Privacy Policy – ENOVATE

Vant Motors Privacy Policy

Vant Motors Ltd. and its affiliates (hereinafter referred to as “Vant Motors,” “we,” “us,” or “our”) understand the importance of personal information and privacy to you and will make every effort to protect the security of your personal information and privacy. We are committed to maintaining your trust and will protect your personal information by adhering to the following principles: the principle of accountability, purpose limitation, choice and consent, data minimization, transparency, security safeguards, and subject participation. At the same time, we promise to take corresponding security protection measures to protect your personal information in accordance with industry-standard security practices.

We will collect, use, store, and share your personal information in accordance with the provisions of this policy. Please read and understand this policy before submitting your personal information to us. Once you start using our services or provide us with your personal data, it means that you have fully understood and agreed to this policy. You are not obligated to provide us with personal information, but if you choose not to provide it, we may not be able to provide you with the relevant products or services.

This policy may not cover all possible data processing scenarios. Information about the collection of specific data for a product or service will be published by us in supplementary policies or in specific notices or policies provided at the time of data collection. Please pay attention to the prompts or notifications when you enable a specific function or use a specific product or service.

By reading this policy, you can learn about the following:

How Vant Motorscollects and uses your personal information.
How Vant Motorsuses Cookies and similar technologies.
How Vant Motorsshares, transfers, and publicly discloses your personal information.
How Vant Motorsprotects your personal information.
Your rights (access, query, correction, deletion, withdrawal of consent, account cancellation).
How Vant Motorshandles the personal information of minors.
Third-party links and their products and services.
Permission enabling.
How your personal information is transferred globally.
How this policy is updated.
How to contact Vant Motors.

How Vant MotorsCollects and Uses Your Personal Information

Personal information refers to any information recorded electronically or by other means that can be used alone or in combination with other information to identify a specific natural person or reflect the activities of a specific natural person. Such information is submitted directly by you when you use our websites, products, or services, or interact with us. We will only collect and use your personal information for the following purposes. When we intend to use the information for purposes not stated in this policy, we will seek your consent in advance. When we intend to use information collected for a specific purpose for other purposes, we will seek your consent in advance:
Purpose of Providing Basic Services: Including, but not limited to, creating your Vant Motors account, for which you need to provide your name, email address, username, and password. During account creation or acceptance of other services, providing additional information (e.g., job position, company, educational background) will help us provide you with better services and experiences, which may vary depending on the specific service you accept. However, if you do not provide this information, it will not affect your use of the basic functions of our services.

User Profiling and Customized Information/Services: Using your personal information for indirect user profiling analysis, sending you personalized promotional information, or providing you with customized services.

Purpose of Verifying Identity: Including, but not limited to, verifying your identity based on your basic information, assisting in identifying your age to determine the provision of appropriate services with your consent; additionally, with your consent, when you participate in lotteries, contests, or similar promotions, marketing activities, or market satisfaction surveys, we may use your basic information to manage such activities. If you do not wish to receive such information, you can unsubscribe at any time.
Purpose of Enhancing Human-Vehicle Interaction: Including, but not limited to, providing personalized settings based on your driving and vehicle usage habits when you use the vehicle; providing driver assistance safety prompts, such as fatigue driving warnings. You can decide to turn such prompts on or off based on your driving habits.
Purpose of Contacting You: Including, but not limited to, responding to your inquiries and requests as needed, conducting service follow-ups, and inviting you to participate in activities related to our products and services. If you do not wish to receive such information, you can unsubscribe at any time.
Providing you with our product releases/service upgrades/software upgrades; sending you information related to products/services you have purchased and changes to relevant terms/conditions/policies, which are crucial for your communication with us.
Purpose of Providing After-Sales Service: Including, but not limited to, remote location analysis when your vehicle malfunctions, providing timely rescue in the event of an accident, and loss assessment and underwriting during vehicle insurance incidents. You can decide whether to accept such services based on your driving situation.
Purpose of Vehicle Management and Safety Alerts: Locating and analyzing the operating status of your Vant Motors products to ensure availability and safety, and detecting and handling product or service faults. With your consent, sending you information related to vehicle management, safety, repair, maintenance, etc. You can decide whether to accept such services based on your driving situation.
Purpose of Improving Our Services: We may use information to understand how you access and use our services to respond to your personalized experiences and needs, such as personalized responses in language settings, location settings, help services, and instructions.
Purpose of Enhancing Vehicle Deep Learning Capabilities and Improving Related Algorithms: To provide you with a safer driving experience, improve service quality, optimize service functions, and facilitate the continuous improvement of advanced features such as automated driver assistance, we will collect data related to these purposes through in-vehicle cameras and sensors, including vehicle segment data, outdoor temperature, humidity, air quality, etc. We will collect different data based on different scenarios of your vehicle usage after obtaining your authorization. We ensure that such data is collected or shared in a way that cannot identify you or your vehicle.
For purposes required by laws, regulations, court rulings, other legal procedures, or competent government authorities.
When we consider it reasonably unnecessary to identify a specific individual to achieve any of the above purposes, we will anonymize such personal information. However, in any case, we may use or share information that cannot identify you personally for any legally permitted purpose.
Other Purposes: Purposes to which you consent; purposes related to account and network security; helping us create, develop, operate, provide, and improve our products, services, content, advertising, as well as loss prevention and anti-fraud purposes. We will only use your data for preventing, detecting, and investigating fraud, etc., if two conditions are met: it is absolutely necessary; and after assessment, the use of data aligns with our legitimate interests in protecting customers and services. For specific online transactions, we may also verify the information you provide through publicly available sources to fulfill your request, including participation in online or offline activities, or providing marketing materials for products or services at your request.
Channels for collecting this information include:
During use of the Vant Motors APP or access to the Vant Motors website: You can only use certain services or functions of the above platforms after registering as a formal user. For example, to facilitate our provision of better services including home test drives, you may need to provide us with your personal information, including but not limited to your name, address, telephone number, email, payment method, delivery address, etc.
During purchase of Vant Motors products or receipt of services from Vant Motors: Including your name, address, telephone number, email, payment method, delivery address, etc., to ensure accurate delivery of consultations and products; information generated during your process of learning about our products, ordering, and purchasing vehicles, such as information left when you participate in our online/offline activities, your vehicle order status, various sales and financial agreements directly related to vehicle purchase; your vehicle’s basic information, such as your license plate number, engine number, motor number, and other vehicle identification numbers; and information you provide during inquiries, such as search queries or questions/information provided to obtain customer support.
During use of Vant Motors products or receipt of services from Vant Motors: Including your location information, vehicle identification number (VIN), vehicle and component operating status, vehicle driving status, vehicle driving trajectory, partial in-vehicle image information collected when you actively initiate it, vehicle segment data, remote control service usage records, driver assistance usage, vehicle charging records and related information, roadside assistance situations, repair situations, operational situations during driving, application loading/unloading and usage, system upgrade status, information on external devices connected to the in-vehicle application platform, information on external storage devices connected to the in-vehicle application platform and their usage records. Additionally, as required by laws, regulations, and policies, we may need to monitor the following vehicle data, including but not limited to static vehicle information, dynamic vehicle data, drive motor data, vehicle data, traction battery data, engine data, vehicle location data, charging data, vehicle collision data, extreme value data, alarm data, etc., and other information required to be obtained/monitored according to the latest applicable laws, regulations, or government requirements.
Where permitted by law, we may obtain your personal information and other information from other legitimate sources, such as public or commercial sources. We may also collect other information about you, your Vant product, or service usage in other legally permitted ways, which will be specifically explained at the time of collection or subject to your consent.
When you use the following functions and services of the Vant MotorsAPP, we will collect the following personal information and other information related to you:

Register Account: When registering an account, you need to provide the following personal information: phone number. You may optionally provide an avatar, nickname, gender, date of birth, profile, city of vehicle use, and address information. You can also register an account by logging in via Weibo, WeChat, or other third-party accounts. We will require you to grant permission to obtain your avatar, nickname, region, gender, and other configuration information you authorize from the third-party account. For privacy controls, options, and specific privacy provisions within these third-party accounts, please refer to their privacy policies.

Circles: Photos, videos, text content, location information, and voting information you upload.

Chat: Nickname, phone number, and chat records.

Online Customer Service Consultation: Consultation records.

Schedule Test Drive: Test drive location, name, contact information.

Points Details: Total points and redemption records.

My Coupons: Coupon information.

Vehicle Orders & Service Orders: Name, ID number (or passport, military officer ID), license plate city, payment information, delivery location, delivery time, contact person information; history of vehicle orders, charging, repair, and roadside assistance service orders.

Public Charging, My Charging Pile: Name, phone number, vehicle VIN, installation time and geographical location, charging pile device ID, history of charging times, duration, electricity consumption, consumption amount per charge; real-time vehicle location.

My Car: Facial information, license plate number, vehicle location, emergency contacts, vehicle nickname, driving mileage, maximum charging limit settings.

We will, and only will, process your data based on appropriate legal grounds as required by applicable laws, including:
Responding to your service requests and processing your personal information;
Processing your personal information based on your consent;
Processing your personal information based on the execution of legal obligations or requirements of judicial, administrative, or other authorities.

How Vant MotorsUses Cookies and Similar Technologies

To ensure the normal operation of our websites, we store small data files called Cookies on your computer or mobile device. These files are created by your web browser software and stored on your hard drive or device to save information related to the website you are currently viewing. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of Cookies, websites can store your preferences or shopping cart items.

We enable Cookies for the same reasons as most websites or internet service providers: to enhance our information channels, improve user experience, and provide you with personalized services. Cookies help us optimize our website and your visit. These Cookies will remain on your computer or device until you clear them. For example, the language, font size, and other browsing preferences of your computer or mobile device. This means users do not need to reconfigure preferences each time they visit. If a website does not use Cookies, it will treat the user as a new visitor every time a page is opened. For example, if you log in to a website and then go to another page, the website will not recognize you, and you will be logged out again. We do not use Cookies for any purpose other than those described in this policy.

You can manage or delete Cookies according to your preferences. For details, please refer to AboutCookies.org. You can also clear all Cookies saved on your computer; most web browsers have the function to block Cookies. However, if you do so, you will need to manually change your user settings each time you visit our website.

In addition to Cookies, we also use web beacons, pixel tags, and other similar technologies on our websites. For example, emails we send to you may contain click URLs linking to Vant Motors website content. If you click such a link, we track this click to help us understand your product and service preferences and improve customer service.

A web beacon is typically a transparent image embedded in a website or email. With pixel tags in emails, we can determine if an email has been opened. If you do not wish your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.

Many web browsers have a Do Not Track (DNT) feature that can send a DNT request to websites. Currently, major internet standards organizations have not established policies stipulating how websites should respond to such requests. If DNT is enabled in your browser, all our websites will respect your choice.

How Vant MotorsShares, Transfers, and Publicly Discloses Your Personal Information

If certain services are provided by authorized partners of Vant Motors, we will share your personal information with that partner in accordance with the principles described in this policy. Where required by applicable law or to respond to legal process, we may also disclose your personal information to relevant law enforcement or other government authorities. Specific handling methods are as follows:

Sharing

Respecting user personal privacy is a fundamental principle of Vant Motors. Without your explicit consent, we will not share your personal information with any company, organization, or individual outside of Vant Motors, except in the following circumstances:

We may share your personal information as required by laws and regulations, or by mandatory requirements of government authorities.
Sharing with Affiliates, Third-Party Service Providers, and Authorized Partners: Only for the purposes stated in this policy, certain services will be provided by third-party service providers or authorized partners. We may share certain personal information with third-party service providers or authorized partners after obtaining your explicit consent to provide better customer service and user experience. We will only share your personal information for legitimate, proper, necessary, specific, and clear purposes. For example, when you purchase our products online or in person, we must share your information with logistics service providers to arrange delivery or arrange for partners to provide services. Our third-party service providers and partners may collect and use your personal information for specific purposes during your use of the services; please see the privacy policy of the information collector for details. Similarly, your information may be shared within our affiliated companies. We will only share your information within our affiliated companies for specific, clear, and legitimate purposes and will only share information necessary to provide the service. For example, during Vant account registration, we verify account uniqueness to prevent duplicate registration.
For companies, organizations, and individuals with whom we share personal information, we sign strict confidentiality agreements requiring them to handle personal information according to our instructions, this privacy policy, and any other relevant confidentiality and security measures. We will not share personally identifiable information about you with non-affiliated third parties who do not provide any services for their marketing purposes unless you choose to share it with them.
Transfer

Without your explicit consent, we will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

In the event of a merger, acquisition, or bankruptcy liquidation, if it involves the transfer of personal information, we will require the new holder of your personal information to continue to be bound by this privacy policy; otherwise, we will require that company or organization to seek your authorization and consent again.

Public Disclosure

Without your explicit consent or your active choice, we will not publicly disclose your personal information, except in the following circumstances:

Disclosure based on legal requirements: We may publicly disclose your personal information under circumstances required by law, legal proceedings, litigation, or mandatory government authorities. We may also disclose your data where reasonably necessary, such as to execute a contract, and where we believe disclosure is necessary and appropriate to prevent physical harm or property damage or to investigate possible or actual illegal activities.

You clearly understand and acknowledge that we do not need to obtain your authorization and consent to provide your personal information externally in the following circumstances:

Related to national security, public security, or significant public interests;
Related to criminal investigation, prosecution, trial, and execution of judgments, or required by public security organs, procuratorates, courts, industry and commerce administrations, or other competent authorities;
Necessary to protect the life, property, and other significant legitimate rights and interests of the personal information subject or other individuals, but difficult to obtain the consent of the individual;
The personal information collected is disclosed to the public by the personal information subject themselves;
Your personal information is collected from legally publicly disclosed information, such as through legitimate news reports, government information disclosure, and other channels;
Necessary for the conclusion or performance of a contract at your request;
Other circumstances stipulated by laws and regulations.

How Vant MotorsProtects Your Personal Information

We value your information security and use industry-standard security measures to protect the personal information you provide, preventing data from unauthorized access, public disclosure, use, modification, damage, or loss. For example, we ensure that only authorized and necessary personnel can access personal information; we have dedicated security personnel responsible for data security protection and assessment; we conduct security and privacy protection training to enhance employees’ awareness of the importance of protecting personal information; we employ encryption technology to ensure data confidentiality; we procure effective security protection solutions as encryption safeguards. We will do our best to protect your personal information, but please note that no security measure is 100% secure and perfect.
We will take all reasonably feasible measures to ensure that personal information unrelated to achieving specific purposes is not collected.
We will retain your personal information for the period necessary to achieve the purposes described in this policy. Our criteria for determining the retention period include: the necessary time to fulfill the business purpose for retaining personal information, including providing products and services, ensuring product and service security, responding to possible user inquiries or complaints, troubleshooting, and whether the user has consented to a longer retention period.
The internet is not an absolutely secure environment, and communication methods such as email and instant messaging may not be encrypted. We strongly recommend that you do not send your personal information through such methods. Please use complex passwords to help us ensure the security of your account.
If our physical, technical, or procedural safeguards are breached, resulting in unauthorized access, public disclosure, alteration, or damage to information, and causing damage to your legitimate rights and interests, we will bear corresponding legal liability.
In the unfortunate event of a personal information security incident, we will, as required by laws and regulations, promptly inform you of the basic situation of the incident, its possible impact, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedies for you. We will promptly notify you of the incident-related situation via email, letter, phone call, or push notification. If it is difficult to notify each personal information subject individually, we will adopt reasonable and effective means to publish an announcement. At the same time, we will also proactively report the handling of the personal information security incident to the supervisory authorities as required.

Your Rights (Access, Query, Correction, Deletion, Withdrawal of Consent, Account Cancellation)

You should ensure that all personal information submitted is accurate. We will strive to maintain the accuracy and completeness of your information and update this data promptly based on your instructions. In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee your exercise of the following rights regarding your personal information:

Right to Access: You have the right to access or understand and obtain the personal information we hold about you, except as otherwise provided by laws and regulations.
Some personal information may not be directly visible in your account information due to technical, storage, display, or other reasons. You can contact our customer service hotline at any time to inquire about relevant details. Generally, we will respond to your access request within one month.
For other personal information generated during your use of our products or services, we will provide it to you unless it requires disproportionate effort. If you wish to exercise your right of access, please contact our customer service.
Right to Correction: You have the right to request us to correct or update inaccurate parts of your personal information.
You can submit a correction request to us by email. Generally, we will respond to your correction request within one month.
Right to Withdraw Consent: Withdraw your authorization for us to use your personal information or refuse our continued access to your personal information.
Right to Deletion: You may request us to delete your personal information under the following circumstances:
If our processing of personal information violates laws and regulations;
If we collect or use your personal information without obtaining your consent;
If our processing of personal information violates our agreement with you;
If we terminate services and operations and no longer provide you with products or services;
If you no longer use our products or services or have canceled your account. When you delete information from our service centers, we may not immediately delete the corresponding information from the backup system but will delete it when the backup is updated.
Right to Change Scope of Authorization: You need to know that each business function may require some basic personal information to be completed. For the use of additionally collected personal information, you can give or withdraw your authorization at any time. After you withdraw consent, we will no longer process the corresponding personal information; however, your decision to withdraw consent will not affect the processing of personal information carried out previously based on your authorization.
Right to Cancel Account: You can cancel your registered account at any time by calling our customer service hotline. After canceling your account, we will stop providing you with products or services and, upon your request, delete your personal information, except as otherwise stipulated by laws and regulations.
Right to Restrict Automated Decision-Making: In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.
Right to Have Requests Addressed: Personal information subjects making requests should follow specific requirements. To ensure security, when you request information from us, we may require the information subject to do the following depending on the business scenario:
Submit the request through our dedicated personal information subject request channel (i.e., our customer service hotline);
Provide sufficient information for us to verify your identity (to ensure the requester is the personal information subject themselves or their authorized representative);
The request content must be specific and executable.

We generally do not charge a fee for reasonable requests. However, for repeated requests beyond a reasonable limit, we may charge a certain cost fee depending on the circumstances.

We will reject manifestly unfounded, excessive, or repetitive requests, or requests requiring disproportionate technical effort (e.g., requiring the development of new systems or fundamentally changing current practices), or those posing risks to the rights and freedoms of others, or those that are impractical.

Response Timeframe: Generally, we will respond within one month of receiving your request. Considering the complexity and number of requests, this period may be extended by a further two months if necessary.

Special Declaration

We will be unable to respond to your requests under the following circumstances:

The request is for information about another person;
The requested information was shared under conditions of confidentiality;
Directly related to national security or national defense security;
Directly related to public security, public health, or significant public interests;
Directly related to criminal investigation, prosecution, trial, or execution of judgments;
There is sufficient evidence to indicate that the subject has subjective malice or is abusing their rights;
Responding to the request would seriously harm the legitimate rights and interests of you or other individuals or organizations;
Involving trade secrets;
For requests that you repeatedly make beyond a reasonable limit and refuse to pay us the corresponding cost fee.

How Vant MotorsHandles the Personal Information of Minors

Our products, websites, and services are primarily aimed at adults. Particularly concerning vehicle driving, please strictly comply with traffic regulations and do not allow minors or adults without a driver’s license to drive vehicles.

Minors may not create their own user accounts without parental or guardian consent. For the collection of minor personal information with parental consent, we will only use or publicly disclose this information where permitted by law, with the explicit consent of the parent or guardian, or when necessary to protect the minor.

If we discover that we have collected personal information from a minor without prior verifiable parental consent, we will endeavor to delete the relevant data as soon as possible.

Third-Party Links and Their Products and Services

Our products may contain other third-party SDKs. When you use services provided by such third parties on our platform, you agree that your information will be collected and processed directly by them. To maximize the protection of your information security, we strongly recommend that you review the privacy terms of any third-party SDK service before using it. To protect your legitimate rights and interests, if you find that such SDKs or similar applications pose risks, we advise you to immediately terminate the relevant operation and contact us promptly. Examples of situations involving embedded third-party SDKs transmitting personal information include:

Our websites, in-vehicle products, app market, APP, and smart services may contain links to other third-party websites, products, and services. Our APP STORE may also list third-party applications. You need to understand that we have no control over third parties; these links are provided solely to enhance user experience and convenience. We also do not provide any express or implied warranty regarding linked content; we cannot control third-party privacy or data protection policies, and such third parties are not bound by this policy. During the operation of third-party products or services, you may be required to provide personal information. You should understand that the entity collecting the information at that time is not Vant Motors. Before submitting your personal information to a third party, please carefully read and understand that third party’s privacy policy.

Permission Enabling

To provide related products and services, we need you to authorize the enabling of the following relevant permissions to collect related information. If you refuse to enable relevant permissions, you may not obtain related functions or services.

Location Permission: When you use location-related functions in the Vant Motors App’s social platform services or vehicle charging services, we may need to enable your mobile device’s location permission.

Camera or Photo Album Permission: When you upload an avatar via the Vant Motors App or upload pictures/videos using the social platform service, we may need to enable your mobile device’s camera or photo album permission.

Microphone Permission: When you use the Vant Motors App customer service chat system or upload videos, we may need to enable your mobile device’s microphone function.

Phone Call Permission: When you contact customer service using the Vant Motors App, we may need to enable your mobile device’s phone call function.

Contacts Permission: When you share a vehicle Bluetooth key with friends using the Vant Motors App, we may need to enable your mobile device’s contacts permission.

Bluetooth Permission: When you use Vant Motors App for vehicle-to-vehicle communication, we may need to enable your mobile device’s Bluetooth function.

Storage Permission: When setting an avatar, using customer service, commenting or sharing, image recognition, downloading files locally, or opening/using local files, you can use or save pictures, videos, or files by enabling storage permission. If you do not enable this permission, you will be unable to use functions related to reading or caching storage cards, but this will not affect your use of other services.

Biometric Permission: You can enable biometric permissions (FaceID or fingerprint) in the Vant Motors APP to replace entering a security password. Biometric permission verification or security password verification will be required in security-sensitive operation scenarios (e.g., sharing vehicle keys). During this process, we do not collect your biometric features themselves; we only obtain the verification result provided by the hardware service provider based on your authorization.

How Your Personal Information is Transferred Globally

Information Storage: We store your personal information on servers and public clouds located within China. This personal information usually will not be transmitted cross-border outside of China (regardless of where you use our products).

In principle, personal information collected and generated within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China. If your personal information may be transferred to jurisdictions outside the country/region where you use the product or service, or accessed from such jurisdictions, we will obtain your authorization and consent. Such jurisdictions may have different data protection laws or even lack relevant laws. In such cases, we will ensure that your personal information receives protection equivalent to that within the People’s Republic of China. For example, we will request your consent for the cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

Retention Period: We will retain your personal information for the shortest period within the scope stipulated by law and the period necessary to achieve the purposes described in this privacy policy. After the above period expires, we will delete your personal information or anonymize it.

How This Policy is Updated

We reserve the right to update or modify this policy from time to time. We will not reduce your rights under this privacy policy without your explicit consent. We will post any changes to this policy on this page. For significant changes, we will provide more prominent notice (including, for certain services, sending notifications via email, customer service hotline, or SMS, explaining the specific changes to the privacy policy).

Significant changes referred to in this 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 way personal information is used.
Significant changes in our ownership structure, organizational structure, etc., such as changes in ownership due to business adjustments, bankruptcy, mergers and acquisitions, etc.
Changes in the main objects with whom personal information is shared, transferred, or publicly disclosed.
Significant changes in your rights regarding personal information processing and how you exercise them.
Changes in our contact details and complaint channels for handling personal information security.
When a personal information security impact assessment report indicates high risk.