EU Data Act
myFirst EU Data Act
Transparency Statement
Data handling overview for myFirst connected products and services, in accordance with Regulation (EU) 2023/2854.
1
Hardware Products (Connected Devices)
| Data Collected | Location (configurable or on demand), steps and activity metrics, device status (battery, connectivity), messages/calls metadata (not content), guardian contact information, device identifiers (IP address, device ID), profile display info (nickname, avatar), height/weight (for step calculation). |
| Format | Structured digital format (JSON via APIs). Encrypted in transit and at rest. |
| Estimated Volume | Approximately 1–5 MB per device per day depending on usage and update frequency. |
| Real-Time Capability | Devices support near real-time location updates when enabled by the parent/guardian. |
| Storage Location | Primary storage and processing occurs on secure cloud infrastructure hosted in secure remote servers. |
| International Transfers | Data transfers outside the European Economic Area are conducted under: Standard Contractual Clauses (SCCs), AWS Data Processing Addendum, and technical and organizational safeguards. |
| Retention | Location data retained in accordance with parental settings and legal requirements. Account data retained while account is active. Deleted or anonymized upon verified parental deletion request, unless required for legal compliance. |
| Access & Portability | Parents/guardians can: view data in the Circle App, request deletion, and request export in machine-readable format. |
2
Circle App (Guardian Application)
| Service Data Collected | User ID, encrypted credentials, contact numbers, profile settings, subscription data (if applicable). |
| Storage | Storage and processing occurs on secure cloud infrastructure hosted in secure remote servers. |
| Use of Data | Service delivery, safety features, performance improvement, and legal compliance. |
| Real-Time Capability | The Circle App reflects near real-time location updates when enabled by the parent/guardian on the connected device. |
| Storage Location | Primary storage and processing occurs on secure cloud infrastructure hosted in secure remote servers. |
| International Transfers | Data transfers outside the European Economic Area are conducted under: Standard Contractual Clauses (SCCs), AWS Data Processing Addendum, and technical and organizational safeguards. |
| Retention | Account data retained while account is active. Deleted or anonymized upon verified parental deletion request, unless required for legal compliance. |
| Access & Portability | Parents/guardians can: view data in the Circle App, request deletion, and request export in machine-readable format. |
3
Data Holder
| Company | myFirst Tech Holdings Pte Ltd |
| Contact Email | support@myfirst.tech |
4
Data Processors
| Data Processing Parties | Amazon Web Services (cloud hosting), customer support providers, payment processors (if applicable). |
| Data Protection | All processors are contractually bound by data protection agreements. |
5
Third-Party Sharing
| Data Sold | No. Data is not sold. |
| Sharing with Third Parties | Data sharing occurs only with verified parental authorization, with service providers under contract, or when legally required. |
6
Trade Secrets
| Trade Secrets | No proprietary trade secrets are included in user-accessible data. |
7
Complaints
| Complaints | Users in the European Union may lodge complaints with their local supervisory authority under the EU Data Act and GDPR. |
| Contact | support@myfirst.tech |
© 2025 myFirst Tech Holdings Pte Ltd. All rights reserved.
This statement is provided in accordance with Regulation (EU) 2023/2854 (EU Data Act).