Data Act Compliance Statement

Updated: August 10, 2026

1. Purpose of this Statement

The EU Data Act (Regulation (EU) 2023/2854, the “Data Act”) has applied since 12 September 2025. Under Article 3 of the Data Act, providers of connected products and related services must, before concluding a contract, provide users with clear and comprehensible information on how product data is generated, accessed, shared and used.

We publish this Statement to provide EU users of our connected products and accompanying software services with this statutory information in one place, and to explain the rights users enjoy under the Data Act — including access, sharing, porting and erasure of data — and how to exercise them.

2. Identity of the Data Holder and Contact Details

The legal entities that conclude product sale or service contracts with users in the EU and act as data holders are:

• Hoymiles MyEnergy GmbH (EU contracting and service entity)
  
• Hangzhou Hoymiles Power Electronics Co., Ltd. (product manufacturer)

Users may contact us quickly and effectively on any data-related matter via:

• Email: service@hoymiles.com
• Contact page and hotline: https://shop.hoymiles.com/pages/contact
  

3. Products and Related Services in Scope

This Statement applies to the following connected products marketed in the EU and their accompanying software services:

4. Types, Generation and Volume of Product Data

4.1 Data generated by the product (device)

• Micro storage systems: port data (PV port, battery port, grid port, off-grid port, etc.), battery data (battery temperature, charge/discharge status, battery power, etc.), and network data (connection status, signal quality, etc.).
  
• Microinverters: port data (PV port, grid port, etc.) and network data (connection status, signal quality, etc.).
  

This data is generated in ProtoBuf format at a volume of approximately 15 KB per operating hour. While the device maintains a normal connection to the server, data is reported to the cloud every 5 minutes.

4.2 Data collected and generated by the related service (App and cloud)

• Device data collected by the App: device serial number (SN) and device status data (power, voltage, current, energy, temperature, etc.).
  
• Data generated by the App and cloud service themselves: usage data such as account information, login logs and in-app interaction records.

5. Data Storage Location and Retention

• On-device: data is stored in the device’s built-in Nor-Flash memory and is overwritten cyclically when full; performing a factory reset erases the on-device data.
  
• Cloud: data is stored on servers located in Frankfurt, Germany, and is retained until the user deletes their account.
  

6. How Users Can Access the Data

Users can access product and related-service data free of charge and in a straightforward manner through the following channels:

• Directly via the device display, with no preconditions or restrictions.
  
• Locally via Bluetooth through the S-Miles Home App, with no preconditions or restrictions.
  
• Via the S-Miles Home App for current status and historical statistics held in the cloud; this channel requires the user to register an account and bind the device SN to create a plant.
  

7. Data Export and Portability

Users can download and export historical archive data through the S-Miles Home App. Exported files are provided in CSV, a commonly used and machine-readable format, allowing users to store, analyse or migrate the data to other services.

8. Sharing Data with Third Parties

Under Article 5 of the Data Act, users have the right to request that we make their accessible product data available to a third party of their choice. This is implemented as follows:

• For products supporting this feature (such as the micro storage systems), users can configure an MQTT server in the S-Miles Home App to stream device data in real time to a third-party platform of their choice.
  
• Users may also submit a data-sharing request through the contact channels listed in Section 2, and we will cooperate in accordance with the law.
  We do not share users’ product data with any third party for commercial or advertising purposes.
  

9. Data Erasure

• Cloud data: deleted upon deletion of the user’s account.
  
• On-device data: erased when the user performs a factory reset of the device.
  

10. Purposes of Data Use

Beyond providing the product’s core functions and the accompanying services, we use the data described above solely for warranty assessment. We do not use the data for any other purpose not disclosed to users.

11. Trade Secrets

The accessible data made available to users as described above does not contain trade secrets of our company or of our suppliers.

12. Contract and Service Term

The software service accompanying the product is a basic service provided free of charge for the life of the product. There is no paid subscription and no automatic renewal. Users may stop using the service at any time, for example by deleting their account or unbinding the device. The handling of data after termination is described in Sections 5 and 9.

13. User Rights and Dispute Resolution

If users believe their rights under the Data Act have been affected, they may first contact us through the channels listed in Section 2, and we will respond promptly. Users also have the right to lodge a complaint with the competent authority of their Member State, or to seek redress before a certified dispute settlement body in accordance with Article 10 of the Data Act.

14. Updates to this Statement

We will update this Statement from time to time in line with legal and regulatory developments and product changes. Updated versions will be published on our official website together with their effective date. This Statement shall be interpreted in accordance with the EU law in force at the relevant time.