Acceleronix Developer Center Data Act Transparency Disclosure
Update Date: September, 11, 2026
Effective Date: September, 11, 2026
1.1 This Disclosure is issued by Acceleronix B.V. (registered address: Haaksbergweg 75, 1101 BR Amsterdam, Netherlands, "we", "us") pursuant to Regulation (EU) 2023/2854 (the "Data Act"). It is addressed to manufacturers, brand owners and other enterprise users ("you") who access or otherwise use our IoT technical services through Acceleronix Developer Center or through other means authorised by us (collectively, the "Platform"), and describes our role under the Data Act, our data processing arrangements, and the capabilities we provide to support your compliance with the Data Act.
1.2 This Disclosure supplements the Acceleronix Developer Center Service Agreement between you and us (the "Services Agreement"). In the event of any inconsistency, the Services Agreement prevails, provided that nothing in the Services Agreement may derogate from the mandatory rights conferred on you by the Data Act.
2.1 In respect of the product data and related service data (the "Device Data") generated by connected products onboarded through the Platform (the "Devices"), you are the data holder, and we act as a technical service provider processing Device Data on your behalf and in accordance with your instructions. We do not acquire the status of data holder of Device Data by virtue of providing the Platform services.
2.2 In respect of the cloud-based data processing and storage services provided through the Platform, we are a provider of data processing services within the meaning of the Data Act, and Sections 5 and 6 of this Disclosure apply.
3.1 We process Device Data within the scope of the Platform services, and such processing is limited to: device connectivity and command transmission; data ingestion and storage; status synchronization; data analytics and operational functions as configured by you; and processing necessary for security purposes. Except as necessary to provide the services to you, we do not use Device Data for our own purposes and do not make Device Data available to any third party, unless mandatorily required by law (in which case the procedure under Section 6 applies).
3.2 Device Data is stored in a data centre located in the EU.
3.3 The complete contractual arrangements (including purpose limitation, confidentiality, security measures and audit) are set out in the Services Agreement and its Appendix 2 to the Data Processing Addendum (the “Data Act Data Governance Addendum”).
4.1 User information support: We provide technical capabilities enabling you to display to end users, on the device pages of WonderFreeAPP or within your branded app, the information you provide pursuant to Article 3(3) of the Data Act.
4.2 Data access and portability support: The Platform supports the export of Device Data in a structured, commonly used and machine-readable format, and provides APIs, console-based export functions and technical documentation to enable you to respond to end users' requests for access to, retrieval of, and making available to third parties of Device Data. The relevant metadata (such as timestamps and data field descriptions) is provided together with the data.
4.3 Erasure support: You may erase the Device Data of a specified Device or user via Device Management - Device Maintenance - Delete; erasure is completed across all storage layers of the Platform within 7days, and the deletion cycle for backup data is 7 days.
4.4 The detailed specifications, response times and service levels of the above capabilities are set out in technical documentation .
5.1 In accordance with Chapter VI of the Data Act, you have the right to switch to another provider of data processing services or to your own ICT infrastructure. The switching terms are set out in the Data Act Data Governance Addendum, including a transitional period of no more than 30 days, a maximum notice period of 60 days, and the scope of exportable data. Where the migration cannot reasonably be completed within such period due to technical complexity or scale, the parties may agree on a reasonable extended transitional period.
5.2 Upon switching, we support the export of Switching Data (including Device Data and the configuration data you have created on the Platform) through the Developer Console via Device Management - Device Maintenance - View - Business Logs - Export. We do not impose unjustified technical, contractual or commercial obstacles to switching.
5.3 Switching charges: from 12 January 2027, we will not impose any switching charges; until that date, any charges, if applied, are limited to reduced charges within the costs permitted by the Data Act, as set out in Data Act Data Governance Addendum.
5.4 Information on functional equivalence and interoperability (including the open interfaces and standards we adopt) is available at technical documentation.
6.1 We take reasonable technical, organisational and legal measures to prevent international transfer of, or governmental access to, non-personal data held on the Platform where such transfer or access would create a conflict with Union law or the law of a Member State.
6.2 Where we receive a judgment or decision of a court or administrative authority of a third country requiring the transfer of, or access to, non-personal data held on the Platform, we will comply only where the conditions of Article 32 of the Data Act are met (including where based on an international agreement, or following a review confirming that the proportionality and minimisation requirements of that Article are satisfied), and, to the extent permitted by law, we will notify you before complying.
Acceleronix B.V.
Address: Haaksbergweg 75, 1101 BR Amsterdam, Netherlands
Email: Dpo@acceleronix.io
We may update this Disclosure as required by law or due to changes in our services. The updated Disclosure will be published on the Platform with its effective date indicated; material changes affecting your compliance arrangements will be notified to you 30 days in advance via console notification and email.
