Privacy Policy

Effective Date: November 27, 2025

This Privacy Policy describes how Yofine Co., Ltd. (“we,” “us,” or “our”) collects, uses, and protects information when you use our mobile applications (the “App”) and related services (collectively, the “Services”). Our mobile applications are distributed through the Apple App Store and Google Play. By using our Services, you agree to the practices described in this Privacy Policy.

1. Information We Collect

We collect only the personal information necessary to provide core App functionality and to improve your experience.

1.1 Personal Information: We collect your email address for account registration, authentication, and essential service-related communications. Our Services do not require you to provide phone numbers, postal addresses, or payment information.

1.2 Device and Usage Information: When you use our Services, we automatically collect limited non-personal information, including device type, operating system version, App version, App interaction data, and diagnostic information (such as crash logs). We also collect pool configuration parameters provided by you (such as pool size, shape, and pool type). Some diagnostic and usage data may be considered personal data under certain laws (such as device identifiers or IP addresses) when processed by our service providers.

1.3 Network Information: The App accesses network information (Wi-Fi SSID) strictly for the purpose of connecting and configuring your robotic pool cleaner. We do not collect or store Wi-Fi passwords.

2. Bluetooth, Wi-Fi, and Location Permissions

To enable device discovery and control, our App requests specific permissions:

2.1 Bluetooth: Our App requests access to Bluetooth to discover and pair with your robotic cleaner.

2.2 Wi-Fi & Location: On iOS and Android, scanning for nearby Wi-Fi networks and hardware devices requires location permission due to operating system requirements. This permission is used solely to enable device discovery and connectivity and is not used to determine or track your actual geographic location. If you do not grant these permissions, certain device discovery and connectivity features of the App may not function properly.

3. How We Use Your Information

We process your information based on the following legal bases:

· Performance of a Contract: To manage your account and enable device control.

· Legitimate Interests: To improve App stability, troubleshoot crashes, and ensure security. We also use pool configuration data (size, shape, etc.) to analyze cleaning patterns and user needs, which helps us research, develop, and improve the performance and algorithms of our products and services over time. We do not process your personal information for direct marketing, advertising, or automated decision-making purposes.

· Legal Obligation or Consent: Where required by applicable law, or where you have provided consent (such as for system permissions or notifications).

4. Third-Party Services and SDKs

We do not integrate third-party analytics, crash-reporting, or push-notification SDKs (including Firebase) in the App.

We may use infrastructure service providers to host and operate our backend Services (for example, cloud hosting). Those providers process information on our behalf as described in Section 5 and are not permitted to use it for their own advertising purposes.

We do not use third-party SDKs for advertising purposes, and we do not engage in cross-app tracking as defined by Apple’s App Tracking Transparency (ATT) framework.

For Android devices and Google Play distribution, you may review Google’s privacy terms at:

https://policies.google.com/privacy

For iOS devices and App Store distribution, you may review Apple’s privacy terms at:

https://www.apple.com/legal/privacy/

5. Information Sharing, International Transfers, and Legal Disclosure

· No Sale of Data: We do not sell your personal information to third parties.

· Service Providers: We may share information with trusted third-party service providers (such as cloud hosting, analytics, crash reporting, or push notification services) that process information on our behalf and are contractually obligated to protect it. Such service providers are authorized to process personal information only as necessary to perform services on our behalf and in accordance with our instructions.

· International Transfers: As we operate globally, your information may be transferred to and processed in countries outside of your residence (including countries where our service providers are located). We ensure appropriate safeguards (such as Standard Contractual Clauses) are in place to protect your data during such transfers.

· Legal Disclosure: We may disclose information if required by law or in connection with a merger or acquisition, where permitted by law.

6. Your Rights (GDPR, CCPA, and Others)

Depending on your location and applicable data protection laws, you may have the right to access, correct, or request deletion of your personal information, subject to legal requirements.

· Access and Portability: Request a copy of your personal data.

· Rectification: Correct inaccurate information.

· Erasure (Right to be Forgotten): Request deletion of your account and data.

· Right to Object/Restrict: Object to certain processing activities.

To exercise these rights, use the Delete Account feature in the App or contact us at info@yofinerobot.com. We will respond to your request within a reasonable timeframe (typically 30 days).

7. Additional Notice for California Residents (CCPA/CPRA)

We have not “sold” or “shared” (for cross-contextual advertising) personal information in the preceding 12 months.

We do not use or disclose “Sensitive Personal Information” for purposes other than providing the Services. California residents may exercise their rights directly or through an authorized agent. We will not discriminate against you for exercising any of your privacy rights.

8. Children’s Privacy

Our Services are not intended for children under 16 (or the minimum age required by applicable law). We do not knowingly collect personal information from children. If we discover such data has been collected, we will delete it immediately.

9. Data Security

We implement reasonable and appropriate technical and organizational measures, including encryption where appropriate, to protect information against unauthorized access, disclosure, alteration, or destruction. However, no method of electronic transmission or storage is completely secure, and absolute security cannot be guaranteed.

We retain your personal information only as long as your account is active or as needed to provide the Services. Upon account deletion, we delete or anonymize your data unless retention is required by law.

10. Data Act Product Data Disclosure (Connected Products)

This Section provides the information required under Article 3 of Regulation (EU) 2023/2854 (the "Data Act"). It supplements, and does not replace, the personal-data terms set out elsewhere in this Policy.

Data Holder: Yofine Co., Ltd. Contact: info@yofinerobot.com

This Section applies to our robotic pool cleaners that connect to the UBoter mobile application (regardless of the brand or model name under which the product is sold or rebranded) and to the AquaLink Wi-Fi accessory (collectively referred to as "Connected Products").

What data we generate: Product data consists of the following categories, transmitted over Bluetooth Low Energy (BLE) and displayed in the App, including battery level, operating mode status, command results and fault or error codes reported by Connected Products.

The data volume per transmission is small, and data is generated on demand only when the App is connected to the Connected Product, rather than being transmitted continuously or in real time. Your Connected Product is identified by its model number, serial number and firmware version. Connected Products do not connect to the internet or transmit product data on their own; data is only transmitted when the App is actively connected to the Connected Product.

We also collect pool configuration parameters you provide (pool size, shape, and pool type). This information is provided by you, rather than generated by Connected Products, and is used together with product data to operate and improve our Connected Products.

Where data is stored, and for how long: Product data may be stored on the Connected Product, within the App, and on our servers (for example, the pairing information between your account and your Connected Product, and the pool configuration parameters you choose to save). Data held on our servers is retained for as long as your account remains active and is deleted or anonymised upon account deletion, as described in Section 9. Uninstalling the App removes data cached locally on your mobile device but does not delete data held on our servers; server-side data is only deleted as described above.

How you can access it: You may view current status data in the App at any time. To request a copy of the readily available product data we hold, email info@yofinerobot.com with your account details and the Connected Product's model and serial number. We will provide this data in a commonly used, machine-readable format (JSON or CSV), free of charge, and aim to respond within 30 days. We do not store Wi-Fi network names and passwords.

How we use it, and who else sees it: We process product data to provide device pairing and control, diagnose faults, deliver firmware and software updates, provide customer support, and improve our products and services. We do not use product data for advertising, profiling, or automated decision-making. Product data is hosted by Amazon Web Services, Inc. ("AWS") in the United States; cross-border transfer safeguards are as described in Section 5. AWS acts as our data processor and does not use product data for its own purposes. We do not sell product data and do not otherwise make it available to third parties, except at your request as described below.

Your rights, and complaints: You may request that we share your readily available product data with a third party you designate, or withdraw such a request at any time, by contacting info@yofinerobot.com. You may also lodge a complaint with the competent authority in your EU Member State. Our processing of product data under this Section continues for as long as you maintain an active account or use the App.

11. Cookies and Similar Technologies

Our website may use cookies or similar technologies to ensure basic functionality and improve user experience. Our mobile App does not use cookies for advertising or tracking purposes.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When updates are made, the effective date will be revised and the updated policy will be made available through our Services. Continued use of the Services after changes take effect constitutes acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

info@yofinerobot.com.