This privacy agreement applies to all products and services provided by Zhejiang E-TWOW Electric Vehicle Co., Ltd. (hereinafter referred to as "us"). We highly value the privacy protection of our users and are committed to explaining to you through clear and explicit terms how we collect, use, store, share, and protect your personal information. Please carefully read this privacy agreement and ensure that you fully understand and agree to the relevant content before using our products and services. If you do not agree to any terms of this agreement, please do not use our products and services.
Personal information: refers to various information recorded in electronic or other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information, including but not limited to name, ID number, contact information, address, date of birth, gender, occupation, educational background, health information, financial information, etc.
Personal sensitive information: personal information, such as ID card number, biometric information, bank account number, transaction code, health information, etc., which may endanger personal and property safety and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment, if disclosed, illegally provided or abused.
Affiliated company: refers to any company, enterprise, or other legal entity that is currently or will be controlled, controlled, or under common control with a party. "Control" refers to the ability to directly or indirectly influence the management of the mentioned company, whether through ownership, voting shares, contracts, or other legally recognized means.
Registration and login information: When you register or log in to our products or services, we will collect the account information you provide, such as username, password, phone number, email address, etc.
Service usage information: During your use of our products or services, we will automatically collect the following information:
Interaction and feedback information: If you interact with us through our customer service channels, feedback forms, comment areas, survey questionnaires, etc., we will collect the relevant information you provide, including but not limited to problem descriptions, suggestions, opinions, evaluation content, etc. These pieces of information help us understand your needs, improve product and service quality, and promptly address any issues you may encounter.
Third party information sharing: We may obtain some of your personal information from legitimate third-party partners, but only with your explicit authorization or permitted by laws and regulations. For example, we may obtain your order information, logistics information, etc. from our partners in order to provide you with a more complete service experience. We will require third parties to comply with strict privacy protection regulations to ensure the security of your information.
When you use "E-TWOW", we may need to invoke some of your device permissions. We will obtain your consent separately in the form of a pop-up window before invoking the corresponding permissions for the first time. You can choose to disable some or all permissions under the device's settings or similar functions according to the specific guidelines of your mobile operating system. If you close/reject these authorizations, we will no longer continue to collect and use your corresponding information, nor will we be able to provide you with the functions corresponding to these authorizations mentioned above.
| Permission | Scenario/Service | Purpose | Information Collected | Impact of Disabling |
|---|---|---|---|---|
| Location | (1) View maps and trajectories (2) View cycling data | View map trajectories and cycling data | Location information, cycling data | Unable to view map trajectories and cycling data |
| Bluetooth | Connect devices via Bluetooth to view maps and trajectories | View map, trajectory, and vehicle status information | Location information, trajectory information, vehicle information | Unable to connect to view maps, trajectories, data, and operations |
| Storage | (1) Post content with photos and audio on "social functions" (2) Send audio messages | Upload photos and audio files | Photos, audio and video files | Unable to publish audio and video posts |
| Camera | (1) Post content with photos and audio (2) Send audio messages | Take photos and audio/video recordings | Photos and videos | Unable to publish audio and video posts |
| Network | Use social media to post, register, and connect devices | Posting social content and uploading pairing information | Network information | Unable to log in, social functions unavailable |
Providing products and services: We use the collected personal information to provide you with various products and services, including but not limited to account management, content display, feature implementation, customer support, etc. For example, displaying vehicle information. When the device is connected via Bluetooth, your vehicle information will be displayed, and you can check the device information through our application, such as speed, mileage, battery information, firmware model, and other functions.
Improving and optimizing products and services: By analyzing the collected information, we can understand users' usage habits, needs, and preferences, and thus improve, optimize, and innovate products and services. For example, optimizing product interface design, improving functional performance, launching new features or services that better meet user needs, etc.
Legal compliance and dispute resolution: Subject to compliance with laws and regulations, we may use personal information for legal compliance purposes, such as responding to legal litigation, administrative procedures, regulatory requirements, etc. Meanwhile, when dealing with disputes or controversies with you, we may use relevant information for investigation and resolution.
Storage location: We will store your personal information within the territory of the People's Republic of China. If it is necessary to transfer some information to overseas storage or processing due to business needs, we will strictly comply with relevant laws and regulations, take necessary security measures, ensure that your personal information is fully protected, and obtain your explicit consent in advance.
Storage period: We will only store your personal information for the shortest time necessary to achieve the purposes described in this privacy agreement. After exceeding the storage period, we will delete or anonymize your personal information, except as provided by laws and regulations. For example, after you cancel your account, we will delete or anonymize your personal information in accordance with relevant regulations; For transaction records and other information, we may store them according to the retention period required by laws and regulations.
Sharing: We will not share your personal information with other third parties unless:
Transfer: We will not transfer your personal information to any third party unless we have obtained your explicit consent in advance. In the event of major transactions such as company mergers, divisions, acquisitions, and asset transfers involving the transfer of personal information, we will ensure that the new recipient continues to fulfill the protection obligations stipulated in this privacy agreement in accordance with legal requirements, and promptly notify you of relevant changes.
Public Disclosure: We will not publicly disclose your personal information unless we have obtained your explicit consent or, in accordance with laws and regulations or the requirements of authorized authorities, make necessary public disclosures. For example, in cases involving legal litigation, investigations, etc., information disclosure is required by the court or relevant law enforcement agencies.
Security technology measures: We adopt various security technology measures to protect your personal information security, including but not limited to data encryption, access control, firewall settings, intrusion detection and defense systems, etc. For example, encrypting and storing your sensitive information to ensure confidentiality during transmission and storage; By setting strict access permissions, only authorized personnel can access your personal information.
Security Management System: We have established a comprehensive information security management system, clarifying the responsibilities and authorities of various departments and personnel in information security management, and standardizing the operational processes of information collection, use, storage, sharing, and other aspects. Regularly provide information security training to employees to enhance their security awareness and operational standards, and prevent information leakage or abuse caused by human factors.
Emergency response mechanism: We have developed an emergency response plan for information security incidents, so that timely measures can be taken to respond in the event of an information security incident and reduce the impact of the incident on you. Once an information security incident occurs, we will immediately activate the emergency plan, investigate and handle the incident, and promptly notify you of the relevant situation and the measures we have taken in accordance with the requirements of laws and regulations.
Children's personal information protection: We attach great importance to the protection of children's personal information. If you are a child under the age of 14, you should carefully read this privacy agreement with your parents or other guardians before using our products and services, and use our products and services with the consent of your guardians. For the collection, use, and protection of children's personal information, we will comply with the requirements of relevant laws and regulations such as the "Regulations on the Protection of Children's Personal Information on the Internet" and strictly fulfill our protection obligations. If we discover that we have collected personal information from children without obtaining valid consent from their guardians, we will immediately delete the relevant information.
Minors' information processing: For minors who are over 14 years old but under 18 years old, we also take appropriate protective measures to ensure the security and lawful use of their personal information. When collecting and using personal information of minors, we will take corresponding measures to protect their rights based on their age and cognitive ability.
Agreement changes: We may revise this privacy agreement based on changes in laws and regulations, business development needs, or other reasonable reasons. The revised privacy agreement will be published on our official website, products, or services, and the date of publication will be the effective date of the agreement. If the revised content involves significant changes to your personal information rights, we will notify you through more prominent means, such as pop-up prompts, internal message notifications, SMS notifications, etc.
User Notice: After the privacy agreement is changed, if you continue to use our products and services, it will be deemed that you agree to be bound by the changed privacy agreement. If you do not agree with the revised agreement, you have the right to stop using our products and services and exercise your relevant rights in accordance with the provisions of this agreement.
If you have any questions, suggestions or complaints about this privacy agreement, or need to exercise your personal information rights, please contact us through the following methods:
We will contact you as soon as possible after receiving your feedback and process and reply to your question within 15 working days. If the processing time needs to be extended due to special circumstances, we will inform you promptly.
Last Updated: November 6, 2025
Effective Date: November 6, 2025