User Privacy Policy

Update Date: March 4, 2025

Effective Date: March 4, 2025

We highly value the protection of users' personal information. We have updated the User Privacy Policy, streamlined its content, and optimized it based on actual circumstances to make it easier for users to understand how we handle and protect your personal information in a clear and transparent manner. This revision will not affect the current level of protection and handling of your personal information.

Introduction

App Name: {appName} ("the App", "we", "us", or "our")

We are committed to protecting users' personal information and privacy. This privacy policy aims to explain how we collect, use, store, share, and protect your personal information, as well as how you can exercise your rights.

We provide products/services through the user App and may also do so through other clients or scenarios in the future, which may involve the processing of your personal information. This privacy policy is closely related to your use of our products/services. The collection and processing of personal information may vary depending on the specific product/service scenario. Please refer to the specific scenario of the product/service you are using. We strongly recommend that you  carefully read and ensure that you fully understand the content of this privacy policy  before using our products/services, so that you can make appropriate choices based on the guidance provided in this policy.

We will follow this privacy policy and collect and use your information when you use the corresponding products/services. However, we will not forcibly bundle the collection of personal information solely because you agree to this privacy policy. The actual collection will depend on the specific product/service you use. If a specific product/service has a separate privacy policy, that separate policy will take precedence. We strive to use concise and easy-to-understand language, so please read carefully.

If you have any questions, comments, or suggestions regarding this privacy policy, you can contact us through the contact information provided in the "Contact Us" section of this policy.

This privacy policy will help you understand the following:

1. Collection and Use of Personal Information

2. Disclosure and Sharing of Personal Information

3. Storage and Protection of Personal Information

4. Use of Cookies and Similar Technologies

5. Your Rights Regarding Personal Data

6. Updates to the Privacy Policy

7. Contact Us

1. Collection and Use of Personal Information

We adhere to the principles of legality, legitimacy, and necessity. Based on the purposes outlined in this privacy policy, we collect and use your personal information that you provide voluntarily or that is generated through your use of our products/services, as well as information obtained from third parties with your authorization, to fulfill your enjoyment of our products/services, communicate with you, and improve or optimize our products/services.

As our business evolves, the products/services we offer may be adjusted or changed. If we intend to use your personal information for purposes not specified in this privacy policy, or use information collected for a specific purpose for other purposes, unless there is another legal basis or legitimate reason for processing your personal information, we will inform you in a reasonable manner and obtain your consent again before such use.

The following table lists the various scenarios in which the App collects information and the corresponding types of information collected:

2. Disclosure and Sharing of Personal Information

(1) External Provision

We treat your personal information with a high degree of diligence. Unless we have obtained your authorization or consent, or unless required by applicable laws and regulations, we will not provide your personal information to any company, organization, or individual outside of our company.

Some of our products/services require the participation of third parties to be completed. Therefore, we may provide your personal information to our affiliates and third-party service providers or partners to ensure and optimize the products/services we provide to you. We will strictly limit and manage the external provision of personal information in accordance with laws and regulations. For scenarios where we entrust third parties to process your personal information, we will sign relevant processing agreements with the entrusted parties, requiring them to process your personal information in accordance with our requirements and this privacy policy, and we will supervise their personal information processing activities. For scenarios where we share your personal information externally, we will share your personal information based on the principles of legality, legitimacy, and necessity, as outlined in this privacy policy.

• Obtain your explicit consent or authorization in advance.

• Achieve product/service functionality.To achieve product capabilities or provide services to you, we will provide your personal information to the following third parties.

  • Our affiliates: We will share your information among affiliates that follow unified management, control, or have significant interests, and such sharing will be bound by the purposes stated in this privacy policy. If our affiliates change the purpose of personal information processing, they will seek your authorization and consent again.
  • Third-party service providers or partners:For example, third parties that enable App or vehicle functionalities. For third parties with whom we share personal information, we will limit the scope to what is necessary to achieve the purpose of cooperation. We will sign corresponding personal information protection agreements or clauses with them, requiring them to process and protect your personal information in accordance with the agreement between us and this privacy policy. We will also require them not to use this information for any other purpose and to take sufficient security measures to protect the information we share.
• Provide information in accordance with applicable laws, regulations, administrative or judicial requirements.  For example: ① Provide your information in accordance with laws, regulations, legal procedures, or the requirements of competent administrative and judicial authorities; ② Conduct necessary vehicle data monitoring as required by laws and regulations.
• Handle disputes or controversies between you and others at your request.
• Protect rights.To the extent required or permitted by laws and regulations, to protect the interests, property, or safety of us, our affiliates or partners, you or other users, or the public from harm, and when it is necessary to provide such information.

(2) Public Disclosure

We will comply with relevant laws and regulations and keep your personal information confidential. We will not actively disclose your personal information that you have not made public yourself, unless required by laws and regulations or with your separate consent.

3. Storage and Protection of Personal Information

(1) Data Storage Description

In accordance with laws and regulations, we store your personal information collected and generated during our operations within the Southeast Asia data center. We will not transfer your personal information to other regions. If we need to transfer your personal information overseas, we will strictly comply with relevant laws, regulations, and policy requirements, or seek your separate authorization and consent.

We will retain your personal information only for the period necessary to achieve the purposes stated in this privacy policy, unless otherwise stipulated by laws and regulations or with your separate authorization and consent. Depending on the product/service you use, the retention period of your personal information may vary. We determine the retention period of personal information based on the following criteria:

• To fulfill the purposes related to the products and services provided to you, maintain corresponding product and business records, and respond to your possible queries or complaints;
• To ensure the security and quality of the services we provide to you;
• Whether you have agreed to a longer retention period;
• According to the requirements of the statute of limitations;
• Whether there are other special agreements or legal provisions regarding the retention period.

After the retention period expires, we will delete or anonymize your personal information.

(2) Data Protection Measures

We attach great importance to the security of your personal information. We have adopted reasonable and feasible security protection measures that comply with industry standards to protect your information from unauthorized access, public disclosure, use, modification, damage, or loss. For example, we use encryption technology to enhance the security of personal information. Data exchanged between your browser and our server is protected by SSL protocol encryption, and we provide HTTPS protocol for secure browsing. We use trusted protection mechanisms to prevent personal information from being maliciously attacked. We deploy access control mechanisms to ensure that only authorized personnel can access personal information. We also conduct information security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

(3) Security Incident Response

In the unfortunate event of a personal information security incident, we will immediately establish a dedicated emergency response team, activate an emergency plan to prevent the incident from escalating, and notify you in accordance with legal requirements: the basic information of the security incident and its potential impact, the measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures for you. We will promptly inform you of the incident via email, letter, phone, push notification, etc. If it is difficult to notify you individually, we will take reasonable and effective measures to issue a public notice. At the same time, we will proactively report the handling of the personal information security incident to regulatory authorities as required.

(4) Special Reminder

The internet is not an absolutely secure environment. We strongly recommend that you use secure methods and complex passwords to help us ensure the security of your account. If you find that your personal information has been leaked, especially if your account or password has been compromised, please contact us immediately through the contact information provided in this privacy policy so that we can take appropriate measures.

We also ask for your understanding that, due to technical limitations and the existence of various malicious means, even with our best efforts to strengthen security measures, we cannot always guarantee 100% security of information in the internet environment.

4. Use of Cookies and Similar Technologies

Cookies and similar device identification technologies are commonly used on the internet. When you use our products/services, we may use related technologies to send one or more Cookies or anonymous identifiers ("Cookies") to your device to collect, identify, and store information about your access and use of our products/services. We use Cookies mainly to ensure the security and efficient operation of our products and services, help you have a smoother access experience, improve our services, and simplify the steps and processes of filling out forms. We will not use Cookies for any purposes other than those stated in this privacy policy.

You can manage or delete Cookies based on your preferences. Most browsers automatically accept Cookies, but you can usually modify your browser settings to reject Cookies. Additionally, you can clear all Cookies saved in the software, but you may not be able to use certain features or services that rely on Cookies.

5. Your Rights Regarding Personal Data

(1) Access, Copy, Correct, Supplement, or Delete Your Personal Information

• Access:If you wish to access your personal information, you can contact us through the contact information provided in the "Contact Us" section of this privacy policy or log in to your App account and access the following:

  • Access account personal information, including profile picture, nickname, gender, etc., in "My → Personal Information";
  • View account binding information, including phone number and email address, in "My → Account Details → Account Management";
  • Set payment management information (including whether to enable automatic payment) in "My → My Wallet → Payment Settings";
  • Access your wallet balance and income/expense records in "My → My Wallet → My Bills";
  • Access vehicle orders, mall orders, and energy replenishment orders, including order type, order status, order time, transaction and consumption records(transaction amount, order number) in "My → My Orders";
  • Access your historical charging/swapping records, including charging/swapping time, status, station, battery information, etc., in "My → My Orders → Energy Replenishment Orders."
• Copy: If you wish to copy the personal information we have collected about you, you can contact us through the contact information provided in the "Contact Us" section of this privacy policy to request a copy. In compliance with relevant laws and regulations and where technically feasible, we will provide you with a copy of the corresponding personal information after verifying your identity. If you request to transfer your personal information to a designated personal information processor, we will provide the transfer method if it complies with national regulations and is technically feasible.

• Correct or Supplement:If you find that the personal information we process about you is incorrect or incomplete, you have the right to correct or supplement the information after we verify your identity, provided that the correction or supplement does not affect the objectivity and accuracy of the information. You can contact us through the contact information provided in the "Contact Us" section of this privacy policy to request a correction or supplement, or you can correct or supplement your personal information collected through the App by logging in to your App account and accessing the following:

  • Correct or supplement personal information: Correct or supplement your profile picture, nickname, gender, etc., in "My → Account Details."
  • Correct or supplement account binding: Correct or supplement whether you need to bind an email or phone number in "My → Account Details → Account Management."
  • Correct or supplement service security password: Correct or supplement your account login password in "My → Account Details → Account Management → Password Management."
  • Correct or supplement vehicle information: Correct or supplement your vehicle nickname or license plate number in "My Car → My Vehicles → Vehicle Information."

• Delete: Under the following circumstances, you can contact us through the contact information provided in the "Contact Us" section of this privacy policy to request the deletion of your personal information. However, this does not apply to information that has been anonymized or where laws and regulations stipulate otherwise. We will verify your identity and ask you to specify the type of personal information to be deleted. We will decide whether to respond to your request based on laws, regulations, and regulatory requirements:

  • If the purpose for which we process your personal information has been achieved, cannot be achieved, or is no longer necessary;
  • If we stop providing the relevant products or services, or the retention period for personal information has expired (e.g., if you no longer use our products/services or have deleted your account);
  • If you withdraw your consent;
  • If our processing of personal information violates laws, regulations, or our agreement with you;
  • Other circumstances stipulated by laws and regulations.

When you delete or request the deletion of personal information from our services, due to the minimum retention period required by laws and regulations and technical limitations, we may not immediately delete the corresponding information from our backup systems. We will only store the information and will not use it for other purposes until the legal retention period expires. At the same time, we will not process the information other than storing it and taking necessary security protection measures.

(2) Manage Your Authorization Scope

Each product/service function requires some basic personal information to be completed. For personal information collected and used with your authorization and consent, you can give or withdraw your authorization and consent at any time. You can contact us through the contact information provided in the "Contact Us" section of this privacy policy to withdraw your consent, or you can view or modify the authorization scope of your device permissions in the App through the App permission settings on your phone.

Please understand that since each function and service requires corresponding necessary personal information to be completed, when you withdraw your consent or authorization, we will no longer be able to provide you with the corresponding product/service functions, and we will no longer process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the previous processing of personal information based on your consent or authorization.

(3) Delete Your App Account

You can delete your user account through "My → Account Details → Account Management → Delete Account." During the deletion process, you need to unbind all bound devices. If you are renting a device, you need to return it before you can delete your account.

After you delete your account, we will stop providing you with our products/services. Unless otherwise stipulated by law, account deletion may result in the permanent loss of all your user data and account information.

After you delete your account, we will delete your personal information or anonymize it in accordance with applicable laws and your specific requests.

(4) Respond to Your Requests

We generally do not charge a fee for reasonable requests from you. However, for repeated requests or requests that exceed reasonable limits, we may charge a certain cost fee depending on the situation. For requests that are unfounded, repetitive, require excessive technical means (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are impractical (e.g., involving information stored on backup tapes), we may refuse to comply.

6. Privacy Policy Updates

To provide you with better services, as our business evolves, this privacy policy will also be updated in a timely manner.

We will not reduce your rights under this privacy policy without your explicit consent. We will issue updated versions and notify you of the updates through announcements or other appropriate means before they take effect. Please check the App regularly to stay informed about the latest privacy policy. If there are significant changes to this privacy policy, we will provide more prominent notices, such as pop-up windows, SMS, or direct emails when you log in to the App.  Significant changes to this privacy policy include but are not limited to:

• Significant changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and the ways personal information is used;
• Significant changes in our ownership structure or organizational structure, such as business adjustments, bankruptcy, mergers, etc., leading to changes in ownership;
• Changes in the main objects of personal information sharing, transfer, or public disclosure;
• Significant changes in your rights and how you exercise them regarding personal information processing;
• Changes in the department responsible for personal information security, contact information, and complaint channels;
• When a personal information security impact assessment report indicates a high risk.

7. Contact Us

We have established a dedicated personal information and data security management team with a designated responsible person. If you have any questions about this privacy policy, or if you have any complaints or suggestions regarding the processing of your personal information, please contact us through the following channels, and we will respond as soon as possible.

Email of the person in charge of personal information protection: pony@scin-power.com