Consent

You have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Some data collection and processing activities (such as device cloud connection, precise location acquisition, etc.) depend on your authorization. If you withdraw consent, we will cease the corresponding data processing, and some functions may be restricted or unavailable.

3.6 Right to Lodge Complaints

If you are dissatisfied with any of our actions, you may choose to file a complaint with Manos. You also have the right to lodge a complaint with the relevant data protection supervisory authority. If you believe we violated applicable data protection laws of your country in processing your personal data, you have the right to complain to the supervisory authority of the EU Member State where you reside or to the supervisory authority where our main establishment is located.

3.7 Right to Restrict Processing

According to applicable law, in certain situations, you have the right to request that we restrict the processing of your personal information. For example, if you contest the accuracy of personal data and we need time to verify it, you may request restriction of processing during that period.

3.8 Right to Object

You have the right to object at any time, based on your particular situation, to our processing of your personal data on grounds of legitimate interests. Upon exercising your right to object, we will cease processing your personal data unless we demonstrate compelling legitimate grounds that override your interests or the processing is necessary for legal claims. If we process your personal data for direct marketing purposes, you have the right to object at any time, and upon objection, we will immediately stop such processing.

Part Two: Personal Data We Process on Your Behalf as Processor

1. All data you entrust to Manos is referred to as service data, including the following parts:

1.1 You connect the devices you add to the cloud, along with the email addresses, phone numbers, and business data you control. Business data includes your device model, operating system, device MAC address, unique device identifiers (such as IMEI/MEID/IMSI/Android ID/IDFA/IDFV/OAID/UAID, SIM card IMSI, ICCID information, and other device identifiers), Wi-Fi status (such as SSID, BSSID), manufacturer-assigned device strings, login IP address, UniEnergy App version number, network connection method, type and status, network conditions, device accelerometer data (such as gravity sensor) uploaded to the cloud, used to provide you with basic app services.

1.2 According to the serial number of the data collector you control installed under the site and its sub-devices (such as inverters, meters, charging piles, batteries, etc.), the monitoring system collects data uploaded by the data collector and its sub-devices every 5 minutes, including telemetry data such as device serial number, device status, and alarm codes, to provide you monitoring functions.

1.3 Based on the site name, region, capacity, address, GPS location, and other information you provide when creating the site, we provide site management functions, which you can modify at any time. During device networking, the device stores the account and password used for device management, which serve as credentials when you manage the device. Accounts and passwords are stored only on the device, and passwords are stored in an irreversible encrypted form.

1.4 When you make a call within the app, we request phone permissions. The purpose of this permission is only to help you open the dialer and display the phone number so you can make a call within the app. Rest assured, we do not obtain your phone number, call content, or make calls without your consent. If you deny permission, you will not be able to use this feature but it will not affect your normal use of other UniEnergy App features.

1.5 When you navigate within the app, we request location permissions and collect the navigation apps installed on your phone. The purpose is only to help you open the navigation app and pass the site location to it so you can navigate to the site from the app. Denying permission will disable this feature but will not affect other UniEnergy App functions.

1.6 If you use the scan code to identify a data collector, we request camera permission. Denying permission may disable this feature but will not affect other UniEnergy App functions.

2. Information Sharing

To ensure certain independent functions and allow you to use more services and features, we embed third-party SDKs in the app and carefully evaluate the purpose of their use. For more information on the purpose, methods, and scope of SDK processing of personal data, please refer to the "Third-Party Sharing List."

Besides, we strictly follow your instructions for sharing.

As Manos business continues to develop, mergers, splits, or other transactions may occur. If personal information is transferred, we will inform you and continue to protect or require the new processor to protect your personal data.

3. Your Rights

You own and control your service data and have the following rights:

3.1 Right to Issue Instructions

You have the right to instruct us in writing on data processing, including purpose, scope, and methods. We shall execute within a reasonable time.

3.2 Right to Audit and Supervision

You or your designated third party may audit the processor’s data compliance, and we shall provide necessary assistance. You may require us to take necessary measures to ensure data security.

3.3 Right to Data Return and Deletion

Upon contract termination, we must delete or return all personal data according to your choice, unless retention is required by law.

3.4 Control Over Sub-processors

Before engaging subprocessors (e.g., cloud service providers), the processor must obtain your prior written authorization (general or specific consent), and subprocessors shall assume the same obligations as we do.

4. Data Subject Requests

If you believe we store, use, or process your data on behalf of our clients and you wish to access, rectify, erase, restrict, or export your personal data, please contact that client. We will support the client to respond to your request within a reasonable timeframe.

Part Three: General Provisions

1. Data Storage

1.1 Storage Location

To better comply with data protection laws and safeguard personal data, we have established data centers in Europe for data storage. If personal data of individuals in the EU, EEA, or Switzerland are transferred to countries or regions not deemed by the European Commission to provide adequate data protection, we ensure such transfers are protected by the European Commission’s approved standard contractual clauses and (if necessary) other appropriate technical measures.

1.2 Storage Duration

Generally, we retain your personal information for the necessary period to achieve a specific purpose, for example:

• Phone numbers or emails: retained during your use of UniEnergy App services (including numbers or emails used for registration and linked to your account) to ensure normal service usage. These will be deleted when your UniEnergy App account is deleted.

• Site information: retained when you create a site to ensure normal monitoring functionality. Upon your deletion of site information, we will delete corresponding data.
If we cease offering products or services, we will notify you by sending notices, publishing announcements, or other means, and delete or anonymize your personal data within a reasonable timeframe ("anonymization" means irreversible erasure or deletion to ensure the data owner’s identity cannot be identified; anonymized data is not considered personal data).
We will respond and execute your deletion requests within 30 days, not exceeding 60 days.

2. Use of Cookies and Similar Technologies

We only use functional cookies necessary for contract performance, mainly for login authentication and session maintenance. You do not need to separately consent to these cookies, but we commit not to use them for non-essential purposes (such as advertising or behavioral analysis), nor to share them with third parties.

3. Information Security

We are committed to protecting user information from theft, misuse, unauthorized access, or disclosure. We implement security measures at reasonable levels, such as encryption (e.g., SSL/TLS), de-identification, and anonymization to protect your personal data. We continuously improve the security of software installed on devices to prevent personal data leaks. For example, partial encryption of device data ensures transmission security; collecting installed or running apps/processes and data stored on devices to prevent viruses, Trojans, or malicious programs or websites; analyzing unique device identifiers, login IP addresses, operation logs, and location data to prevent illegal activities such as fraud, account theft, and impersonation, and conducting security checks. We have established policies, procedures, and teams to ensure information security. Access to information is strictly limited to authorized personnel subject to confidentiality obligations and audits. In case of data breaches or other information security incidents, we will respond immediately to prevent escalation and further impact, and notify you by sending notices or announcements. We will take all possible technical and organizational measures to protect your information but cannot guarantee elimination of all security risks.

4. Revisions

This policy may be updated, revised, modified, or changed regularly as needed. If any terms are updated, changed, or revised, we will notify you of the revised policy through push notifications, pop-ups, or other means when you log into the UniEnergy App or update the app version.

5. Contact Us

We have established a dedicated personal information protection team and Data Protection Officer (DPO). If you have any questions, complaints, or suggestions about this Privacy Policy or personal data protection, you can contact us by any of the following means:
1. Phone: 0049 1743150766
2. Email: info@manos.ai
3. DPO contact: qing.ren@igen-tech.com

We will review and respond within 30 days of receiving your request or complaint. Subsequent processing typically will not exceed 90 days. If special circumstances occur, we will inform you of the processing time and reasons for delay within 30 days of receiving your request.