EU Data Act Disclosures

Effective Date: November 2025

NETGEAR Inc. and its affiliates, (collectively “NETGEAR”) pursuant to Regulation (EU) 2023/2854 (“Data Act”), Article 3(2) and 3(3), hereby makes the following information available to potential purchasers and/or licensees of NETGEAR’s products and services:

NETGEAR Connected Products

I. NETGEAR routers and modems (“Connected Products”) generate certain data about your use of the Connected Product (“Product Data”). NETGEAR collects Product Data as set forth below for the purposes of detecting and addressing potential security threats, performance issues, opportunities to improve our products and services, and optimize the consumer experience.

II. Users can access, retrieve and/or erase the Product Data, collected by NETGEAR from its Connected Products by using our online tool at https://preferences.netgear.com.

III. We may share Product Data with third-party service providers to fulfill the purpose set forth above.

IV. All Product Data is retained for as long as NETGEAR needs it to achieve the purposes illustrated above, in accordance with applicable terms of use, to comply with legal obligations or to protect NETGEAR’s or other's interests. The Terms and Conditions governing users access, retrieval, erasure, and use of Product Data are set forth on NETGEAR’s website here: https://www.netgear.com/about/terms-and-conditions-product-data/.

Product Data:

Router Analytics
Data format: JSON. Estimated Volume: The exact volume of Product Data generated depends on the amount of use of the Connected Product as well as the number of events triggering an upload of Product Data, such as performance issues or potential security threats detected. On average, NETGEAR Connected Products send 1.5 megabytes of Product Data to NETGEAR per month.
Location of Storage: On-device until uploaded to servers controlled by NETGEAR located in the EU and then transferred to servers controlled by NETGEAR in the US. After data is uploaded from the Connected Product it is deleted from the Connected Product.
Data Type	Data Generation Frequency
Router attributes (e.g., serial number, model name, firmware version).	Daily or event based
Router configuration (e.g., feature and setting configurations).	Daily
Router Health (telemetry) (e.g., CPU, memory, mesh backhaul setup).	Daily or event based
Router Wifi Performance (e.g., channel used, signal strength, number of connected devices).	Daily or event based
Router Connected Device Health (e.g., type of connected devices, OS and OS version, signal strength).	Daily
NETGEAR Device Management and Remote Access Services
Data format: JSON. Estimated Volume: The exact volume of Product Data generated depends on the amount of use of the Connected Product as well as the number of events triggering an upload of Product Data, such as performance issues or potential security threats detected. On average, NETGEAR Connected Products send 1.5 megabytes of Product Data to NETGEAR per month. Location of Storage: On-device until uploaded to servers controlled by NETGEAR located in the EU and then transferred to servers controlled by NETGEAR in the US. After data is uploaded from the Connected Product it is deleted from the Connected Product.
Data Type	Data Generation Frequency
Device and User Registration Data (via NETGEAR Device Management Cloud) – Structured device and user data (e.g., router serial number, model, firmware version, user association).	At onboarding and device registration.
Router Status and Configuration Metadata (via Device Management Agent on Router) – Structured telemetry (e.g., device identifiers, firmware version, operational state).	Periodic / event-based transmission.
Cloud Connectivity and Device Status (via Remote Access Agent / NETGEAR Remote Access Cloud) – Structured connectivity telemetry (e.g., connection state, timestamps, managing user account, router identifiers).	Real-time transmission on connection events.
Device Country Metadata (for Compliance) – Country of device operation stored as structured compliance metadata; no IP address or precise location data captured.	Captured when device connects or region updated.

NETGEAR Related Services supporting Connected Product functionality

I. NETGEAR provides certain services that support its Connected Products (“Related Services”). When users use NETGEAR Related Services, NETGEAR collects certain data about user actions and events that are recorded or generated by the NETGEAR Connected Services (“Related Service Data”). NETGEAR collects the Product Data described above, and the Related Service Data as set forth below, when users use Related Services to fulfill our agreements with users, including to provide the service requested by the user, to provide security and fraud detection, to detect bugs, flaws, or troubleshoot, for use in customer support, and to understand user preferences for product development and optimize the consumer experience.

II. Users can access and/or retrieve the Related Service Data collected by NETGEAR, as well as request to share the Related Service Data with a third party, by using our online tool at https://preferences.netgear.com.

III. We may share Related Service Data with third-party service providers to fulfill the purpose set forth above and in the tables below.

IV. All Related Service Data is retained for as long as NETGEAR needs it to achieve the purposes illustrated above – in accordance with applicable terms of use – comply with legal obligations or to protect NETGEAR’s or other's interests.

V. The Terms and Conditions governing users access, retrieval, erasure, use, of Product Data and Related Service Data, as well as their sharing with third parties upon user request, are set forth on NETGEAR website here: https://www.netgear.com/about/terms-and-conditions-product-data/

Related Service Data:

Armor Service Data

Estimated Volume: The volume of Related Service Data generated depends on the amount of use of the Related Service as well as the number of events triggering an upload of Related Service Data, such as performance issues or potential security threats detected.

Storage arrangement: On-device until uploaded to servers controlled by NETGEAR located in the EU and then transferred to servers controlled by NETGEAR in the US. After data is uploaded from the Connected Product it is deleted from the Connected Product.

Data Type

Threat and Alert Telemetry (via Bitdefender / NETGEAR Armor) – Structured event data (e.g., threat detections, alert metadata).

Service Status and Performance Telemetry – Structured operational data (e.g., activation state, license status, update timestamps).

User Authentication and Account Activity (Cognito)

Data Type

User Registration and Login Activity – Structured authentication event data (e.g., account identifiers, login timestamps, authentication status). No geolocation data is captured.

NETGEAR Mobile Apps (Nighthawk and Orbi)

Data Type

App Identifiers – Structured telemetry (e.g., app version, device ID, operating system version).

App Interaction Telemetry – Structured interaction data (e.g., screen visits, taps, feature usage).

Device-to-Cloud Interactions – Structured event data representing app-initiated device management actions (e.g., Wi-Fi configuration, settings change).

User Account and Device Association – Structured data linking user accounts to managed devices, including router serial number, firmware version, and registration status.

User Authentication and Account Activity

Data Type

User Registration and Login Activity – Structured authentication event data (e.g., account identifiers, login timestamps, authentication status). No geolocation data is captured.

Insight Service Data

Data Type

Managed device attributes (e.g., serial number, model name, firmware version).

Managed device configuration (e.g., feature and setting configurations).

Managed device health/performance (telemetry) (e.g., CPU, memory, traffic utilization, number of connected clients).

Managed device topology (e.g., interconnectivity of managed devices).

Additional Disclosures

1. NETGEAR is headquartered in the United States at 3553 N. First Street, San Jose, CA 95134 and its EU main establishment is located at:

      NETGEAR International Limited
      First Floor Building 3 University Technology Centre Curraheen Road
      Cork, Ireland.

2. NETGEAR is the holder of trade secrets contained in the data that is accessible from the Connected Product or generated during the provision of a Related Service.

3. To communicate with us, please send an email to legal@netgear.com

4. To request that we share the Product Data or Related Service Data we collect from your Connected Product, or through your use of our Related Services, with a third party, or to end data sharing that you initiated, please send an email to legal@netgear.com

5. You have the right to lodge a complaint alleging an infringement of any of the provisions of the Data Act with the competent authority designated under Article 37 of the Data Act.

6. The duration of your contract with NETGEAR for any of the products or services identified above, including any rights to terminate that contract, are as specified in the contract you have entered for those products or services.