Data Act
Information on Regulation (EU) 2023/2854 (Data Act)
Chapter 1 — Introduction, Purpose and Definitions
1. Purpose of this document
This document is intended to provide pre-contractual information to users of connected products in accordance with Article 3(2) of Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data (Data Act).
The purpose of this document is to provide general information regarding:
· the types of data generated by the use of devices manufactured or placed on the market by elem6 s.r.o.,
· the manner in which such data may be stored,
· the manner in which such data may be accessed or made available to users, and
· the rights of users in relation to such data.
This document provides general information only. The availability of specific data and functionalities may vary depending on the product model, configuration, and the digital services associated with the product.
2. Identification of the manufacturer
The manufacturer of the products covered by this document is:
elem6 s.r.o.
Braškovská 308/15
161 00 Prague 6
Czech Republic
Company ID: 24232335
3. Definition of the user
For the purposes of this document, the term user shall have the meaning set out in Regulation (EU) 2023/2854 (Data Act), namely a natural or legal person that:
· owns a connected product, or
· has been contractually granted temporary rights to use a connected product, or
· receives related digital services associated with such connected product.
4. Definition of a connected product
For the purposes of this document, a device (hereinafter referred to as the product) shall be considered a connected product within the meaning of Regulation (EU) 2023/2854 (Data Act) only where, during its normal use, data generated by the use of the product are systematically made available through a digital service or interface operated by the manufacturer or by an authorised entity acting on behalf of the manufacturer.
Such digital services may include, in particular:
· server-based services,
· cloud services,
· user accounts enabling access to data,
· or other digital infrastructures enabling data generated by the use of the product to be made available to the user.
The mere existence of local connectivity (for example Bluetooth or local WiFi communication used solely for local control or display purposes) does not in itself constitute making data available within the meaning of the Data Act.
5. Scope of application
This information applies to products placed on the market in the European Union by elem6 s.r.o. that generate data through their use and make such data available to users through a mobile application, digital service, or other digital interface operated by or on behalf of the manufacturer.
This document does not apply to products that generate data solely for local use where such data are neither made available through a digital service nor processed or stored outside the user’s device.
Chapter 2 — Devices with Their Own Internet Connection
1. Scope of this category
This category includes connected products equipped with their own internet connectivity, in particular devices capable of transmitting data through mobile networks or other internet-based communication technologies.
Typical examples include:
· children’s smart watches,
· GPS trackers,
· and similar devices enabling remote monitoring or communication through digital services.
2. Types of data generated
Depending on the product type and configuration, the following categories of data may be generated through the use of the product:
· geolocation data (e.g. GPS position),
· communication data (e.g. voice communication or text messages where applicable),
· physical activity data (e.g. step count or similar activity indicators),
· operational and diagnostic data (e.g. firmware version, connectivity status, device performance information).
The scope of generated data may vary depending on the specific product model and user settings.
3. Data format
Data generated by the use of the product may be made available in a commonly used, structured and machine-readable format enabling further use, where applicable and where such data are made available through a digital service.
4. Data volume
The volume of data generated by these devices depends on the intensity and manner of use. In typical operation, devices in this category may generate a continuous stream of data, for example in the case of real-time location tracking or ongoing communication functions.
5. Data recording interval
Devices in this category may generate and transmit data continuously or at regular intervals during operation, depending on device configuration and availability of network connectivity.
Data transmission may be affected by external circumstances, including but not limited to mobile network coverage or temporary loss of connectivity.
6. Data storage
Data generated by the use of the product may be stored:
· locally within the device (for example call logs, temporary records or locally stored content), and/or
· within digital services operated by or on behalf of the manufacturer, where such services are used to enable functionality such as displaying historical data or device activity.
The retention period of data stored within digital services may vary depending on the type of data and the applicable terms of the relevant digital service.
7. Access to data
Users may access data made available to them through a mobile application or other digital interface associated with the product.
Access to such data may require user authentication through login credentials created during activation of the relevant digital service.
8. Deletion of data
Where data are stored within a digital service, users may request deletion of such data in accordance with applicable contractual terms and applicable legislation, including data protection legislation where personal data are concerned.
Deletion of data may result in irreversible removal of such data from the relevant digital service.
9. Data sharing
Where applicable, users may request that data made available to them be shared with a third party. Data may be provided in a commonly used, structured and machine-readable format, where technically feasible and where such functionality is supported by the relevant digital service.
Chapter 3 — Devices with Bluetooth Connection and Mobile Application
1. Scope of this category
This category includes connected products that communicate primarily through Bluetooth or similar short-range communication technologies and are used in conjunction with a mobile application.
Typical examples include:
· smart scales,
· thermometers,
· blood pressure monitors,
· fitness trackers,
· and similar devices generating measurement or activity data.
2. Types of data generated
Depending on the product type and configuration, the following categories of data may be generated through the use of the product:
· physiological or measurement data (e.g. body weight, body temperature, blood pressure, heart rate),
· activity-related data where applicable,
· operational and diagnostic data (e.g. firmware version, connectivity status),
· device operational data necessary for proper functioning of the product.
The exact scope of generated data depends on the specific product model and user settings.
3. Data format
Data generated by the use of the product may be made available in a commonly used, structured and machine-readable format where such data are made available through a mobile application or associated digital service.
4. Data volume
The volume of data generated by devices in this category is typically low, as the devices produce individual measurement records rather than continuous data streams.
In typical operation, individual data records are small in size and generated only during active use of the product.
5. Data recording interval
Devices in this category generate data only when actively used by the user, for example during a measurement or activity recording.
Data are subsequently transferred to the mobile application when a connection between the device and the user’s mobile device is established.
Where applicable, data may subsequently be made available through a digital service if such functionality is enabled by the user.
6. Data storage
Data generated by the use of the product are typically stored primarily within the user’s mobile application, which serves as the primary storage location for measurement history.
Devices themselves usually contain only temporary memory required for storing recent measurements prior to synchronisation.
Unless explicitly enabled by the user, data are not transmitted to or stored on remote servers.
Where cloud-based services are available and activated by the user, data may additionally be stored within digital services operated by or on behalf of the manufacturer in accordance with the applicable terms of use.
7. Access to data
Users may access data made available to them through the mobile application associated with the product, where measured values and historical data may be displayed.
Access may require user authentication where a user account is used.
8. Deletion of data
Where applicable, users may delete data stored within the mobile application or request deletion of data stored within digital services in accordance with applicable contractual terms and data protection legislation.
9. Data sharing
Where supported by the relevant product or digital service, users may request export or sharing of data made available to them with third parties in a commonly used and machine-readable format.
Chapter 4 — Devices Connected to a Home WiFi Network
1. Scope of this category
This category includes connected products that are connected to a local or home WiFi network and are typically controlled or monitored through a mobile application.
Typical examples include:
· baby monitors,
· air purifiers,
· humidifiers and diffusers,
· and similar devices enabling remote monitoring or control through a digital interface.
2. Types of data generated
Depending on the product type and configuration, the following categories of data may be generated through the use of the product:
· real-time audio and video transmission data, where applicable,
· locally measured environmental data (e.g. temperature, humidity or air quality values),
· operational and diagnostic data (e.g. firmware version, connectivity status),
· device operational data necessary for proper functioning of the product.
The scope of generated data depends on the specific product model and user configuration.
3. Data format
Audio and video data are typically transmitted in streaming form in real time. Diagnostic or operational data generated by the device may be made available in a commonly used, structured and machine-readable format where applicable.
4. Data volume
Where audio or video transmission is involved, the volume of generated data may be significantly higher compared to other device categories, as data are transmitted continuously during active use.
Other generated data, such as environmental measurements or diagnostic data, are typically small in volume.
5. Data recording interval
Devices in this category generate data during active use, for example while video streaming is active, device functions are being configured, or monitoring functions are enabled.
Data transmission typically occurs in real time once a connection between the device and the mobile application is established.
6. Data storage
In typical configurations, audio and video data are not permanently stored within digital services and are transmitted only as a real-time stream between the device and the user’s mobile application.
Where specific functionalities allow recording or storage, such storage may occur locally on the user’s device or within optional digital services, depending on product configuration and user settings.
7. Access to data
Users may access data made available to them through the mobile application associated with the product.
Access may require authentication through a user account where digital services are used to enable remote access.
8. Deletion of data
Where data are not permanently stored within digital services, deletion is not applicable.
Where optional storage functionalities are enabled, deletion may be performed by the user or requested in accordance with applicable contractual terms and data protection legislation.
9. Data sharing
Where supported by the relevant product or application, recordings or device access may be shared directly by the user through application functionalities.
Chapter 5 — Data Protection
All data generated by the use of the products described in this document are processed and transmitted using appropriate technical and organisational measures designed to ensure an adequate level of security.
Data transmission between devices, mobile applications and digital services is performed using secure communication protocols, including encrypted communication where applicable.
Access to digital services and mobile applications may be protected by authentication mechanisms such as user accounts and passwords.
Data generated by the use of the product are not made available to third parties without the user’s consent, unless such disclosure is required by applicable legislation or necessary for the provision of the requested digital service.
The processing of personal data, where applicable, is governed by Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR) and related applicable legislation.
Chapter 6 — User Rights under the Data Act
In accordance with Regulation (EU) 2023/2854 (Data Act), users may have the right, where applicable:
· to access data generated by the use of their connected product that are made available to them through a digital service,
· to receive such data free of charge in a commonly used, structured and machine-readable format,
· to request that such data be made available to a third party designated by the user, where technically feasible and in accordance with applicable legislation,
· to receive clear information regarding the categories of data generated and the purposes for which such data are used.
The availability and scope of these rights may depend on the specific product, its configuration, and the digital services associated with the product.
Chapter 7 — Contact Details
For requests concerning access to data, data sharing, or other matters related to data generated by the use of connected products, users may contact via email: info@elem6.com
elem6 s.r.o. 11.9.2025
Frequently Asked Questions
How long does the watch stay charged?
The battery life always depends on how the watch is used. Under normal operation, the battery lasts about 3 days. However, if the watch is actively used throughout the day with all notifications enabled and high-frequency location tracking (each 9 minutes), it can drain within a day. We recommend enabling power-saving features, such as scheduled on/off times, limiting watch usage during classes, and using localisation manually.
Which phone is suitable for pairing with the watches?
You can pair WatchY4 with any phone that runs on the Android or iOS operating system and has the LAMAX Connect application installed.
What does the WatchY4 product package contain?
WatchY4 Play
Watch, charging cable, manual, T-Mobile SIM card, QR code to download the LAMAX Connect application to communicate with the watch user.
WatchY4 Plus
Watch, charging cable, manual, T-Mobile SIM card, 2 straps and 2 watch covers in different colours, QR code to download the LAMAX Connect application to communicate with the watch user.
What do I need to make phone calls with the watch?
In the package with the watch, you will find a T-Mobile SIM card (200MB free), which you insert into the watch. Remove the watch cover and on the left side, you will find the SIM card slot; open it and insert the SIM card. It is not necessary to have an e-SIM, as you can physically insert the card into the watch. This eliminates the complicated setup of the e-SIM and connecting it with a mobile phone.
Can I use my own purchased SIM card?
Yes, you can choose a SIM card from your preferred operator, which must have data purchased for 2G/3G/4G.
What if the SIM card is blocked by a PIN code?
You simply enter the PIN code of the SIM card in the watch after switching it on. The PIN code of the SIM card can be deactivated after entering it into the mobile phone in the settings. After deactivating the PIN code, it will no longer be necessary to enter it.
Are the watches water-resistant or waterproof?
WatchY4 Play
The watch is only water-resistant with an IP68 rating, providing reliable protection in the rain or when in contact with water during hand washing, etc. Although the IP68 rating allows for submersion up to 1 meter, we recommend always removing the watch before bathing and not diving with it. This level of protection is not suitable for prolonged water exposure such as swimming, playing at the pool, or showering.
WatchY4 Plus
The watch is only water-resistant with an IP67 rating, providing reliable protection in the rain or when in contact with water during hand washing, etc. Although the IP67 rating allows for submersion up to 1 meter, we recommend always removing the watch before bathing and not diving with it. This level of protection is not suitable for prolonged water exposure such as swimming, playing at the pool, or showering.
What is the length of the watch warranty period?
We provide a full two-year warranty on the watches.
How can WatchY4 be paired with a mobile phone?
You need to download the LAMAX Connect application specifically designed for WatchY4. After downloading the app, register using your email address, where you will receive a verification code. The watch needs to be connected to the internet, either through mobile data or Wi-Fi. Then, press the crown (the button on the right side) on the watch and find and select the BIND option. A QR code will appear, which you scan using the app on your mobile phone, and the watch will pair easily.
Where can I download the app and which devices is it compatible with?
You can easily download the LAMAX Connect app from Google Play or the App Store, making it compatible with both Android and iOS devices. After downloading the app, register and pair the watch with your device.
I didn't receive the verification code during registration.
First, please verify the correctness of the email address you entered when registering into the application. If the address is correct, then check if you have blocked message reception or if the email might have been placed in the SPAM folder. You can also ask inside the application to resend the verification code once more.
How many devices can I monitor under one account in the application?
The number of devices under one account is unlimited.
How much data do the watches consume per month?
The average data consumption is around 100 MB monthly. For comparison, a 1-minute video call consumes approximately 4 MB of data.
To perform settings directly on the watch?
Swipe your finger from left to right. Here you will find partial settings for the watch. For complete settings, you will need to use the application. This is designed to give you, as a parent, control over the settings.
How do I connect the watch to Wi-Fi?
To connect the watch to wi-if, follow these steps: On the watch, select "MORE" -> "SETTINGS" -> WI-FI. Choose the Wi-Fi network you want to connect to. Enter the Wi-Fi password when prompted.
Once the password is entered correctly, the watch will connect to the Wi-Fi network. After this setup, the watch should be fully functional and configured to connect properly.
How do I set the time on the watch?
There's no need to set the time manually. The watch will automatically obtain the time once a SIM card is inserted. However, you can customize the visual appearance of the time in the MORE menu, where you can choose either digital or analog clocks.
Can multiple users track location of the watch user?
Yes, if e.g. grandparents are taking care of your little one and want to monitor their whereabouts or stay in touch, they can install the app on their phone, be approved as family members and pair the watch using a QR code.
Where are the movement and location data of children stored?
Log messages are first stored on the server and then retrieved by the app. Once the app has obtained the information from the server, it will be automatically deleted and saved locally in the app. After the watch is unbound, all information on the servers will be deleted.
Where are the servers situated?
Our servers are situated in Frankfurt, Germany.
How do I set up calling on the watch?
You always need to assign the phone number of the watch SIM card in the app. To do this, go to the app settings, select your child's profile, open it, click on "Watch Phone Number," enter the correct phone number assigned by the operator for the watch's SIM card, and save it.
Note: We recommend entering the watch's phone number including the international dialing code (e.g. +420 for the Czech Republic). Instead of the "+" sign, you can use the digits "00" (e,g, 00420 for the Czech Republic).
Who can communicate within the chat?
Everyone connected to the app linked with your child's watch can communicate both within the family chat and individually.
I can't see my child's location and can't send them a voice message.
Make sure that location services and microphone permissions are enabled. You need to enable these settings to communicate with your child and view their location.
Another reason could be a switched off or discharged watch.
When the watch is turned off manually, a notification is sent to the application. Manual shutdown of the watch can be disabled in the application. To disable manual shutdown of the watch, go to menu *MORE*, *DEVICE SETTINGS*, *DISABLE SHUTDOWN* and enable. Now the watch can only be turned off remotely from the app.
When the watch battery drops to 20%, a notification will be sent to the app and then after every 5% battery reduction thereafter. From the application, it is possible to switch the watch to energy-saving mode, which will reduce energy consumption. To set the power saving mode, go to the *MORE* menu in the application, *ENABLE POWER-SAVING MODE* and enable.
Note: When the watch is in power saving mode, it only supports showing the time, receiving calls, determining the location from the application and using the SOS button.
What is the maximum duration of a video call?
The maximum duration for a video call is 5 minutes.
My child can't hear me when I call them. How can I resolve this?
You always need to allow microphone access directly on your mobile phone. This feature is offered right after installing and registering in the app. If you initially denied microphone access, you'll need to enable it in your mobile phone settings. If everything is allowed, uninstall the app, download it again, and log back into your account.
How do I add a new contact?
Select the MORE menu - open it and select CONTACTS IN THE WATCH - here you can add anyone your child can reach out to if needed.
How do I block calls from unknown numbers?
Select the MORE category in the app, choose REJECT UNKNOWN CALLS, and turn it on. Now you can be sure that no strangers will be able to call your child.
Is it possible to pair a watch with someone else's app via QR code?
No, for security reasons, this is not possible. Only the so-called superadmin, who registered through the app and paired the watch with their application first, can approve and add other family members. There is no need to worry about someone else pairing the app and gaining access to the child's data and location.
How many contacts can I add to the address book?
You can add 15 regular contacts and 3 emergency contacts.
Can I track my child's chat history directly within the app?
Within the app, it's not possible to monitor specific chats or the content of chats. If you have concerns that your child may be communicating with someone they shouldn't, it's important to talk to your child directly and address the situation with them.
How do I set up a safety zone for where my child should be located?
Select the MORE category in the app, choose SAFETY ZONE, and set up a zone according to your needs where your child should stay in your absence. If your child enters or leaves this zone, the app will alert you.
How do I set silent mode when my child is at school?
Go to the MORE category in the app, where you'll find RESTRICT WATCH FOR SPECIFIC TIME. Here, you can set the time range when your child is at school or studying at home to ensure they are not disturbed.
Can I monitor the watch user's health data in real time?
In the application, it is possible to monitor steps per day, current and average heart rate and blood oxygenation.
The step data is updated automatically on the watch face and in the application. It is also possible to monitor the heart rate and either call up the measurement of the current heart rate from the application or the watch, or set a continuous measurement - in this case, the data is updated every 10 minutes, both in the application and on the watch face (if one is selected which this view allows). The application then displays both the data from the last measurement or the average for the last 24 hours. To turn on continuous heart rate measurement, go to *MORE* and *HEALTH SETTINGS* in the app. The last health data is % blood oxygenation. This data can be measured once either on the watch or from the application. The application then displays an overview of the measured values for the last 7 days.
Note: Heart rate and blood oxygenation functions are not supported by Watchy4 Play.
Warning: These heart rate monitoring watches are not certified medical devices. The measurements they provide are for informational purposes only and cannot replace professional medical diagnosis. If you have health concerns or questions about your condition, please consult your doctor.
Can watches communicate directly with each other?
Yes, use the *ADD FRIEND* function. After selecting *START TO MAKE FRIEND* on two Watchy4 watches, the watches will connect and add the other watch as a new contact. To pair, the watches must be within 8 meters of each other. After connecting, the watches can chat with each other, and if they are the same model (Plus or Play), they can also communicate with each other using video calls.
Check quick start video instructions on how to use me and the LAMAX Connect app.
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Quick Start Guide
Quick start guide for setting up WatchY4 and LAMAX Connect application, where you will find top 10 points to set up.
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