B2B Privacy Notice

Effective Date: May 22, 2026

Scope of this Notice: This statement supplements the Smart Bay General Privacy Policy. It specifically outlines how Shenzhen Smart Bay Technology Co., Ltd. ("we," "us," or "our") processes the personal data of our business partners, corporate clients, enterprise service users, suppliers, retail distributors, and developers ("Business Contacts").

As a global provider of AI-native hardware and cloud enterprise solutions, we regularly engage in Business-to-Business (B2B) operations. This notice clarifies how we handle the corporate and professional information necessary to maintain these commercial relationships.

1. WHAT B2B DATA DO WE COLLECT?

When you interact with us on behalf of your organization (e.g., purchasing enterprise AI Phones, integrating FlowOS APIs, or supplying hardware components), we may process the following categories of B2B personal data:

Professional Contact Information: First and last name, corporate email address, business phone number, job title, and the name of the organization you represent.
Enterprise Account Data: Usernames, passwords, and security logs associated with enterprise portals (e.g., FlowOS Developer Console or Enterprise Device Management hubs).
Financial & Transactional Records: Corporate billing details, bank account information, tax identification numbers (VAT/TIN), and invoicing records required for corporate procurement and supply chain logistics.
Communication Logs: Records of B2B email correspondence, contract negotiations, customer success tickets, and meeting minutes.

2. WHY DO WE PROCESS YOUR DATA? (PURPOSE & LEGAL BASIS)

We process your professional data under strict corporate governance rules, primarily for the following operational pillars:

A. Contract Fulfillment & Supply Chain Operations

Why are we processing your data? To establish, execute, and terminate commercial contracts. This includes processing purchase orders for AI hardware, managing component deliveries, and handling financial invoicing.

What is the legal basis? Performance of a Contract between your organization and Smart Bay Technology.

B. Business Relationship Management (CRM) & Support

Why are we processing your data? To provide technical support for enterprise software deployments, manage our developer relations ecosystem, and maintain an active database of our suppliers and retail distributors.

What is the legal basis? Our Legitimate Interest in maintaining efficient commercial operations and providing high-quality enterprise support.

C. B2B Direct Marketing & Product Updates

Why are we processing your data? To send you enterprise-focused newsletters, API deprecation warnings, hardware launch invitations, and industry whitepapers. You can opt-out of B2B marketing emails at any time.

What is the legal basis? Legitimate Interest (for existing clients) or your explicit Consent (where required by regional e-privacy laws).

D. Legal and Regulatory Compliance

Why are we processing your data? To fulfill corporate tax reporting, anti-money laundering (AML) checks, export control screenings, and auditing obligations.

What is the legal basis? Compliance with a Legal Obligation.

3. DATA SHARING & THIRD-PARTY RECIPIENTS

To facilitate our global supply chain and enterprise software services, your B2B data may be securely shared with trusted third parties, including:

Enterprise Service Providers: Cloud hosting platforms (e.g., Google Cloud), Customer Relationship Management (CRM) tools, and corporate email systems.
Logistics & Payment Partners: Freight forwarders, customs brokers, and corporate banking institutions required to complete hardware deliveries and process commercial payments.
Legal & Financial Auditors: External auditing firms and governmental tax authorities when mandated by statutory reporting requirements.

4. B2B DATA RETENTION LIFECYCLE

We retain your professional contact details and enterprise account data for as long as your organization maintains an active commercial relationship with Smart Bay Technology. Following the termination of a contract, core financial records, commercial invoices, and signed agreements are retained for the statutory period mandated by local corporate and tax laws (typically ranging from 7 to 10 years) before being securely purged.