Effective Date: May 21, 2026
Supplement Notice: This statement supplements the Smart Bay General Privacy Policy. It applies specifically to the processing of device-level data and hardware telemetry carried out by Shenzhen Smart Bay Technology Co., Ltd. ("we" or "us") in relation to AI Phones, tablets, and devices operating on FlowOS.
When you power on your Smart Bay device for the first time, we process your device activation and basic network data to measure your hardware warranty, provide you with localized customer service, and prevent hardware fraud. We also process this data to notify you about critical OS patches and deliver Firmware Over-The-Air (FOTA) updates to keep FlowOS secure.
We strictly categorize our hardware data processing into the following operational pillars:
Why are we processing your data? We need to accurately measure your device's active warranty lifecycle and provide you with related hardware support services.
What data are we processing? Device activation data: Phone identification number (IMEI), international mobile subscriber identity (IMSI), IP address, MAC address, and specific FlowOS system build versions.
What is the legal basis? Performance of a Contract between us.
Why are we processing your data? We identify and prevent device cloning, unauthorized flashing, and other hardware misuses, while protecting the ecosystem against fraudulent warranty claims.
What data are we processing? Device activation data: Phone identification number (IMEI) and hardware serial numbers (SN).
What is the legal basis? Our Legitimate Interest in protecting our business and users from fraudulent operations.
Why are we processing your data? To inform you about critical FlowOS updates, push security patches, and ensure your device maintains optimal system stability.
What data are we processing? Software update data: Phone identification number (IMEI), IP address, current FlowOS version, and network carrier identifiers.
What is the legal basis? Performance of a Contract between us.
Why are we processing your data? To establish correct time zones, comply with localized wireless frequency regulations, and provide foundational positioning for system applications.
What data are we processing? Satellite (GPS), mobile cell-tower, Wi-Fi, or other network-based location metrics.
What is the legal basis? Your Consent. You can withdraw this consent and disable system-level positioning at any time within your FlowOS settings menu.
We maintain strict retention boundaries to minimize data footprint while securing our hardware ecosystem:
To deliver FlowOS functionality globally, device activation and update data may be processed via trusted third-party infrastructure. Data is stored principally within highly secure cloud platforms (such as Google Cloud Infrastructure) located in your operating region (e.g., the EU/EEA, United States, or local servers within China for domestic devices).
Firmware Over-The-Air (FOTA) Services: Your device’s IP address and OS version will securely handshake with our designated FOTA delivery servers to download system images. All structural transfers outside the EU/EEA are fully compliant with the European Commission's Standard Contractual Clauses (SCCs) to ensure sovereign-level data protection.