Company Privacy Policy

The "Company" (hereinafter referred to as "we"), located at Shayang Road, Shahe, Changping District, Beijing, China.

We highly value and are committed to protecting the security of your personal information. When using our services, we may collect and use your relevant information. This "Privacy Policy" aims to explain to you how we will collect, use, store, share, and protect your information when you use our services, as well as to inform you of the ways in which you can access, update, and control the relevant information.

By default, we do not collect your personal information when the vehicle is delivered.

If you would like to use our Telematics service, you will need to be informed of the following:

1. We will collect your vehicle data.

2. In general, we will not link the collected data to your identity or account information. Therefore, apart from yourself, others cannot access your relevant data. Other activity data inside your vehicle is also protected.

3. We collect your personal data minimally, and the scope of data collection is limited to the information necessary for the normal use of the services we provide and for the optimization of the vehicle's functionality.

The following will help you understand in detail how we collect, use, transfer, disclose, and protect your personal information, as well as how we manage your relevant information and handle the personal information of minors. Important information about your personal information rights is highlighted in bold, so please pay special attention to it.

This Privacy Policy was updated and effective on 1st March 2024.

A. How we collect and use your personal information

B. How we entrusted processing, share, transfer, public disclosure your personal information

C. How we protect your personal information

D. How we manage your personal information

E. How we process minors' personal information of minors

F. Global transfer of your personal information

G. How we update this Privacy Policy

H. How to contact us

A.How we collect and use your personal information

a) We may collect and use data related to you or generated from your use of our location and big data-related services in the following two categories:

1. Personal Data

To register for some of the functionality we provide (e.g., the TSP) to achieve certain functions (e.g., creating an account), we collect your name, contact information, and email address from you. Such information will only be used for account registration. To protect your privacy, your name, contact information, and email address will be de-identified and your data will be stored in a standard encrypted format so that only the administrators of the functional platforms will have access to your information, and if you need to add, modify, delete, or change your information, you can contact us through the contact information disclosed in this Privacy Policy exercise your rights.

2. Vehicle Data

To ensure continuous vehicle operation, predictive maintenance, and improve functionality and experience, the TSP provides vehicle management services (including Vehicle Location, Real-Time Positioning, Real-Time Data, Offline Vehicle, Vehicle Analytics, and Driving Analytics modules), Big Data Analytics (including Operations Analytics, Offline Analytics, Fault Alarms, and Operations Ranking modules), and Battery Management (Charging Reports, Driving Reports, Battery Monitoring, Battery Care). When using these features, your vehicle will collect and process vehicle location data, T-box device number, vehicle identification number (VIN), and vehicle data related to usage, operation, and status. This information is used to identify and resolve potential problems and to continually improve your vehicle and the services provided to you. To protect your privacy, such vehicle data will generally be stored in the following manner: VIN, T-box device number will be de-identified and your data will be stored in a standard encrypted format, including, but not limited to, the following:

We clearly define what vehicle data we do and do not collect. Vehicle data collected under the conditions of Australian law includes vehicle speed information, acceleration information, steering wheel turning angle, and other data used to identify issues and analyze vehicle performance. If you have any questions about the collection of your vehicle data or requests for non-collection of your vehicle operational data and any other requests related to the processing of your vehicle operational data, you can fulfill your rights by contacting us through the contact details disclosed in this Privacy Policy.

1) Location Data (High Precision Positioning): provide you with location services, we need your vehicle to use location data or geographic data to support location services and other functions. Location services may use GPS and ionospheric data to determine your location. To protect your privacy, location data will be processed online by the system, or processed in a form that cannot identify your personal information, or we cannot directly access it without your consent (unless required by Australian law). You can also contact us at any time to enable or disable this function.

2) Vehicle Basic and Operational Data: better provide you with data analysis features, keep our products and services up-to-date, troubleshoot or debug, and continuously improve, we strive to collect the minimum necessary diagnostic data to help ensure the security and normal operation of your vehicle. We may collect and store your vehicle's basic data, which may contain your VIN, T-box device serial number, and your vehicle's operating data (vehicle speed, steering wheel turning angle, vehicle braking status, brake pedal angle, throttle angle, fault information, etc.); data on any issues that could seriously affect the operation of your vehicle and data on any critical security issues will also be collected.

We understand that this Privacy Policy basically covers all data scenarios of the company collecting and using your personal information, but for specific details of information collection and usage rules that may be involved, we will further inform you in the privacy policy of specific products or services and obtain your consent. We assure you that we will not collect or use any of your personal information without your consent.

We assure you that if we make any changes to our collection of personal information, we will notify you by posting them on our website, and we will never collect any sensitive personal information that could cause others to discriminate against you.

b) We may collect and use personal information without obtaining your authorization in the following situations:

1. It is not reasonable or practicable to obtain the individual's consent to the collection, use or disclosure of the information;

2. It is necessary to mitigate or prevent a serious breach of an individual's privacy;

3. It is necessary to mitigate or prevent a serious threat to the life, health or safety of any individual or a serious threat to the life, health or safety of any individual, or to public health or safety;

4. Unlawful activity or misconduct of a egregious nature in connection with that our function or activity;

5. We reasonably believe that the collection, use or disclosure of the information is necessary for that entity to take appropriate action, or for appropriate action to be necessary;

6. Actions are necessary to assist any APP entity, agency, or awareness in locating a person who has been reported missing;

7. It is reasonably necessary to establish, exercise, or defend a legal or equitable claim or demand;

8. It is reasonably necessary for a confidential alternative dispute resolution process;

9. It is necessary for diplomatic or consular functions or activities;

10. We reasonably believe that the collection, use or disclosure of the information is necessary for any situation that is occurring, the situation contains:

c) Situations in which we obtain your personal information from third parties

Based on the reasonable requirements of fulfilling network operation security obligations, providing products and/or services to you, or improving the quality, experience, and security of product and/or services, we will receive your personal information and other information (such as Vehicle Identification Number (VIN)) from affiliated companies and other trusted partners in accordance with legal regulations or your authorization. We will use your personal information according to agreements with third parties or this policy.

d) Rules for the use of your personal information

1、 We will use the collected personal information within the necessary scope to achieve the functions of our products and/or services as specified in this Privacy Policy.

2、 We keep statistics on the use of our products and/or services and may share these statistics with the public or third parties to show trends in the overall use of our products and/or services. However, these statistics do not contain any identifying information about you.

3、 When we use your personal information for purposes not specified in this Privacy Policy or when information collected for specific purposes is used for other purposes, we will ask for your consent in writing or electronically in advance.

B. How we entrusted processing, share, transfer, public disclosure your personal information

a) Entrusted Processing

In the scenarios of entrusted processing your personal information, we will sign the Data Processing Agreement with the entrusted party in accordance with the laws and regulations. We will require them to process your personal information within the necessary scope to achieve the purpose of use, in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures. We will supervise their personal information processing activities.

b) Share

We will strictly limit the sharing of personal information according to legal regulations. In general, we will not share your personal information externally. However, we will share your personal information with third parties in the following situations:

c) Transfer

We will not transfer your personal information to any company, organization or individual unless we have your explicit consent.

In the event of a merger, acquisition, or asset sale, we may transfer your personal information for the purposes of the transaction such as a merger, acquisition, or asset sale. Before transferring your personal information, we will provide you with appropriate notice and ensure that your personal information receives protection equivalent to that provided in this Privacy Policy.

d) Public disclosure

We will comply with relevant laws and regulations to keep your personal information confidential. We will not publicly disclose your personal information unless we have your explicit consent or authorization, or unless it is required by laws and regulations.

e) Exceptions

In the following, we share, transfer, and public disclose your personal information without obtaining your prior authorized consent:

1. It is not reasonable or practicable to obtain the individual's consent to the collection, use or disclosure of the information;

2. It is necessary to mitigate or prevent a serious breach of an individual's privacy;

3. It is necessary to mitigate or prevent a serious threat to the life, health or safety of any individual or a serious threat to the life, health or safety of any individual, or to public health or safety;

4. Unlawful activity or misconduct of an egregious nature in connection with that our function or activity;

5. We reasonably believe that the collection, use or disclosure of the information is necessary for that entity to take appropriate action, or for appropriate action to be necessary;

6. Actions are necessary to assist any APP entity, agency, or awareness in locating a person who has been reported missing;

7. It is reasonably necessary to establish, exercise, or defend a legal or equitable claim or demand;

8. It is reasonably necessary for a confidential alternative dispute resolution process;

9. It is necessary for diplomatic or consular functions or activities;

10. We reasonably believe that the collection, use or disclosure of the information is necessary for any situation that is occurring, the situation contains:

C. How we protect your personal information

1. Technical measures for data security

We will adopt security measures with industry standards, including the establishment of a reasonable system of norms, security technology to prevent unauthorized access to your personal information to use, modify, avoid data damage or loss.

The company adopts encryption technology to encrypt the transmission and storage of users' personal information. The company protects personal information by adopting strict data access rights control to avoid unauthorized use of data.

2. We only allow employees of the company and its affiliates who have a need to know such information to access personal information, and have set up strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill the corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of the relationship.

3. We recommend that you use complex passwords when using email, instant messaging, social media apps, and other communication tools, and pay attention to protecting your personal information security.

4. Please note that the Internet environment is not completely secure, we will take security measures in accordance with the legal requirements and the level of technological development, and try our best to ensure the security of any information you send to us. But at the same time, if our physical, technical, or management protection facilities are subjected to unforeseen and preventive damage, resulting in unauthorized access, public disclosure, tampering, or destruction of information, we will not be responsible for any losses that are not caused by the company.

5. Security incident processing

Please protect your personal information properly and only provide it when necessary. The company has established systems to handle security incidents, categorizing and classifying security data, along with corresponding processing procedures. The company has also established a specialized emergency response team for security incidents, which activates security plans for different security incidents, stops damage, analyzes, locates, formulates remedial measures, and joins with relevant departments to trace and combat security incidents in accordance with the requirements of the security incident handling specifications.

After the occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently take to prevent and reduce the risk, and the remedial measures for you. At the same time, we will promptly inform you of the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make a public announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents to the supervisory authorities in accordance with legal requirements.

6. We have set up a specialized data security team responsible for carrying out work related to the protection of personal information. If you have any questions about our personal information protection, you can contact us through the contact information listed at the bottom of this privacy policy. If you find that your personal information has been compromised, especially your account and password, please contact us immediately through the contact information in this Privacy Policy and assist us in taking appropriate measures.

D. How we manage your personal information

In accordance with relevant Australian laws, regulations, and standards, as well as common practices in other countries and regions, we store your personal information for the shortest period necessary to achieve our business purposes, and we guarantee that you will exercise the following rights with respect to your personal information:

a) Access to your personal information

If you would like to access, review, or copy your personal information, you may access your personal information by contacting us in the "Contact Us" section below. Subject to certain exceptions, we may deny your request to the extent permitted by applicable laws and regulations. We reserve the right to adjust your request as described above in accordance with applicable laws and regulations.

We will transfer copies of your personal information to third parties designated by you at your request, subject to compliance with relevant legal requirements and technical feasibility.

b) Correcting or supplementing your personal information

You have the right to request that we correct or supplement the personal information we process about you if you discover that it is incorrect. You may make a request for correction or supplementation in the manner set out in this section "Access to your personal information". We will respond to your request within thirty natural days.

c) Delete your personal information

You can request the deletion of certain personal information through the methods mentioned in the "Access to your personal information" section.

In the following cases, you may make a request to us to delete your personal information:

1. If our handling of personal information violates laws and regulations;

2. If the purposes for which we process personal information have been achieved, cannot be achieved or are no longer necessary to achieve the purposes for which the processing was carried out;

3. If we collect or use your personal information without your consent;

4. If you withdraw your authorized consent;

5. If our processing of personal data constitutes a serious breach of our agreement;

6. If you no longer use our products or services, or if you voluntarily cancel your account;

7. If we permanently cease to provide products or services to you;

8. If the retention period of your personal information expires;

9. Other situations stipulated by laws and regulations.

Exception: We will not be able to completely delete your personal information if the retention period stipulated by laws and regulations has not expired or if deletion of personal information is technically difficult to achieve. However, we will stop storing and taking necessary security measures beyond the processing of personal information.

If you request the deletion of your personal information based on the circumstances described above, you may contact us at any time through the contact information set forth in this Privacy Policy, and we will respond within thirty natural days, unless otherwise required by law or regulation. If we decide to respond to your request for deletion, we will also notify the entities from which we obtained your personal information to delete your personal information, unless otherwise required by law or regulation or unless those entities have been independently authorized by you. When you delete information from our services, we may not immediately delete the corresponding information from our backup systems but will delete the information when the backups are updated. Please know and understand that, in accordance with laws and regulations, if the retention period stipulated by laws and regulations has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing other than storing and taking the necessary security protection measures.

d) Withdrawal of consent

You have the right to withdraw your authorization, but the business function requires some basic personal information to be completed, and in the case of a service that relies on your authorization to be implemented or to function properly, we will not be able to continue to provide you with the corresponding service or part of the function of the service will be affected if you withdraw the relevant authorization. You may withdraw your consent by contacting us at via the contact details disclosed in this Privacy Policy.

When you withdraw the relevant authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your authorization will not affect the processing of personal information previously carried out based on your authorization.

e) Obtaining a copy of your personal information and portability

You have the right to obtain a copy of your personal information, and you may contact us using the contact information disclosed in this Privacy Policy.

Subject to the conditions of national laws and regulations and technical feasibility, we may also transmit a copy of your personal Information directly to a third party designated by you at your request if the data interface has been matched.

f) Account Cancellation

You may cancel your previously registered account at any time, and you may cancel your account by contacting us using the contact information disclosed in this Privacy Policy;

After canceling your account, we will stop providing you with products or services and delete your personal information upon your request, unless otherwise provided by law or regulation.

g) Responding to your requests

For security purposes, you may be required to submit a written request or provide other forms of identity verification. We may request identity verification before processing your requests, and responses will be provided within thirty natural days. If you are not satisfied with our respondence, you may also initiate a complaint through the "How to contact us". In principle, we do not charge you for reasonable requests. However, repeated or excessive requests beyond reasonable limits may incur costs. We may refuse requests that are unnecessarily repetitive, require excessive technical means (e.g., require the development of a new system or a fundamental change in current practice), pose a risk to the legitimate interests of others, or are highly impractical.

E. How we process minors' personal information

Currently, we do not process personal information of minors.

F. Global transfer of your personal information

Since we provide products or services through resources and servers located around the world, this means that, with your authorized consent, your personal information may be transferred to, or accessed from overseas jurisdictions where the product or service is used. We will provide you with information in advance about the personal information protection requirements of foreign countries, measures taken by third parties to protect personal information, and other references in accordance with the regulations of the authorities.

Currently, the TSP is deployed in Singapore, and our cloud services operations and maintenance personnel who can access the system are in China. However, such jurisdictions may have different data protection laws, or even no laws at all. In such cases, we will ensure that your personal information is adequately protected and monitored.

If some of our services involve cross-border business and we need to transmit relevant personal information to overseas organizations, we will follow the laws and regulations and the provisions of the relevant supervisory authorities to inform you of the name and contact information of the overseas recipient, the purpose of the processing, the processing method, the types of personal information, and the ways and procedures for you to exercise your rights, and obtain your consent as well as signing of an agreement, on-site inspection and other effective measures, request the overseas organization to ensure the security of your personal information.

Our services will involve global transfer of your personal information under the following circumstances:

To ensure the stability and security of the products/services provided and to manage the products/services, your vehicle's VIN, vehicle location, name, email, contact information, T-box device number information is remotely accessed by Foton located in China. In order to provide real-time location and vehicle location functionality, your vehicle location information is transmitted to Google Maps located overseas.

Google Maps Privacy Policy:

https://developers.google.cn/maps/security/compliance/security-compliance.

G. How we update this Privacy Policy

Our privacy policy may be changed in needs.

We will not restrict your rights under this privacy policy without your explicit consent. For significant changes, we will provide prominent notice.

Significant changes referred to in this policy include, but are not limited to:

1. Significant changes in our service. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;

2. We experience significant changes in control, etc. Such as changes in ownership due to mergers and acquisitions, reorganizations, etc.;

3. Changes in the third parties and purposes for which personal information is entrusted processing, share, transfer or public disclose;

4. Significant changes in your rights to participate in the processing of personal information and how you exercise them;

5. Changes in the department responsible for the security of personal information, our contact details and complaint channels;

6. When the personal information security impact assessment indicates a high risk;

We will also archive an older version of this Privacy Policy for your review.

H. How to contact us

a) We have a team dedicated to the protection of personal information and a person responsible for the protection of personal information. If you have any questions about this policy or related matters, if you believe that our processing of personal information has harmed your legitimate rights and interests, you can contact us in the following ways, and we will review the issues involved as soon as possible;

1) Send your questions to e-mail address: customer@foton.com.cn

2) Send a mail: customer@foton.com.cn

b) Seek resolution by filing a lawsuit in a court of competent jurisdiction where the defendant is located.

The "Company" (hereinafter referred to as "we"), located at Shayang Road, Shahe, Changping District, Beijing, China.

We highly value and are committed to protecting the security of your personal information. When using our services, we may collect and use your relevant information. This "Privacy Policy" aims to explain to you how we will collect, use, store, share, and protect your information when you use our services, as well as to inform you of the ways in which you can access, update, and control the relevant information.

By default, we do not collect your personal information when the vehicle is delivered.

If you would like to use our Telematics service, you will need to be informed of the following:

1. We will collect your vehicle data.

2. In general, we will not link the collected data to your identity or account information. Therefore, apart from yourself, others cannot access your relevant data. Other activity data inside your vehicle is also protected.

3. We collect your personal data minimally, and the scope of data collection is limited to the information necessary for the normal use of the services we provide and for the optimization of the vehicle's functionality.

The following will help you understand in detail how we collect, use, transfer, disclose, and protect your personal information, as well as how we manage your relevant information and handle the personal information of minors.

Important information about your personal information rights is highlighted in bold, so please pay special attention to it.

This Privacy Policy was updated and effective on 1st March 2024.

A. How we collect and use your personal information

B. How we entrusted processing, share, transfer, public disclosure your personal information

C. How we protect your personal information

D. How we manage your personal information

E. How we process minors' personal information of minors

F. Global transfer of your personal information

G. How we update this Privacy Policy

H. How to contact us

A.How we collect and use your personal information

a) We may collect and use data related to you or generated from your use of our location and big data-related services in the following two categories:

1. Personal Data

To register for some of the functionality we provide (e.g., the TSP) to achieve certain functions (e.g., creating an account), we collect your name, contact information, and email address from you. Such information will only be used for account registration. To protect your privacy, your name, contact information, and email address will be de-identified and your data will be stored in a standard encrypted format so that only the administrators of the functional platforms will have access to your information, and if you need to add, modify, delete, or change your information, you can contact us through the contact information disclosed in this Privacy Policy exercise your rights.

2. Vehicle Data

To ensure continuous vehicle operation, predictive maintenance, and improve functionality and experience, the TSP provides vehicle management services (including Vehicle Location, Real-Time Positioning, Real-Time Data, Offline Vehicle, Vehicle Analytics, and Driving Analytics modules), Big Data Analytics (including Operations Analytics, Offline Analytics, Fault Alarms, and Operations Ranking modules), and Battery Management (Charging Reports, Driving Reports, Battery Monitoring, Battery Care). When using these features, your vehicle will collect and process vehicle location data, T-box device number, vehicle identification number (VIN), and vehicle data related to usage, operation, and status. This information is used to identify and resolve potential problems and to continually improve your vehicle and the services provided to you. To protect your privacy, such vehicle data will generally be stored in the following manner: VIN, T-box device number will be de-identified and your data will be stored in a standard encrypted format, including, but not limited to, the following:

We clearly define what vehicle data we do and do not collect. Vehicle data collected under the conditions of New Zealand law includes vehicle speed information, acceleration information, steering wheel turning angle, and other data used to identify issues and analyze vehicle performance. If you have any questions about the collection of your vehicle data or requests for non-collection of your vehicle operational data and any other requests related to the processing of your vehicle operational data, you can fulfill your rights by contacting us through the contact details disclosed in this Privacy Policy.

1) Location Data (High Precision Positioning): provide you with location services, we need your vehicle to use location data or geographic data to support location services and other functions. Location services may use GPS and ionospheric data to determine your location. To protect your privacy, location data will be processed online by the system, or processed in a form that cannot identify your personal information, or we cannot directly access it without your consent (unless required by New Zealand law). You can also contact us at any time to enable or disable this function.

2) Vehicle Basic and Operational Data: better provide you with data analysis features, keep our products and services up-to-date, troubleshoot or debug, and continuously improve, we strive to collect the minimum necessary diagnostic data to help ensure the security and normal operation of your vehicle. We may collect and store your vehicle's basic data, which may contain your VIN, T-box device number, and your vehicle's operating data (vehicle speed, steering wheel turning angle, vehicle braking status, brake pedal angle, throttle angle, fault information, etc.); data on any issues that could seriously affect the operation of your vehicle and data on any critical security issues will also be collected.

We understand that this Privacy Policy basically covers all data scenarios of the company collecting and using your personal information, but for specific details of information collection and usage rules that may be involved, we will further inform you in the privacy policy of specific products or services and obtain your consent. We assure you that we will not collect or use any of your personal information without your consent.

We assure you that if we make any changes to our collection of personal information, we will notify you by posting them on our website, and we will never collect any sensitive personal information that could cause others to discriminate against you.

b) We may collect and use personal information without obtaining your authorization in the following situations:

1. It will not jeopardize the interests of the individuals concerned;

2. It will affect the purpose of the function;

3. The information is publicly available;

4. It avoids prejudice to the maintenance of laws by authorities, including prejudice to the prevention, detection, investigation, prosecution and punishment of crime; or to the enforcement of laws imposing fines; or to the protection of the public revenue; or to the carrying out of legal proceedings (i.e. proceedings which have been commenced or are reasonably contemplated) in any court or tribunal; or to the prevention or mitigation of a serious threat to the life or health of the individual concerned or of any other individual;

5. For public health or public safety;

6. For the life or health of the individual concerned or any other individual;

7. Compliance is not reasonably practicable in some circumstances;

8. The information will not be used in a form that identifies the individual concerned or the user for statistical research purposes and will not be released in a form that can reasonably be expected to identify the individual concerned.

c) Situations in which we obtain your personal information from third parties

Based on the reasonable requirements of fulfilling network operation security obligations, providing products/services to you, or improving the quality, experience, and security of product and/or services, we will receive your personal information and other information (such as Vehicle Identification Number (VIN)) from affiliated companies and other trusted partners in accordance with legal regulations or your authorization. We will use your personal information according to agreements with third parties or this policy.

d) Rules for the use of your personal information

1、 We will use the collected personal information within the necessary scope to achieve the functions of our products and/or services as specified in this Privacy Policy.

2、 We keep statistics on the use of our products and/or services and may share these statistics with the public or third parties to show trends in the overall use of our products and/or services. However, these statistics do not contain any identifying information about you.

3、 When we use your personal information for purposes not specified in this Privacy Policy or when information collected for specific purposes is used for other purposes, we will ask for your consent in writing or electronically in advance.

B. How we entrusted processing, share, transfer, public disclosure your personal information

a) Entrusted Processing

In the scenarios of entrusted processing your personal information, we will sign the Data Processing Agreement with the entrusted party in accordance with the laws and regulations. We will require them to process your personal information within the necessary scope to achieve the purpose of use, in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures. We will supervise their personal information processing activities.

b) Share

We will strictly limit the sharing of personal information according to legal regulations. In general, we will not share your personal information externally. However, we will share your personal information with third parties in the following situations:

c) Transfer

We will not transfer your personal information to any company, organization or individual unless we have your explicit consent.

In the event of a merger, acquisition, or asset sale, we may transfer your personal information for the purposes of the transaction such as a merger, acquisition, or asset sale. Before transferring your personal information, we will provide you with appropriate notice and ensure that your personal information receives protection equivalent to that provided in this Privacy Policy.

d) Public disclosure

We will comply with relevant laws and regulations to keep your personal information confidential. We will not publicly disclose your personal information unless we have your explicit consent or authorization, or unless it is required by laws and regulations.

e) Exceptions

In the following, we share, transfer, and public disclose your personal information without obtaining your prior authorized consent:

1. The disclosure of the information is one of the purposes for which your information was collected or is directly related to the purpose for which it was collected;

2. The source of the information is from publications;

3. To avoid prejudice to the maintenance of laws by authorities, including prejudice to the prevention, detection, investigation, prosecution and punishment of crime; or to the enforcement of laws imposing fines; or to the protection of the public revenue; or to the conduct of legal proceedings (i.e. proceedings which have been commenced or are reasonably contemplated) in any court or tribunal;

4. For the purpose of preventing or mitigating a serious threat to public health or public security, or to the life or health of the individual concerned or other individuals;

5. We reasonably believe that the collection, use or disclosure of the information is necessary for that entity to take appropriate action, or for appropriate action to be necessary;

6. It is necessary to facilitate the sale or other disposal of a business as a going concern;

7. The information is used in a form that does not identify the individual concerned; or will be used for statistical or research purposes and will not be released in a form in which the individual concerned can reasonably be expected to be identified.

C. How we protect your personal information

1. Technical measures for data security

We will adopt security measures with industry standards, including the establishment of a reasonable system of norms, security technology to prevent unauthorized access to your personal information to use, modify, avoid data damage or loss.

The company adopts encryption technology to encrypt the transmission and storage of users' personal information. The company protects personal information by adopting strict data access rights control to avoid unauthorized use of data.

2. We only allow employees of the company and its affiliates who have a need to know such information to access personal information and have set up strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill the corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of the relationship.

3. We recommend that you use email, instant messaging, social software, and other communication tools, with other users please use complex passwords and pay attention to protect your personal information security.

4. Please note that the Internet environment is not completely secure, we will take security measures in accordance with the legal requirements and the level of technological development and try our best to ensure the security of any information you send to us. But at the same time, if our physical, technical, or management protection facilities are subjected to unforeseen and preventive damage, resulting in unauthorized access, public disclosure, tampering, or destruction of information, we will not be responsible for any losses that are not caused by the company.

5. Security incident processing

Please protect your personal information properly and only provide it when necessary. The company has established systems to handle security incidents, categorizing and classifying security data, along with corresponding processing procedures. The company has also established a specialized emergency response team for security incidents, which activates security plans for different security incidents, stops damage, analyzes, locates, formulates remedial measures, and joins with relevant departments to trace and combat security incidents in accordance with the requirements of the security incident handling specifications.

After the occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently take to prevent and reduce the risk, and the remedial measures for you. At the same time, we will promptly inform you of the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make a public announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents to the supervisory authorities in accordance with legal requirements.

6. We have set up a specialized data security team responsible for carrying out work related to the protection of personal information. If you have any questions about our personal information protection, you can contact us through the contact information listed at the bottom of this privacy policy. If you find that your personal information has been compromised, especially your account and password, please contact us immediately through the contact information in this Privacy Policy and assist us in taking appropriate measures.

D. How we manage your personal information

In accordance with relevant New Zealand laws, regulations, and standards, as well as common practices in other countries and regions, we store your personal information for the shortest period necessary to achieve our business purposes, and we guarantee that you will exercise the following rights with respect to your personal information:

a) Access to your personal information

If you would like to access, review, or copy your personal information, you may access your personal information by contacting us in the "Contact Us" section below. Subject to certain exceptions, we may deny your request to the extent permitted by applicable laws and regulations. We reserve the right to adjust your request as described above in accordance with applicable laws and regulations.

We will transfer copies of your personal information to third parties designated by you at your request, subject to compliance with relevant legal requirements and technical feasibility.

b) Correcting or supplementing your personal information

You have the right to request that we correct or supplement the personal information we process about you if you discover that it is incorrect. You may make a request for correction or supplementation in the manner set out in this section "Access to your personal information". We will respond to your request within 6 working days and will reply to your correction request within 20 working days.

c) Delete your personal information

You can request the deletion of certain personal information through the methods mentioned in the "Access to your personal information" section.

In the following cases, you may make a request to us to delete your personal information:

1. If our handling of personal information violates laws and regulations;

2. If the purposes for which we process personal information have been achieved, cannot be achieved or are no longer necessary to achieve the purposes for which the processing was carried out;

3. If we collect or use your personal information without your consent;

4. If you withdraw your authorized consent;

5. If our processing of personal data constitutes a serious breach of our agreement;

6. If you no longer use our products or services, or if you voluntarily cancel your account;

7. If we permanently cease to provide products or services to you;

8. If the retention period of your personal information expires;

9. Other situations stipulated by laws and regulations.

Exception: We will not be able to completely delete your personal information if the retention period stipulated by laws and regulations has not expired or if deletion of personal information is technically difficult to achieve. However, we will stop storing and taking necessary security measures beyond the processing of personal information.

If you request the deletion of your personal information based on the circumstances described above, you may contact us at any time through the contact information set forth in this Privacy Policy, and we will respond to your request within 6 working days and will reply to your deletion request within 20 working days, unless otherwise required by law or regulation. If we decide to respond to your request for deletion, we will also notify the entities from which we obtained your personal information to delete your personal information, unless otherwise required by law or regulation or unless those entities have been independently authorized by you. When you delete information from our services, we may not immediately delete the corresponding information from our backup systems but will delete the information when the backups are updated. Please know and understand that, in accordance with laws and regulations, if the retention period stipulated by laws and regulations has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing other than storing and taking the necessary security protection measures.

d) Withdrawal of consent

You have the right to withdraw your authorization, but the business function requires some basic personal information to be completed, and in the case of a service that relies on your authorization to be implemented or to function properly, we will not be able to continue to provide you with the corresponding service or part of the function of the service will be affected if you withdraw the relevant authorization. You may withdraw your consent by contacting us at via the contact details disclosed in this Privacy Policy.

When you withdraw the relevant authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your authorization will not affect the processing of personal information previously carried out based on your authorization.

e) Obtaining a copy of your personal information and portability

You have the right to obtain a copy of your personal information, and you may contact us using the contact information disclosed in this Privacy Policy.

Subject to the conditions of national laws and regulations and technical feasibility, we may also transmit a copy of your personal Information directly to a third party designated by you at your request if the data interface has been matched.

f) Account Cancellation

You may cancel your previously registered account at any time, and you may cancel your account by contacting us using the contact information disclosed in this Privacy Policy.

After canceling your account, we will stop providing you with products or services and delete your personal information upon your request, unless otherwise provided by law or regulation.

g) Responding to your requests

For security purposes, you may be required to submit a written request or provide other forms of identity verification. We may request identity verification before processing your requests, and responses will be provided within six working days. If you are not satisfied with our respondence, you may also initiate a complaint through the "How to contact us". In principle, we do not charge you for reasonable requests. However, repeated or excessive requests beyond reasonable limits may incur costs. We may refuse requests that are unnecessarily repetitive, require excessive technical means (e.g., require the development of a new system or a fundamental change in current practice), pose a risk to the legitimate interests of others, or are highly impractical.

E. How we process minors' personal information

Currently, we do not process personal information of minors.

F. Global transfer of your personal information

Since we provide products or services through resources and servers located around the world, this means that, with your authorized consent, your personal information may be transferred to, or accessed from overseas jurisdictions where the product or service is used. We will provide you with information in advance about the personal information protection requirements of foreign countries, measures taken by third parties to protect personal information, and other references in accordance with the regulations of the authorities.

Currently, the TSP is deployed in Singapore, and our cloud services operations and maintenance personnel who can access the system are in China. However, such jurisdictions may have different data protection laws, or even no laws at all. In such cases, we will ensure that your personal information is adequately protected and monitored.

If some of our services involve cross-border business and we need to transmit relevant personal information to overseas organizations, we will follow the laws and regulations and the provisions of the relevant supervisory authorities to inform you of the name and contact information of the overseas recipient, the purpose of the processing, the processing method, the types of personal information, and the ways and procedures for you to exercise your rights, and obtain your consent as well as signing of an agreement, on-site inspection and other effective measures, request the overseas organization to ensure the security of your personal information.

Our services will involve global transfer of your personal information under the following circumstances:

To ensure the stability and security of the products/services provided and to manage the products/services, your vehicle's VIN, vehicle location, name, email, contact information, T-box device number information is remotely accessed by Foton located in China. In order to provide real-time location and vehicle location functionality, your vehicle location information is transmitted to Google Maps located overseas.

Google Maps Privacy Policy:

https://developers.google.cn/maps/security/compliance/security-compliance.

G. How we update this Privacy Policy

Our privacy policy may be changed in needs.

We will not restrict your rights under this privacy policy without your explicit consent. For significant changes, we will provide prominent notice.

Significant changes referred to in this policy include, but are not limited to:

1. Significant changes in our service. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;

2. We experience significant changes in control, etc. Such as changes in ownership due to mergers and acquisitions, reorganizations, etc.;

3. Changes in the third parties and purposes for which personal information is entrusted processing, share, transfer or public disclose;

4. Significant changes in your rights to participate in the processing of personal information and how you exercise them;

5. Changes in the department responsible for the security of personal information, our contact details and complaint channels;

6. When the personal information security impact assessment indicates a high risk;

We will also archive an older version of this Privacy Policy for your review.

H. How to contact us

a) We have a team dedicated to the protection of personal information and a person responsible for the protection of personal information. If you have any questions about this policy or related matters, if you believe that our processing of personal information has harmed your legitimate rights and interests, you can contact us in the following ways, and we will review the issues involved as soon as possible;

1) Send your questions to e-mail address: customer@foton.com.cn

2) Send a mail: customer@foton.com.cn

b) Seek resolution by filing a lawsuit in a court of competent jurisdiction where the defendant is located.

The "Company" (hereinafter referred to as "we"), located at Shayang Road, Shahe, Changping District, Beijing, China.

We highly value and are committed to protecting the security of your personal information. When using our services, we may collect and use your relevant information. This "Privacy Policy" aims to explain to you how we will collect, use, store, share, and protect your information when you use our services, as well as to inform you of the ways in which you can access, update, and control the relevant information.

By default, we do not collect your personal information when the vehicle is delivered.

If you would like to use our Telematics service, you will need to be informed of the following:

1. We will collect your vehicle data.

2. In general, we will not link the collected data to your identity or account information. Therefore, apart from yourself, others cannot access your relevant data. Other activity data inside your vehicle is also protected.

3. We collect your personal data minimally, and the scope of data collection is limited to the information necessary for the normal use of the services we provide and for the optimization of the vehicle's functionality.

The following will help you understand in detail how we collect, use, transfer, disclose, and protect your personal information, as well as how we manage your relevant information and handle the personal information of minors. Important information about your personal information rights is highlighted in bold, so please pay special attention to it.

This Privacy Policy was updated and effective on 1st March 2024.

A. How we collect and use your personal information

B. How we entrusted processing, share, transfer, public disclosure your personal information

C. How we protect your personal information

D. How we manage your personal information

E. How we process minors' personal information of minors

F. Global transfer of your personal information

G. How we update this Privacy Policy

H. How to contact us

A.How we collect and use your personal information

a) We may collect and use data related to you or generated from your use of our location and big data-related services in the following two categories:

1. Personal Data

To register for some of the functionality we provide (e.g., the TSP) to achieve certain functions (e.g., creating an account), we collect your name, contact information, and email address from you. Such information will only be used for account registration. To protect your privacy, your name, contact information, and email address will be de-identified and your data will be stored in a standard encrypted format so that only the administrators of the functional platforms will have access to your information, and if you need to add, modify, delete, or change your information, you can contact us through the contact information disclosed in this Privacy Policy to exercise your rights.

2. Vehicle Data

To ensure continuous vehicle operation, predictive maintenance, and improve functionality and experience, the TSP provides vehicle management services (including Vehicle Location, Real-Time Positioning, Real-Time Data, Offline Vehicle, Vehicle Analytics, and Driving Analytics modules), Big Data Analytics (including Operations Analytics, Offline Analytics, Fault Alarms, and Operations Ranking modules), and Battery Management (Charging Reports, Driving Reports, Battery Monitoring, Battery Care). When using these features, your vehicle will collect and process vehicle location data, T-box device number, vehicle identification number (VIN), and vehicle data related to usage, operation, and status. This information is used to identify and resolve potential problems and to continually improve your vehicle and the services provided to you. To protect your privacy, such vehicle data will generally be stored in the following manner: VIN, T-box device number will be de-identified and your data will be stored in a standard encrypted format, including, but not limited to, the following:

We clearly define what vehicle data we do and do not collect. Vehicle data collected under the conditions of Singaporean law includes vehicle speed information, acceleration information, steering wheel turning angle, and other data used to identify issues and analyze vehicle performance. If you have any questions about the collection of your vehicle data or requests for non-collection of your vehicle operational data and any other requests related to the processing of your vehicle operational data, you can fulfill your rights by contacting us through the contact details disclosed in this Privacy Policy.

1) Location Data (High Precision Positioning): provide you with location services, we need your vehicle to use location data or geographic data to support location services and other functions. Location services may use GPS and ionospheric data to determine your location. To protect your privacy, location data will be processed online by the system, or processed in a form that cannot identify your personal information, or we cannot directly access it without your consent (unless required by Singaporean law). You can also contact us at any time to enable or disable this function.

2) Vehicle Basic and Operational Data: better provide you with data analysis features, keep our products and services up-to-date, troubleshoot or debug, and continuously improve, we strive to collect the minimum necessary diagnostic data to help ensure the security and normal operation of your vehicle. We may collect and store your vehicle's basic data, which may contain your VIN, T-box device number, and your vehicle's operating data (vehicle speed, steering wheel turning angle, vehicle braking status, brake pedal angle, throttle angle, fault information, etc.); data on any issues that could seriously affect the operation of your vehicle and data on any critical security issues will also be collected.

We understand that this Privacy Policy basically covers all data scenarios of the company collecting and using your personal information, but for specific details of information collection and usage rules that may be involved, we will further inform you in the privacy policy of specific products or services and obtain your consent. We assure you that we will not collect or use any of your personal information without your consent.

We assure you that if we make any changes to our collection of personal information, we will notify you by posting them on our website, and we will never collect any sensitive personal information that could cause others to discriminate against you.

b) We may collect and use personal information without obtaining your authorization in the following situations:

1. For your interest; necessary for any purpose that is clearly in the individual's interest; or necessary to respond to an emergency that threatens your life, health or safety or that of another individual;

2. For matters affecting the public: including where it is available from open sources, for the national interest, for archival or historical purposes only; for press events;

3. It is in our legitimate interests and our legitimate interests outweigh any adverse impact on the individual;

4. For business asset transactions, including mergers and asset transfers;

5. For business improvement purposes;

6. Collection and use of information disclosed by public authorities;

7. For public interest;

8. For research purposes (historical or statistical research).

c) Situations in which we obtain your personal information from third parties

Based on the reasonable requirements of fulfilling network operation security obligations, providing products/services to you, or improving the quality, experience, and security of product services, we will receive your personal information and other information (such as Vehicle Identification Number (VIN)) from affiliated companies and other trusted partners in accordance with legal regulations or your authorization. We will use your personal information according to agreements with third parties or this policy.

d) Rules for the use of your personal information

1、 We will use the collected personal information within the necessary scope to achieve the functions of our products and/or services as specified in this Privacy Policy.

2、 We keep statistics on the use of our products and/or services and may share these statistics with the public or third parties to show trends in the overall use of our products and/or services. However, these statistics do not contain any identifying information about you.

3、 When we use your personal information for purposes not specified in this Privacy Policy or when information collected for specific purposes is used for other purposes, we will ask for your consent in writing or electronically in advance.

B. How we entrusted processing, share, transfer, public disclosure your personal information

a) Entrusted Processing

In the scenarios of entrusted processing your personal information, we will sign the Data Processing Agreement with the entrusted party in accordance with the laws and regulations. We will require them to process your personal information within the necessary scope to achieve the purpose of use, in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures. We will supervise their personal information processing activities.

b) Share

We will strictly limit the sharing of personal information according to legal regulations. In general, we will not share your personal information externally. However, we will share your personal information with third parties in the following situations:

c) Transfer

We will not transfer your personal information to any company, organization or individual unless we have your explicit consent.

In the event of a merger, acquisition, or asset sale, we may transfer your personal information for the purposes of the transaction such as a merger, acquisition, or asset sale. Before transferring your personal information, we will provide you with appropriate notice and ensure that your personal information receives protection equivalent to that provided in this Privacy Policy.

d) Public disclosure

We will comply with relevant laws and regulations to keep your personal information confidential. We will not publicly disclose your personal information unless we have your explicit consent or authorization, or unless it is required by laws and regulations.

e) Exceptions

In the following, we share, transfer, and public disclose your personal information without obtaining your prior authorized consent:

1. It is an appropriate measure to realize the purposes related to the preparation of historical documents or archives in the public interest, or for purposes related to research or statistics, to safeguard your rights and freedoms, and in accordance with the notifications prescribed by the Commission;

2. For the prevention or suppression of danger to the life, body or health;

3. Necessary for the performance of a contract to which you are a party or for taking measures at the request of the data subject prior to the conclusion of the contract;

4. Necessary for us to carry out a task in the public interest or in the exercise of official powers vested in the data controller;

5. Necessary for the legitimate interests of any other person or legal entity other than us, unless such interests are overridden by your fundamental rights in relation to your personal data;

6. Necessary to comply with the laws to which we are subject.

7. In other situations stipulated by laws and regulations.

C. How we protect your personal information

1. Technical measures for data security

We will adopt security measures with industry standards, including the establishment of a reasonable system of norms, security technology to prevent unauthorized access to your personal information to use, modify, avoid data damage or loss.

The company adopts encryption technology to encrypt the transmission and storage of users' personal information. The company protects personal information by adopting strict data access rights control to avoid unauthorized use of data.

2. We only allow employees of the company and its affiliates who have a need to know such information to access personal information, and have set up strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill the corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of the relationship.

3. We recommend that you use email, instant messaging, social software, and other communication tools, with other users please use complex passwords, and pay attention to protect your personal information security.

4. Please note that the Internet environment is not completely secure, we will take security measures in accordance with the legal requirements and the level of technological development, and try our best to ensure the security of any information you send to us. But at the same time, if our physical, technical, or management protection facilities are subjected to unforeseen and preventive damage, resulting in unauthorized access, public disclosure, tampering, or destruction of information, we will not be responsible for any losses that are not caused by the company.

5. Security incident processing

Please protect your personal information properly and only provide it when necessary. The company has established systems to handle security incidents, categorizing and classifying security data, along with corresponding processing procedures. The company has also established a specialized emergency response team for security incidents, which activates security plans for different security incidents, stops damage, analyzes, locates, formulates remedial measures, and joins with relevant departments to trace and combat security incidents in accordance with the requirements of the security incident handling specifications.

After the occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently take to prevent and reduce the risk, and the remedial measures for you. At the same time, we will promptly inform you of the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make a public announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents to the supervisory authorities in accordance with legal requirements.

6. We have set up a specialized data security team responsible for carrying out work related to the protection of personal information. If you have any questions about our personal information protection, you can contact us through the contact information listed at the bottom of this privacy policy. If you find that your personal information has been compromised, especially your account and password, please contact us immediately through the contact information in this Privacy Policy and assist us in taking appropriate measures.

D. How we manage your personal information

In accordance with relevant Singaporean laws, regulations, and standards, as well as common practices in other countries and regions, we store your personal information for the shortest period necessary to achieve our business purposes, and we guarantee that you will exercise the following rights with respect to your personal information:

a) Access to your personal information

If you would like to access, review, or copy your personal information, you may access your personal information by contacting us in the "Contact Us" section below. Subject to certain exceptions, we may deny your request to the extent permitted by applicable laws and regulations. We reserve the right to adjust your request as described above in accordance with applicable laws and regulations.

We will transfer copies of your personal information to third parties designated by you at your request, subject to compliance with relevant legal requirements and technical feasibility.

b) Correcting or supplementing your personal information

You have the right to request that we correct or supplement the personal information we process about you if you discover that it is incorrect. You may make a request for correction or supplementation in the manner set out in this section "Access to your personal information". We will respond to your request within thirty natural days.

c) Delete your personal information

You can request the deletion of certain personal information through the methods mentioned in the "Access to your personal information" section.

In the following cases, you may make a request to us to delete your personal information:

1. If our handling of personal information violates laws and regulations;

2. If the purposes for which we process personal information have been achieved, cannot be achieved or are no longer necessary to achieve the purposes for which the processing was carried out;

3. If we collect or use your personal information without your consent;

4. If you withdraw your authorized consent;

5. If our processing of personal data constitutes a serious breach of our agreement;

6. If you no longer use our products or services, or if you voluntarily cancel your account;

7. If we permanently cease to provide products or services to you;

8. If the retention period of your personal information expires;

9. Other situations stipulated by laws and regulations.

Exception: We will not be able to completely delete your personal information if the retention period stipulated by laws and regulations has not expired or if deletion of personal information is technically difficult to achieve. However, we will stop storing and taking necessary security measures beyond the processing of personal information.

If you request the deletion of your personal information based on the circumstances described above, you may contact us at any time through the contact information set forth in this Privacy Policy, and we will respond within thirty natural days, unless otherwise required by law or regulation. If we decide to respond to your request for deletion, we will also notify the entities from which we obtained your personal information to delete your personal information, unless otherwise required by law or regulation or unless those entities have been independently authorized by you. When you delete information from our services, we may not immediately delete the corresponding information from our backup systems but will delete the information when the backups are updated. Please know and understand that, in accordance with laws and regulations, if the retention period stipulated by laws and regulations has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing other than storing and taking the necessary security protection measures.

d) Withdrawal of consent

You have the right to withdraw your authorization, but the business function requires some basic personal information to be completed, and in the case of a service that relies on your authorization to be implemented or to function properly, we will not be able to continue to provide you with the corresponding service or part of the function of the service will be affected if you withdraw the relevant authorization. You may withdraw your consent by contacting us at via the contact details disclosed in this Privacy Policy.

When you withdraw the relevant authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your authorization will not affect the processing of personal information previously carried out based on your authorization.

e) Obtaining a copy of your personal information and portability

You have the right to obtain a copy of your personal information, and you may contact us using the contact information disclosed in this Privacy Policy.

Subject to the conditions of national laws and regulations and technical feasibility, we may also transmit a copy of your personal Information directly to a third party designated by you at your request if the data interface has been matched.

f) Account Cancellation

You may cancel your previously registered account at any time, and you may cancel your account by contacting us using the contact information disclosed in this Privacy Policy;

After canceling your account, we will stop providing you with products or services and delete your personal information upon your request, unless otherwise provided by law or regulation.

g) Responding to your requests

For security purposes, you may be required to submit a written request or provide other forms of identity verification. We may request identity verification before processing your requests, and responses will be provided within thirty natural days. If you are not satisfied with our respondence, you may also initiate a complaint through the "How to contact us". In principle, we do not charge you for reasonable requests. However, repeated or excessive requests beyond reasonable limits may incur costs. We may refuse requests that are unnecessarily repetitive, require excessive technical means (e.g., require the development of a new system or a fundamental change in current practice), pose a risk to the legitimate interests of others, or are highly impractical.

E. How we process minors' personal information

Currently, we do not process personal information of minors.

F. Global transfer of your personal information

Since we provide products or services through resources and servers located around the world, this means that, with your authorized consent, your personal information may be transferred to, or accessed from overseas jurisdictions where the product or service is used. We will provide you with information in advance about the personal information protection requirements of foreign countries, measures taken by third parties to protect personal information, and other references in accordance with the regulations of the authorities.

Currently, the TSP is deployed in Singapore, and our cloud services operations and maintenance personnel who can access the system are in China. However, such jurisdictions may have different data protection laws, or even no laws at all. In such cases, we will ensure that your personal information is adequately protected and monitored.

If some of our services involve cross-border business and we need to transmit relevant personal information to overseas organizations, we will follow the laws and regulations and the provisions of the relevant supervisory authorities to inform you of the name and contact information of the overseas recipient, the purpose of the processing, the processing method, the types of personal information, and the ways and procedures for you to exercise your rights, and obtain your consent as well as signing of an agreement, on-site inspection and other effective measures, request the overseas organization to ensure the security of your personal information.

Our services will involve global transfer of your personal information under the following circumstances:

To ensure the stability and security of the products/services provided and to manage the products/services, your vehicle's VIN, vehicle location, name, email, contact information, T-box device number information is remotely accessed by Foton located in China. In order to provide real-time location and vehicle location functionality, your vehicle location information is transmitted to Google Maps located overseas.

Google Maps Privacy Policy:

https://developers.google.cn/maps/security/compliance/security-compliance.

G. How we update this Privacy Policy

Our privacy policy may be changed in needs.

We will not restrict your rights under this privacy policy without your explicit consent. For significant changes, we will provide prominent notice.

Significant changes referred to in this policy include, but are not limited to:

1. Significant changes in our service. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;

2. We experience significant changes in control, etc. Such as changes in ownership due to mergers and acquisitions, reorganizations, etc.;

3. Changes in the third parties and purposes for which personal information is entrusted processing, share, transfer or public disclose;

4. Significant changes in your rights to participate in the processing of personal information and how you exercise them;

5. Changes in the department responsible for the security of personal information, our contact details and complaint channels;

6. When the personal information security impact assessment indicates a high risk;

We will also archive an older version of this Privacy Policy for your review.

H. How to contact us

a) We have a team dedicated to the protection of personal information and a person responsible for the protection of personal information. If you have any questions about this policy or related matters, if you believe that our processing of personal information has harmed your legitimate rights and interests, you can contact us in the following ways, and we will review the issues involved as soon as possible;

1) Send your questions to e-mail address: customer@foton.com.cn

2) Send a mail: customer@foton.com.cn

b) Seek resolution by filing a lawsuit in a court of competent jurisdiction where the defendant is located.