EU Data Act

VuPoint (Europe) Company Limited

Trading as ‘Toucan Smart Home’ (herein referred to as ‘Toucan’) 
EU Data Act Compliance Statement (V1.0)

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Background

The EU Data Act ensures that users of a connected product or related service in the European Union can access, in a timely manner, the data generated by the use of that connected product or related service and that those users can use the data, including by sharing them with third parties of their choice. It imposes the obligation on data holders to make data available to users and third parties of the user’s choice in certain circumstances. It also ensures that data holders make data available to data recipients in the European Union under fair, reasonable and non-discriminatory terms and conditions and in a transparent manner. 

 1. Scope of This Statement

This document explains how Toucan Smart Home (herein “Toucan”) products and related services comply with the EU Data Act. It applies to all connected Toucan devices sold or used within the European Union, including:

• Toucan Smart Cameras
• Toucan Smart Doorbells
• Toucan Smart Sensors (motion, temperature, entry)
• Toucan Smart Home App
• Toucan Cloud Services

The EU Data Act applies to all connected products that generate data during use, including smart home devices.

 

2. Types of Data Generated by Toucan Devices

Toucan smart home products generate the following categories of data during normal operation:

(i) Device‑Generated Data (Non‑Personal)

• Sensor readings (motion events, temperature, door open/close)
• Device status (online/offline, battery level, firmware version)
• System logs (error codes, performance metrics)

(ii) User‑Generated or Personal Data

• Video recordings and snapshots
• Audio captured by doorbells or cameras
• User account information
• Device configuration settings

The EU Data Act requires companies to know what data their products produce and how it flows through their systems.  Therefore, the following is a brief summary of the data collected by Toucan and how it deals with it:

Type A — Video Files

• These are auto-removed based on membership level (either 1day, 7 days, or 90 days)

Note: Once the video files have been removed, they are not recoverable.

Type B — User Data (e.g., email address, mobile phone details, passwords, app OS, region, language)

• The cloud keeps the latest data until the user deletes their Toucan account

Type C — Device Data (e.g., device name, Wi-Fi SSID, timezone, SN, status)

• The cloud keeps the latest data until the user unpairs the device.

Type D — Device Operation Data (e.g., number of triggers, Wi-Fi strength, battery level, FW version, daily operation duration)

• The cloud keeps historical daily data and removes it after 180 days.

Under the provisions of the EU Data Act, Toucan is required to amend its agreements and contracts with its customers to reflect the new obligations imposed upon it by the Act, including providing to customers full disclosure of the data collected and processed.   The amended agreements and contracts provide greater detail in respect of the data collected by Toucan, and serve to further underline the rights of customers to the said data.

This Compliance Statement outlines the rights afforded to customers by the EU Data Act.  Toucan is fully committed to respecting those rights and to ensuring that all requests for data are dealt with fully and expeditiously.

 

 3. Your Rights Under the EU Data Act

The EU Data Act confers upon users of connected products extensive rights to access, control and share the data collected about them.  As a user of Toucan Smart Home products in the European Union, you have the right to:

(i) Access All Data Collected and Processed by Toucan

You may request access to all data as listed above and denoted as Type A to Type D inclusive.  This includes both your user data, data generated by your Toucan devices, raw sensor data, logs, and operational metrics.

It should be noted that Toucan may require appropriate user identification to verify a user’s entitlement to access the data.

(ii) Transparency About What Data Is Collected

Upon request you will be informed about:

• what data has been generated about you
• how that data has been used

You will also be provided with guidance and technical help on how you can access your data.

(iii) Receive Data in a Machine‑Readable Format

Toucan will provide your data in the standard CSV format.  Other formats required by the EU Data Act, such as JSON, will be considered for future development.                          

(iv) Share Your Data with Third Parties

You may instruct Toucan to share your device‑generated data with a third‑party service provider of your choice (e.g., home security monitoring, energy management). Toucan will not interfere with or delay this sharing.  In addition, Toucan will ensure:

• The secure transfer of your data
• There will be no unjustified delays
• There will be no contractual barriers to the transfer of your data
• There is no exclusive control over your data

(v) Right to Complain and Receive Redress

The EU Data Act affords users the right to complain to the pertinent authorities should Toucan not fully comply with your requests.

 

4. How to Access Your Data

You can access your Toucan Smart Home data through:

(i) A Formal Request Via the Toucan customer Support Portal

The requested data (Type B, C, D) will be provided by email.

(ii) The App log Via the Toucan Smart Home App

Go to Support/Send App Log to export the app's operation log.

 

5. Data Security and Protection

Under the provisions of the EU Data Act, data holders may apply appropriate technical protection measures to prevent the unlawful disclosure of or access to data. However, those measures should neither discriminate between data recipients, nor hinder access to or the use of data for users or data recipients. 

Accordingly, Toucan maintains strong security measures to protect your data, including:

• end‑to‑end encryption for video and audio
• secure authentication
• encrypted data exports
• strict access controls

 

6. Business‑to‑Government (B2G) Data Requests

In exceptional circumstances—such as emergencies or public‑safety situations—Toucan may be required to provide certain device‑generated data to public authorities, as permitted under the EU Data Act.

Such requests will be:

• limited to what is strictly necessary
• logged and documented
• communicated to the user unless prohibited by law

 

 7. Interoperability and Switching

The EU Data Act stipulates that providers of data processing services should be required to offer all the assistance and support within their capacity, proportionate to their respective obligations, that is required to make the switching process to a service of a different provider of data processing services successful, effective and secure.

As such, if Toucan provides cloud‑based storage or processing for your smart home data, you have the right to:

• export your data
• Terminate your account and all user data will be erased immediately

 

8. Personal Data and the EU General Data Protection Regulations (GDPR)

It should be noted that where personal data is involved an individual’s rights concerning such data granted under the EU General Data Protection Regulations (passed by the European Union on the 25^th May 2018) remain in full force and effect. Those rights granted under the EU GDPR take priority over the rights granted to individuals under the EU Data Act.  Toucan has published its commitment to and compliance with the EU GDPR on its website.  

 

9. Contact Information

For data access, sharing requests, or questions about this statement, please contact:

Toucan Smart Home – EU Data Access Team Via the Toucan Smart Home App or through our website’s customer support portal. Contact us on support:

Contact Us – Toucan Smart Home UK

Or email us: uksupport@toucansolution.com