MAGIC EAGLE Privacy Notice

 Effective Date: August 1, 2025

This Privacy Notice (the "Notice")  is issued byHOTSALES GLOBAL TRADE LLC  and its affiliates (together, “MAGIC EAGLE”, “we”, “us” and “our”) and is addressed to users of MAGIC EAGLE Intelligent Management Platform (“you”).

The Notice  applies to all products and/or services provided by the MAGIC EAGLE Platform, including the MAGIC EAGLE App (mobile client) and the MAGIC EAGLE Wechat mini program (collectively, the "Services"). When you use our Services, we collect and process information about you, so please read this Notice carefully and make sure you understand our rules for the collection and processing of your personal data (including how we collect, use, store and share such information), and how we provide you with access to, update, delete and protect this information.

We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on via email or in-app message/notice prior to the change becoming effective. All changes shall be effective from the date of publication unless otherwise provided. We encourage you to periodically review this page for the latest information on our privacy practices.

If you are a minor under the age of 18, please obtain the consent of your parent or legal guardian before using our products or services in accordance with relevant laws and regulations. In addition, if you are a child under the age of 14, please be sure to read the MAGIC EAGLE Children's Privacy Protection Statement and ensure that you are clear with your guardian or parent about the relevant child privacy protection information.

This Notice mainly explains to you:

1. Definitions
2. Collection of Personal Data
3. Purpose of processing and legal basis for processing
4. Disclosure of Personal Data
5. International transfer of personsal data
6. Your privacy rights
7. Data security measures
8. Data retention
9. Direct Marketing
10. Children's Privacy Protection Statement
11. Contact us

1.Definitions

1、Personal data: Information recorded electronically or otherwise that can be used alone or in combination with other information to identify an individual or to reflect the activities of a particular individual.

2、Sensitive personal data: including personal biometric information, communication records and content, health information, transaction information, precise location information, etc. When we provide you with specific products or services, involving the collection of sensitive personal data, we will collect sensitive personal data about you through a prominent and explicit notice to obtain your consent.

3、Smart device: refers to the hardware produced by the manufacturer that has a human-machine interface and can transmit information through a wireless network non-standard computing equipment, including smart household appliances, smart cameras, smart photo frame equipment, etc.

4、Applications: Mobile applications developed by MAGIC EAGLE that enable end users to remotely control smart devices and connect to the MAGIC EAGLE Internet of Things (IoT) platform.

2.Collection of Personal Data

To provide our Services, we collect personal data as follows. Without this information, we may be unable to provide the requested products or services.

A. Data You Voluntarily Provide

1、Account Registration: When creating an account, we collect your username, email address, and login credentials. Optional profile details (e.g., nickname, language preference) may be added later.

Third-Party Login: If you use a third-party account (e.g., social media), we receive shared information (e.g., profile picture, nickname) as permitted by the third party’s privacy settings.

2、   User Feedback: Submitting feedback or service requests may include your contact information (email/phone), feedback content, and optional media (photos/videos) to resolve issues.

B. Optional Permissions for Enhanced Features

You may enable the following permissions to access additional services. Disabling them does not affect basic functionality:

C. Automatically Collected Information

Device & Usage Data: To ensure service security and performance, we automatically collect:

1、    Mobile device details (model, OS version, app version, IP address, network information).

2、    Usage logs (e.g., app interactions, feature usage, error reports).

3、Installed app list (to monitor compatibility and performance).

Note: This data is anonymized unless combined with personal identifiers (e.g., your account), in which case it will be treated as personal data under applicable laws.

D. Smart Device Information

1、Basic Device Data: When connecting smart devices (e.g., cameras, doorbells), we collect device ID, online status, firmware version, and connection details (e.g., MAC address, Wi-Fi SSID).

2、Camera & Surveillance Data(if applicable):

• Motion-triggered snapshots are temporarily stored locally or in the cloud (if you purchase cloud storage) for your review.
• Cloud-stored videos are retained per your subscription terms and deleted immediately upon your request.
• Disabling motion detection stops automatic recording but may limit security alerts.

Managing Permissions: You can adjust permissions anytime via your device settings or MAGIC EAGLE’s in-app privacy menu (My → Settings → Privacy Settings). Disabling a permission revokes future data collection for that feature but does not delete previously collected data.

This revision prioritizes readability with clear headings, bullet points, and a permission table, while aligning with GDPR/CCPA requirements (e.g., explicit consent for optional data, transparent permission controls, and data retention limits).

3. Purpose of Processing and Legal Basis for Processing

We process your personal data for the following purposes, each based on a specific legal ground as required by applicable data protection laws:

4. Disclosure of Personal Data

MAGIC EAGLE only shares your personal data in transparent, lawful ways. We may disclose your information to the following parties:

A. Service Providers

We share data with third-party service providers who assist us in operating our business, such as website hosting, data analytics, payment processing, IT support, and customer service. These providers are contractually obligated to protect your data and use it solely to fulfill services for MAGIC EAGLE.

B. Business Partners & Device Providers

We may share data with customers or business partners who supply the smart devices, networks, or systems you use to access our services.

C. Business Transitions

In the event of a reorganization, merger, acquisition, or sale of assets (including bankruptcy proceedings), your data may be transferred to the new entity. You will receive prior notice via email or our website regarding changes to data ownership or processing practices, with options to object if legally required.

D. Legal & Safety Requirements

We may disclose data when necessary to:

•   Comply with laws, regulations, legal processes, or government requests;
•   Enforce our Terms of Use, policies, or agreements (e.g., investigating violations);
•   Protect our operations, systems, or business interests;
•   Safeguard the rights, privacy, safety, or property of MAGIC EAGLE, users (including you), or third parties;
•   Prevent or address fraud, illegal activities, or security threats;
•   Share with MAGIC EAGLE subsidiaries or affiliates for legitimate business purposes.

E. Your Consent

Except as outlined above, we will only share your data with other third parties if you explicitly consent.

Third-Party Services & SDKs

•   Third-Party Services: When you use third-party services via our platform, we share data only after confirming the third party has obtained your authorization, as required by law. Details on third-party data practices are available in ourThird Party Information Sharing and SDK Service List.
•   Embedded SDKs: Our apps may contain third-party SDKs to ensure functionality (e.g., crash reporting, user authentication). SDK providers may update their data processing practices; refer to their official privacy notices for the latest information.

5. International Transfer of Personsal Data

MAGIC EAGLE operates globally, so the personal data we collect in accordance with this Notice may be transferred, stored and processed in different countries or regions. The laws and regulations applicable in the country where we operate may differ from those applicable in your country of residence, but we will strictly comply with the laws, regulations and requirements related to the protection of personal data (see MAGIC EAGLE Global Data Centers and Storage). Therefore, under the framework of personal data protection, in order to facilitate our operations, we may transfer personal data to the countries or regions where we do business. Regardless of where your information is stored, our privacy and security practices are designed to provide global protection for your personal data.

In the event of a transfer by MAGIC EAGLE, we ensure that international transfers of your Personal Data are made pursuant to appropriate safeguards, such as:

(i) Ensuring that the Personal Data is only transferred to countries recognized as Adequate Jurisdictions. The current adequacy decisions can be found here. There is currently no adequacy decision for China; and there is only a partial adequacy decision for the U.S., where only such companies that are registered under the Data Privacy Framework are covered by an adequacy decision or

(ii) the transfer is made pursuant to appropriate safeguards, such as Standard Contractual Clauses adopted by the European Commission or UK Secretary of State (as applicable) in connection with appropriate supplementary measures. The decision and the template text of these Standard Contractual Clauses can be found here;

If you would like to know more about our security measures, you can contact us directly through this Notice.

6.Your Privacy Rights

We respect your rights and keep your personal data.

If you decide to send us a request by email, please indicate what information you would like to change, whether you would like your personal data to be removed from our database, or what restrictions you would like us to have on using your personal data. Please note that for security reasons, we will ask you to verify your identity before further processing your request.

You may exercise your rights in relation to your personal data through the following specified paths:

1、Access to personal data: If you request access to the personal data we process about you (that is, apply to us for a copy of your personal data), you can obtain information through the application of [My] - [Settings] - [Privacy Notice management] - [personal data Export];

Right to amend personal data: If you ask us to correct inaccurate or incomplete personal data about you, you can amend the information in the following two ways:

1) Modify "Registered Account" (email) : [My] - [Settings] - [Account and Security] - [Modify account];

2) Modify "Nickname and/or time zone" : [My] - [Profile];

2、Right to delete personal data: If you request to delete your personal data, you can go to the upper right corner of [My] - [Settings] - [personal data] - [Logout account], according to the prompt, you can cancel your account and further delete your personal data;

Right to, on legitimate grounds, restrict Processing of personal data: To request temporary or permanent restrictions on our processing of some or all of your personal data, please delete your account or [My] - [Settings] - [Account & Security] in the app to us, or submit your request at support@magiceagle.com;

3、Right to revoke the processing of personal data: When we use your personal data based on your consent or our legitimate interests, choose to object or refuse our use of your personal data, please refer to the following "Withdrawal of consent" processing method to cancel your consent to processing:

1) As mentioned above, you can change the permission Settings obtained in the device system Settings through the application's [My] - [Settings] - [Privacy Permission Settings] and revoke your consent, including location, camera/camera, album (photo library/video library), microphone, Bluetooth Settings, message notification push and other related functions;

2) In non-marketing communications that you agree to, turn off your selection by going to My - Message Center - Settings;

3) When the data you agree to is used to analyze the function optimization service related to you, turn off your selection through [My] - [Settings] - [Privacy Settings] - [Feature Experience upgrade Plan];

4) In the personalized push service you agree to, [My] - [Settings] - [Privacy Settings] - [Personalized Push Service] turn off your selection;

5) Unbind the smart device through the application, and the information about your use of the smart device will not be collected;

6) If you have previously voluntarily agreed to associate your MAGIC EAGLE account with a third party service, such as a third party health platform, please unbind it on that third party platform.

4、When you withdraw your consent or authorization, we are unable to continue to provide you with the services corresponding to the withdrawal of authorization. However, your withdrawal of consent or authorization does not affect the withdrawal of previous processing of personal data based on your consent.

Under the GDPR, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

This does not affect your statutory rights.

If you still have more questions, please go to My - FAQs & Feedback in our app, or email us at support@magiceagle.com

7.Data Security Measures

We use commercially reasonable physical, administrative and technical safeguards to maintain the integrity and security of your personal data. MAGIC EAGLE provides a variety of security policies to effectively ensure the information security of users and devices.

For device access, we use MAGIC EAGLE proprietary algorithms to ensure data isolation, access authentication, and authorization applications.

In terms of data communication, it supports communication using secure algorithms and transmission encryption protocols as well as commercial grade information encrypted transmission based on dynamic keys.

In terms of data processing, strict data filtering and verification as well as a complete data review process are used.

In terms of data storage, all confidential information of the user will be securely encrypted for storage.

In addition to the above technical security guarantees, MAGIC EAGLE has also formulated a series of security guarantees at the system and control level, including job assignment and responsibility, security and privacy protection training courses, strengthening employees' awareness of data protection, control of access rights and other measures to prevent data loss, illegal use, unauthorized access or leakage, tampering or damage.

If for any reason you believe that your interaction with us is no longer secure (for example, you believe that the security of your MAGIC EAGLE account has been compromised), please let us know immediately by sending an email to（ support@magiceagle.com ）as described below.

In the event of a security incident affecting the security of your personal data, we will notify you at the first time through your reserved email address, telephone number, message center push and other means, and inform you of relevant risk reduction or prevention suggestions and other information. When necessary, we will take corresponding remedial measures in a timely manner in accordance with the internal security incident emergency plan, and report to the relevant competent authorities in accordance with regulations.

8.Data retention

We will process your personal data for the shortest period necessary to achieve the purposes stated in our Notice or as required by laws and regulations, unless it is necessary to retain it for a longer period in accordance with specific legal requirements. We will determine the appropriate retention period based on the quantity, nature and sensitivity of the personal data, and we will destroy your personal data at the end of the retention period.

1) Products and services to meet your request in accordance with the User Agreement and this Notice;

2) When you explicitly request the deletion of your personal data, we will set this as a task and no longer retain your personal data.

When we confirm on the basis of 1) that the personal data has completed the purpose of collection and processing, or after we confirm your deletion or deregistration application in accordance with 2), or we terminate the operation of the corresponding product or service, we will stop retaining and delete your personal data. In general, we will no longer retain your personal data once the specified retention period has been reached. If we are unable to destroy the information for technical reasons and as a result the personal data is retained beyond the storage period, we will take appropriate measures to prevent further use of your personal data, including anonymization.

9.Direct Marketing

We Process Personal Data to contact you via email, telephone, direct mail, or other communication formats to provide you with information regarding Services that may be of interest to you. If we provide Services to you, we may send or display information to you regarding our Services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law. Please note that we may track your opening and clicking behavior.

We may invite you to participate in surveys, product research, and beta testing activities. Where required by applicable law, we will obtain your prior opt-in consent before sending such invitations.

You may unsubscribe from specific promotional email campaigns at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. After you unsubscribe, we will not send you further promotional emails in connection with the email campaigns you have unsubscribed from, but in some circumstances we will continue to contact you to the extent necessary for the purposes of providing any Services you have requested or in connection with any email campaigns to which you remain subscribed.

You may unsubscribe from specific promotional text campaigns at any time by replying STOP via text message to any of the promotional text communications we send in relation to the specific campaign you would like to opt out from. After you unsubscribe, we will not send you further promotional text messages in connection with the text campaigns you have unsubscribed from, but in some circumstances, we will continue to contact you to the extent necessary for the purposes of providing any Services you have requested or in connection with any text campaigns to which you remain subscribed.

10.Children's Privacy Protection Statement

MAGIC EAGLE takes the protection of children's personal data very seriously. If you are under the age of 14 (or the required age in your country), you must read the MAGIC EAGLE Children's Privacy Protection Statement carefully and obtain the prior written consent of your parent or legal guardian before using our services. MAGIC EAGLE protects children's personal data in accordance with the relevant regional, national or regional laws and regulations. Please note that if we become aware that a child's personal data has been collected without the prior consent of a verifiable parent or legal guardian, we will try to delete the personal data as soon as possible.

11. Contact us

If you have any comments or questions about this Privacy Notice, or if you have any questions about our collection, use, or disclosure of your personal data, please contact us via:

The "My Account" > "FAQs & Feedback" section in the MAGIC EAGLE app, with the subject line "Privacy Notice Inquiry"; or

The contact details below..

We have a professional privacy and security team to solve your personal data related rights requests and questions. If your question itself involves a more significant matter, we may ask you to provide additional information to confirm the nature and impact of the matter. If you are not satisfied with the response you receive, you can refer your complaint to the appropriate regulatory authority.

When you consult us, we will provide you with information on the relevant complaint channels that may be used according to your actual situation, and will complete the verification and processing of your needs within 7 working days.

Contact information:

E-mail: support@magiceagle.com

Contact number:Tel: +1 888-991-1009 (9:00 AM – 5:00 PM EST, Mon-Fri)