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Privacy Policy of ROX Auto

Version publication and effective date: May 6, 2025

Shanghai Xuanwuyan Intelligent Technology Co., Ltd. (registered address: Unit 1701, No. 25, Lane 1688, Guoquan North Road, Yangpu District, Shanghai), Qingdao ROX Automobile Sales Co., Ltd. (registered address: ZC412, No. 12, Laiwu Second Road, Shinan District, Qingdao, Shandong Province), Shanghai Xuelawan Automobile Sales and Service Co., Ltd. (registered address: Room 4625, 4th Floor, No. 8, Lane 458, Yichang Road, Putuo District, Shanghai) (hereinafter referred to as "ROX Auto" or "We") fully understand the importance of personal information to users (or "You"), and will strictly comply with legal and regulatory requirements to protect your personal information and privacy security. Based on this, in accordance with the Cyber Security Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China, the Data Security Law of the People's Republic of China and other laws and regulations, and with reference to national standards such as the Information security technology—Personal information security specification (GB/T 35273-2020), we have formulated the "Privacy Policy of ROX Auto" (the "Privacy Policy"). This privacy policy aims to explain how we collect, use, store, share, and protect your personal information, as well as how you exercise your rights.

You understand and agree that we provide you with ROX products/services through the official website of ROX Auto, ROX APP, ROX Mini Program, ROX offline stores, and in other customer terminals or scenarios now or in the future. When you use ROX products/services, we may process personal information related to you. 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 in which you use our products/services. Before using our products/services, please carefully read and confirm that you have fully understood the content stated in this privacy policy.

If you have any questions about this privacy policy or related matters, you can contact us through the contact information stated in Article Ⅷ "How to contact us". Thank you for your understanding and support. This privacy policy will help you understand the following content:

Ⅰ. How do we collect and use your personal information

Ⅱ. How do we use Cookies and similar technologies

Ⅲ. How do we entrust to process, share, transfer and publicly disclose your personal information

Ⅳ. How do we protect and store your personal information

Ⅴ. How do you manage your personal information

Ⅵ. How do we handle information about minors

Ⅶ. Update and revision of this privacy policy

Ⅷ. How to contact us

Ⅰ. How do we collect and use your personal information

We will adhere to the principles of legality, justice, and necessity, and collect and use your personal information provided by you in the process of using products/services or generated by using products/services, and obtained from third parties with your authorization, based on the following purposes stated in this privacy policy, to provide you with, optimize our services, and ensure the security of your account.

Please pay special attention to our bold or bold and underlined content. For sensitive personal information specified in laws and regulations, we will highlight such information in bold and underline; For personal information specified in laws and regulations, we will highlight such information in bold.

Please understand that with the continuous iteration and update of products/services, the types of personal information we need to collect and the purpose of processing may change. If we intend to use your personal information for other purposes not specified in this privacy policy, or collect information of specific purposes for other purposes, we will inform you in a reasonable manner and obtain your consent before use, unless there are legal reasons clearly defined by law.

(Ⅰ) Information from or about you

Scenarios for our products/services to collect and use personal information include:

1. Account registration and login

You can use your ROX account to log in to the ROX APP and ROX Mini Program.

When you register a ROX account through the ROX APP or Mini Program, according to the requirements of the network real-name system, we will collect your mobile phone number and verify your identity by sending a SMS verification code. When you log in to ROX account, we will collect your mobile phone number and SMS verification code so that you can log in and use our products and services normally.

You can also use a third-party platform account to register and log in to the ROX APP. We will obtain third-party account information (your avatar, nickname, mobile phone number) authorized by you for quick login. At the same time, we will collect your mobile phone number and SMS verification code to create a ROX account for you and bind the third-party account.

When you register and log in to ROX account through the ROX Mini Program, we will obtain your mobile phone number from a third-party platform, so as to verify your identity and facilitate your normal login and use of our mini program.

If you do not want to register and log in, you can choose guest mode to enter the ROX APP or ROX Mini Program to view some content. In guest mode, you do not need to provide the above information.

2. Personal information

In order to display your personal information, you can fill in/supplement/modify your personal information (nickname, avatar, gender, birthday, region, introduction) on the ROX APP. The specific information is subject to the page display. You can decide whether to fill in or modify your personal information. When you modify your avatar, we will use your camera permission or album permission/storage permission for taking photos or selecting images from the album and upload them as your avatar. When you modify your region, we will call your location permission. If you do not agree with us to call your location permission, you can also manually choose to modify the region.

3. Invite friends

You can click "My" - "Invite Friends" to share the ROX poster or ROX QR code with your friends and invite them to use the ROX APP with you. When you save the poster or QR code to the local of the device, we will call your album/storage permission to save the invitation poster or QR code for you.

4. Test drive

When you make an appointment for a test drive through the official website sssof ROX, we will collect your name/nickname, mobile phone number, mobile verification code, test drive store information, and city information to schedule a test drive for you. When you use the appointment function of the ROX APP or ROX Mini Program, we will collect your mobile phone number, test drive store information, and call your location permission to schedule a test drive for you. If you agree to enable location permission, we will automatically select the nearest test drive store for you, or you can manually select the test drive store.

Please understand that if you refuse to provide the above information, you will not be able to complete the test drive appointment. Please pay special attention. If you make an appointment for our centralized test drive for others, please ensure that you have obtained their consent.

You can also choose to go directly to our offline stores for a test drive. Before conducting a test drive in the store, you need to provide us with the name, mobile phone number, and identification information of the test driver for signing the test drive agreement and disclaimer; In order to verify the identity and driving qualifications of the test driver, we will require them to present their personal identification documents and driver's license before the test drive.

5. Purchase service

When you pay a deposit to purchase a ROX car, we will use your location permission to collect information about your registered city, sales stores and delivery center. We will also collect your name, mobile phone number, ID type, ID number, as well as car model and configuration information, price, and payment information to help you complete the car reservation and provide you with subsequent delivery services. If you do not agree with us to call your location permission, you can also manually select the registration city, sales store, and delivery center. When you make the final payment, we will collect your payment information to confirm that you have completed the final payment.

When you pay the deposit and the final payment, you can choose the payment services provided by third-party payment institutions (including WeChat, Alipay, UnionPay, etc., and the payment method displayed on the page shall prevail). We need to share your order number and transaction amount with these payment institutions, so that they can confirm your payment instructions and complete the payment.

When the car is delivered, we will collect the name, mobile phone number, ID type, ID number, as well as license plate number and driver's license information of the car owner user and rights registrant, to determine the owner and rights registrant, in order to complete the delivery of the vehicle.

We will arrange our staff to contact you and provide you with services based on the information you have provided voluntarily.

6. Real-name authentication

Based on the real-name system requirements of the vehicle networking card, you need to complete real-name authentication when your car is delivered. You can complete real-name authentication on the ROX APP or in our offline stores. We will collect your name, ID type, valid ID number, ID photo, and facial information in accordance with laws and regulations to complete real-name authentication for you.

7. Financial services

You can use financial services through the ROX APP. When you click on the financial plan application, you need to provide us with your name, mobile phone number, ID type, and ID number to meet your financial service needs. You understand and agree that financial services are provided to third-party financial institutions (the specific list of financial institutions is subject to the page display). When you choose to use this service, you will enter the loan application retention page of third-party financial institutions to complete subsequent loan application and approval. We will share some of your information with the third-party financial institutions you have selected, which is necessary for financial approval, including your name, mobile phone number, ID type, ID number, and vehicle related information, including order number, configuration, vehicle price, city of delivery, vehicle registration city, and your intended financial plan.

8. Shopping in the mall

When you use the ROX APP for shopping in the mall, we will collect the recipient's name, address, and mobile phone number in order to deliver the goods to you. If you purchase goods for others, you need to provide their receiving information, please ensure that you have obtained their authorization and consent. At the same time, our system will generate order information for you, which will include the name of the purchased goods, order number, order creation time, payment method, and payment amount. After you complete the payment, we will collect your payment information.

If you need an electronic invoice, please contact our customer service and provide your email address and invoice header information.

9. Remote management

You can use the ROX APP to scan the QR code on the vehicle to activate the ROX in-car system. When you use the "Scan" function, we will call your camera permission. When you activate the ROX in-car system, your account ID, nickname, avatar, VIN code, and license plate number will be used to bind the vehicle information to the in-car system, so as to achieve the interconnection between ROX and the vehicle and remotely control the vehicle. For the personal information processing rules of the ROX in-car system, please refer to the Privacy Policy of ROX Internet of Vehicles.

During the binding process, you can choose to use the system's fingerprint ID or facial ID to complete authentication. After completing the binding, you can remotely view your vehicle (such as model, license plate number, VIN code, ODO, battery level, vehicle location, etc.) through the ROX APP, and remotely unlock/lock the vehicle, open/close the windows, tailgate, air conditioning, perform remote parking, mode switching, car finding, and other operations. Please refer to the relevant functional interface in the APP for details.

10. Charging services

When you need us to provide you with installation service of home charging station, you need to provide us with your name, installation address, mobile phone number, and parking space number (optional), so that our service personnel can come and install the charging station for you.

11. Pick-up and delivery service

When your vehicle is being repaired, you can choose the pick-up and delivery service we provide for you. You need to provide us with your name, license plate number, contact information and pick-up and delivery location, so that the staff can get in touch with you and provide you with pick-up and delivery service after verifying the vehicle information.

12. tire replacement

If you are entitled to the tire replacement service, we will, based on your explicit consent, share your name, mobile phone number, ID card number, VIN code, and tire DOT number necessary for the provision of the service with our designated third party, China Ping An Property Insurance Co., Ltd. Shanghai Branch for the record, so that we can be contacted to provide the service in a timely manner if you have a need for the service. This information will only be used for service-related purposes and will be kept strictly confidential in accordance with the applicable privacy policy. If you do not consent to the sharing of such information, you will not be able to enjoy the Service. For the third party privacy policy, please visit [Ping An General Insurance website personal information protection policy] (link: https://hcz-static.pingan.com.cn/base-common/client/index.html#/agreement/protocol?id=85).

13. accident repair compensation

If you are entitled to the accident repair compensation, we will, based on your explicit consent, share your name, mobile phone number, ID card number, and VIN code necessary to provide the service with our designated third party, China Ping An Property Insurance Co., Ltd. Shanghai Branch for record purposes, so that we can be contacted to provide the service in a timely manner when you have a need for it. This information will only be used for service-related purposes and will be kept strictly confidential in accordance with the applicable privacy policy. If you do not consent to the sharing of such information, you will not be able to enjoy the Service. For third party privacy policies, please visit [Ping An General Insurance website personal information protection policy](link: https://hcz-static.pingan.com.cn/base-common/client/index.html#/agreement/protocol?id=85).

14. User community services

You can post, comment, and like in the user community. In order to provide you with such services, we will collect your nickname, account ID, and the content you posted and your favorite. You can upload pictures and text in the community. When you upload pictures, you need to enable album/storage permission and camera permission. If you refuse to provide such authorization, you will not be able to upload pictures, but it does not affect your use of other functions. If you choose to mark your location when posting, we need to call your location permission and use your location information, and you can also adjust and mark your location. When you use the sharing function to share picture information to the Rednote or Tiktok platform, we will call your storage permission to save the shared picture locally for you. If you refuse such permission, you will not be able to store the picture, but it will not affect your use of other functions. You can share your information in the user community, but please note that the information you publicly publish may include your or others' personal information and sensitive personal information. Please carefully consider whether to disclose your or others' relevant information before publishing. If the information you disclose contains other people's information, please make sure to get the authorization and consent of others before publishing it.

15. Customer service

When you contact us, we will collect your mobile phone number, name and account for verifying your identity. In addition, we may selectively record your communication information with us (including but not limited to text, voice, photos, videos, location, etc. sent during the communication) and consultation records, so as to help you solve problems.

16. Information push and promotion

We will push you activity registration information, car purchase information, etc. In order to ensure that you can receive message reminders in a timely manner when the ROX APP is closed or in the background, you need to enable notification permission. You can choose to disable notification permission in the "Settings" of your mobile device.

In order to help you better understand our products or services, we may use your name and mobile phone number to send you advertisements, promotions and marketing information from time to time, and invite you to participate in the investigation of our products/services or the membership activities organized by us. If you don't want to accept the above information we sent you, you can contact us in the way listed in "VIII. How to contact us" to unsubscribe from these information.

(Ⅱ) System permissions called by ROX APP

In order to make you have a better experience while using our products/services, our products/services may need to call your system permissions. We will prompt you in the form of a pop-up window, and you need to explicitly agree that we can call these permissions, and we will only call these system permissions when necessary for the relevant functions or services. The system permissions and scenarios that we may call are as follows:

1. Location permission. We will access and obtain your location information in the background after you have enabled location permission. This information will be used to automatic selection and posting positioning for car ordering and registered cities, test drive stores. If you refuse to enable location permission, the above functions will not be available, but it does not affect your normal use of our other products/services.

2. Camera permission. After enabling this permission, relevant functions can be used to achieve functions such as taking photos, recording videos, and scanning. We only collect photos and videos when you actively click to take photos, record videos. If you refuse to enable camera permission, the above functions will not be available, but it does not affect your normal use of our other products/services.

3. Storage/album permission. When you use local files, save files, invite friends, modify your avatar, post and upload album images, and other functions, we need to call your storage/album permission. If you refuse to enable storage/album permission, the above functions will not be available, but it does not affect your normal use of our other products/services.

4. Network permission. In the iOS system, you can use it to communicate with cloud services after enabling network permission; In the Android system, network permission include viewing network status and changing network connection. When using network status information to locate and distinguish between mobile data network or Wi-Fi network, you need to view network status permission. If you refuse this authorization, the above functions will not work properly.

5. Notification permission. We will push you order status information, event registration information, car purchase information, etc. If you refuse to enable notification permission, the above functions will not be available, but it does not affect your normal use of our other products/services.

6. Phone call permission. When you use the ROX APP and call us for consultation on the ordering page, we may need to enable your phone call permission. If you refuse to enable the phone call permission, you will not be able to make consultation call.

7. Facial ID and fingerprint ID: We need to use your facial ID and fingerprint ID permissions to receive verification results, but we do not directly collect your facial ID and fingerprint ID information. We only obtain verification results provided by the hardware service provider based on your authorization. If you refuse to enable this permission, you will not be able to unlock verification services using your facial ID or fingerprint ID, but it does not affect your choice of other methods. Please note that your facial ID and fingerprint ID are sensitive personal information. When providing your aforementioned information to the hardware service provider, please read the relevant privacy policies and instructions of the hardware service provider. If you refuse this authorization, the aforementioned functions will not be used normally, but it will not affect your normal use of our products and/or services.

You understand and agree that by enabling these permissions, you authorize us to collect and use this personal information to achieve the above scenario functions. You can turn off these authorizations in your phone settings. After you turn off the permission authorization, we will no longer collect your personal information and cannot provide you with the functions corresponding to these authorizations. Your decision to disable permissions will not affect the processing of personal information based on your authorization.

(Ⅲ)Exceptions with your authorization and consent

Please understand that according to laws and regulations, we do not need your consent to collect and use your personal information when the following legal reasons arise:

1. Related to our obligations under laws and regulations;

2. Necessary for the conclusion and performance of the contract to which you are a party;

3. Directly related to national security and national defense security;

4. Directly related to public safety, public health, and major public interests;

5. Directly related to criminal investigation, prosecution, trial, and enforcement of judgment;

6. In response to sudden public events or for the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain your authorization and consent;

7. Personal information that you disclose to the public by yourself;

Collect your personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;

8. Other situations stipulated by laws and regulations.

Ⅱ. How do we use Cookies and similar technologies

(Ⅰ) The use of Cookies

When you use our services, we may send one or more Cookies or anonymous identifiers to your device to collect your preferences, account settings, and permissions, so as to:

1. Remember your registration, login, and permissions information to facilitate your more convenient operation of the system;

2. Timely detect and prevent security risks.

We will not use Cookie or similar technologies for any purpose outside the scope of this privacy policy. You can manage or delete Cookie according to your preference. You can clear all Cookies saved in the software, but if you do so, you may need to change the user settings yourself every time you visit, and the corresponding information you have previously recorded will also be deleted, which may have some impact on the security of the services you use.

Ⅲ. How do we entrust to process, share, transfer and publicly disclose your personal information

(Ⅰ) Entrusted processing

In specific service scenarios, we may entrust a third party to process your personal information. We will sign a strict confidentiality agreement or data processing agreement with the companies, organizations and individuals entrusted by us to process personal information. We will clarify the responsibilities, processing items and processing purposes of both parties, require them to process personal information according to our requirements, the requirements of this privacy policy and any other relevant confidentiality and security measures, and strictly supervise their personal information processing activities.

(Ⅱ) Sharing

We will not share your personal information with other personal information processors, except in the following circumstances:

1. Based on legal regulations, administrative and judicial requirements

Providing your personal information based on mandatory requirements of laws and regulations, administrative and judicial requirements.

2. Sharing with our affiliated companies

In order for us and our affiliates to jointly provide some services to you, we will share your personal information among affiliated companies that follow unified management and control, and are bound by the purposes stated in this privacy policy. If our affiliated company changes the purpose of processing personal information, we will obtain your authorization and consent again.

3. Sharing with business partners

Some of our products/services are provided by third parties or provided according to our instructions. In order to realize this part of the function you selected, we need to share the necessary information with third parties.

(Ⅲ) Third-party SDK

Third party SDKS may be included in certain business scenarios, such as when you use such services provided by a third party through its SDK in connection with the use of our products and/or services, that third party may process your information. In order to maximize the security of your information, we strongly recommend that you review the privacy policy of any third party SDK services before using them. Please refer to Annex I "List of Third Party SDK" for details of the third-party SDK we are currently accessing under this privacy policy.

(Ⅳ) Transfer

We will not transfer your personal information to other companies, organizations, or individuals. However, please understand that with the development of our business, we may encounter situations such as mergers, divisions, and acquisitions. In such circumstances, if it involves the transfer of personal information, we will inform you of the recipient's name and contact information, and require them to continue to be bound by this privacy policy. Otherwise, we will seek your authorization and consent again.

(Ⅴ) Public disclosure

We will strictly keep your personal information confidential. We will only publicly disclose your personal information in the following circumstances:

1. After obtaining your explicit consent;

2. Disclosure based on law: under the compulsory requirements of laws, legal procedures, lawsuits or government authorities.

(Ⅵ) Exceptions with your authorization and consent

We will not obtain your authorization and consent to share, transfer, or publicly disclose your personal information in the following situations:

1. Related to our obligations under laws and regulations;

2. Necessary for the conclusion and performance of the contract to which you are a party;

3. Directly related to national security and national defense security;

4. Directly related to public safety, public health, and major public interests;

5. Directly related to criminal investigation, prosecution, trial, and enforcement of judgment;

6. In response to sudden public events or for the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain your authorization and consent;

7. Personal information that you disclose to the public by yourself;

8. Collect your personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;

9. Other situations stipulated by laws and regulations.

Ⅳ. How do we protect and store your personal information

(Ⅰ) Our technology and measures to protect your personal information

1. Technical and organizational measures:

We have used industry standard security measures to protect the personal information provided by you, preventing unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, we will use national encryption techniques to ensure the confidentiality of data; We will use trusted protection mechanisms to prevent data from being maliciously attacked; We will encrypt the transmission and storage of your sensitive personal information.

We will deploy access control mechanisms to ensure that only authorized personnel can access personal information. We will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information. We only allow employees and partners of us and our affiliates who need to know this information to access personal information, and have established strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill corresponding confidentiality obligations.

2. Security incident response

If a personal information security incident unfortunately occurs, we will promptly inform you of the basic situation and possible impact of the security incident in accordance with legal requirements, the disposal measures we have taken or will take, suggestions that you can prevent and reduce risks independently, and remedial measures for you. We will inform you through email, letters, phone calls, push notifications, and other means. If it is difficult to inform the individual information subject one by one, we will take reasonable and effective measures to publish the announcement. At the same time, we will also proactively report the disposal of personal information security incidents in accordance with regulatory requirements.

3. Special reminder

We will make every effort to ensure the security of your personal information and use technical means to restrict unauthorized access, use, or disclosure of your personal information by others. Despite taking the above measures, please understand that due to the limitations of current technological development and various malicious means that may exist, even if we do our best to strengthen security measures, it is impossible to always fully guarantee the 100% security of personal information. Please understand that the systems and communication networks connected during the use of ROX and related services may encounter problems due to factors beyond our control. If our physical, technical, or management protection measures are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which damages your legitimate rights and interests, we will bear corresponding responsibilities within the scope of legal provisions.

(Ⅱ) Storage of your personal information

We will store your personal information collected and generated during our domestic operation in accordance with laws and regulations within the territory of the People's Republic of China, located in our controlled data center (Shanghai). We will not transfer your personal information abroad without your permission.

Generally speaking, we only retain your personal information at the necessary period for the purposes stated in this privacy policy and within the time limit required by laws and regulations, unless otherwise provided by laws and regulations or authorized by the personal information subject. The storage period for different types of personal information may vary based on different processing purposes. We determine the storage period factors for different types of personal information, including legal or recommended storage periods determined by laws, regulations or other normative guidelines; the necessary time for retaining personal information to achieve processing purposes; the retention period for which you have clearly instructed.

If you cancel your account, voluntarily delete personal information, or exceed the necessary retention period, we will delete or anonymize your personal information.

Ⅴ. How do you manage your personal information

We attach great importance to your concerns about personal information and do our best to protect your right to inquire, correct, supplement, delete and withdraw your consent about your personal information, so that you have sufficient ability to protect your privacy and security. According to relevant Chinese laws, regulations, standards, etc., we guarantee that you can exercise the following rights on your personal information:

(Ⅰ) Inquiring and copying your personal account information

You have the right to inquire your personal information at any time on the ROX APP and ROX Mini Program, or you can contact us through the contact information listed in the "How to contact us" to obtain your personal information. Please understand that we may refuse your request beyond the scope permitted by applicable laws and regulations.

(Ⅱ) Correcting and supplementing your personal information

When you find that your personal information processed by us is incorrect or incomplete, you have the right to make corrections or supplements. You can contact us through the contact information listed in the "How to contact us", or correct or supplement your personal information on the ROX APP by yourself. The specific operation method is as follows: My - Nickname.

(Ⅲ) Deleting your personal information

In the following situations, you can request us to delete personal information:

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

2. If we collect and use your personal information without your consent;

3. If our processing of personal information violates our agreement with you;

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

5. If we no longer provide you with products or services.

You can request us to delete your personal information through the contact information listed in the "How to contact us", except that your personal information has been anonymized or otherwise stipulated by laws and regulations. When deleting, your identity needs to be verified, and you need to confirm the specific type of personal information to be deleted. We will respond to your request in accordance with national laws, regulations, and regulatory requirements.

When you delete information from our service, we may not immediately delete the corresponding information in the backup system, but we will delete it when the backup is updated.

(Ⅳ) Changing the scope of your authorization or withdrawing your authorization

You have the right to grant or withdraw your authorization at any time, if necessary, you can grant or withdraw your authorization through the mobile phone Settings.

Please understand that each business function requires some basic personal information to be completed (please refer to "Ⅰ. How do we collect and use your personal information" for details). When you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. But your decision to withdraw your consent or authorization will not affect the personal information processing previously carried out based on your authorization.

(Ⅴ) Canceling account

You can apply to cancel your account through ROX APP "My-Settings-Account Security-Account Cancellation". On the premise of complying with national laws, regulations and regulatory requirements, we will respond to your request within 15 working days. In case of unsuccessful cancellation, you can call our customer service hotline at 400 006 0707 to contact us.

Please note that after you cancel your account, we will stop providing you with our products/services and delete your personal information or anonymize your personal information, except for the storage time of user information stipulated by laws, regulations or regulatory agencies.

(Ⅵ) Obtaining a copy of your personal information

If you need to obtain a copy of your personal information that we have collected, you can contact us by sending an email to privacy-protection@roxmotor.com, and we will conduct necessary identity verification for you, and submit a copy of your personal information to you on the premise of complying with relevant laws and technical feasibility. If you request to transfer your personal information to the designated personal information processor and meet the requirements set by the national regulatory authorities, we will provide a way to transfer it.

(Ⅶ) Responding to your request

To ensure security, we need to verify your identity first before processing your request. We will complete the identity verification and response processing within 15 working days after receiving your application. If sensitive personal information is involved, we will complete the identity verification and response processing within 10 working days after receiving your application. If your request is complex or requires excessive technical means, we will complete the response processing within the response time stipulated by laws and regulations. For your reasonable requests, we do not charge any fees in principle,but we will charge a certain fees for requests that are repeated many times, beyond reasonable limits or require too much technical means.

Please understand that we will not be able to respond to your request in the following situations:

1. Related to the fulfillment of legal and regulatory obligations by personal information controllers;

2. Directly related to national security and national defense security;

3. Directly related to public safety, public health, and major public interests;

4. Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;

5. We have sufficient evidence to indicate that users have subjective malice or abuse of rights;

6. For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain your consent;

7. Responding to your request will result in serious damage to your or other individuals or organizations' legitimate rights and interests;

8. Involving trade secrets.

Ⅵ. How do we handle information about minors

We attach great importance to the protection of personal information of minors. Our products and services are mainly aimed at adults and do not knowingly collect personal information of minors. If we find that we have collected personal information of minors without obtaining verifiable consent from their guardians in advance, we will try our best to delete the relevant information as soon as possible. If you find that we have unintentionally collected personal information of minors, please notify us immediately and we will try our best to delete the relevant information as soon as possible. We will only process the personal information of minors provided with the consent of the guardian if it is permitted by law or if the guardian explicitly agrees or is necessary to protect the minor.

Ⅶ. Update and revision of this privacy policy

In order to provide you with better services, our products/services will continue to be iterated and updated, and this privacy policy will also be updated accordingly. But without your explicit consent, we will not reduce your rights under past privacy policy. Before the updated version officially takes effect, we will remind you of the update of relevant content through announcement or other appropriate means.

For significant changes, we will notify you in a more prominent manner (including but not limited to emails, text messages, or special reminders on webpages to explain the specific changes to our privacy policy). The significant changes referred to in this privacy policy include but are not limited to:

1. Our product/service mode has undergone significant changes, such as the purpose of processing personal information, the type of personal information processed, and the way of using personal information.

2. We have undergone significant changes in ownership structure, organizational structure, and other aspects, such as changes in ownership caused by business adjustments, bankruptcy mergers and acquisitions, etc;

3. The main objects of personal information sharing, transfer, or public disclosure have changed;

4. Your right to participate in personal information processing and the way you exercise it have undergone significant changes;

5. When our responsible department, contact information and complaint channels of processing personal information security change;

6. When the personal information security impact assessment report indicates that there is a high risk.

We will also archive the old version of this privacy policy for your reference. If necessary, please contact us through the contact information specified in "How to contact us".

Ⅷ. How to contact us

We have set up a dedicated department for personal information protection. If you have any questions, opinions or suggestions about this privacy policy, or have any privacy complaints or claims, you can contact us through the following methods:

Email of person in charge of personal information protection:

privacy-protection@roxmotor.com

Customer service hotline:

400 006 0707

Address:

19th Floor, Building C4, Lane 1688, Guoquan North Road, Yangpu District, Shanghai.

Normally, we will respond within 15 working days after receiving your feedback and verifying your user identity. If sensitive personal information is involved, we will reply within 10 working days

Annex 1: List of third-party SDKs

Name of SDK or APIScope of information collectionPurposeSensitive system permissions calledCollection methodName of third-party organizationPrivacy policy or official website link
Baidu Map SDKDevice information, location informationUsed to display your city and regionLocation permissionSDK local collectionBeijing Baidu Network Technology Co.,Ltd.https://lbs.baidu.com/index.php?title=openprivacy
WeChat Open SDKDevice information (unified device identifier, MAC address), network information, WeChat account information, application information, payment order identification, payment statusSupport the implementation of WeChat login, sharing, and payment functionsNetwork permissionSDK local collectionShenzhen Tencent Computer Systems Co., Ltd.
https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8
SDK Pushed by MobileDevice information, network information, account binding informationPush messages on mobile terminal devicesNetwork permissionSDK local collectionShenzhen Tencent Computer Systems Co., Ltd.https://privacy.qq.com/document/preview/8565a4a2d26e480187ed86b0cc81d727
Alipay Client App SDKIMEI, IMSI, MAC address, device serial number, hardware serial number, SIM card serial number, ICCID, Android ID, OAID, SSID, BSSID; System settings, system attributes, device model, device brand, operating system; IP address, network type, operator information, Wi-Fi status, Wi-Fi parameters, Wi-Fi list; Software installation list.Provide you with payment servicesNetwork permissionSDK local collectionAlipay (China) Network Technology Co., Ltd.https://opendocs.alipay.com/common/02kiq3
Weibo SDKDevice information, IP address, and installed application informationShare information to Sina Weibo/SDK local collectionWeimeng Chuangke Network Technology (China) Co., Ltd.https://weibo.com/signup/v5/privacy
SDK Pushed by Huawei Device information, basic information of applications, network informationProvide message push Network permissionSDK local collectionHuawei Technologies Co., Ltd.https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/sdk-data-security-0000001050042177
SDK Pushed by XiaomiPushing of device information, network information, application information and running notification informationProvide message push Network permissionSDK local collectionXiaomi Tech.https://dev.mi.com/console/doc/detail?pId=1822
SDK Pushed by OPPODevice information, basic information of applications, network informationPush notification messages to usersNetwork permissionSDK local collectionHeyTaphttps://open.oppomobile.com/new/developmentDoc/info?id=10288
SDK Pushed by VIVODevice information, basic information of applications, network informationPush notification messages to usersNotification permissionSDK local collectionVivo Mobile Communication Co., Ltd.https://dev.vivo.com.cn/documentCenter/doc/366
Bugly SDKCrash information, software version, device modelCollect App crash information and solve the flashback problem/SDK local collectionShenzhen Tencent Computer Systems Co., Ltd.https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56
UnionPay SDKDevice information (device model, IMSI, IMEI, device hardware serial number, MAC), location information, mobile phone number, application information
Provide support for payment services and confirm device security/SDK local collectionChina UnionPayhttps://wallet.95516.com/s/wl/WebAPP/helpAgree/page/agreement/regPrivacy.html?cntryCode=86
Mobile One-Click Login SDKMobile phone number maskRealize one-click login to the app with a mobile phone number/SDK local collectionChina Mobilehttps://wap.cmpassport.com/resources/html/contract.html
Unicom One-Click Login SDKMobile phone number maskRealize one-click login to the app with a mobile phone number/SDK local collectionChina Unicomhttps://opencloud.wostore.cn/authz/resource/html/disclaimer.html?spm=a2c4g.11186623.0.0.41f1633eHxMLkQ&fromsdk=true
Telecom One-Click Login SDKMobile phone number maskRealize one-click login to the app with a mobile phone number/SDK local collectionChina Telecomhttps://e.189.cn/sdk/agreement/detail.do?spm=a2c4g.11186623.0.0.41f1633eHxMLkQ&appKey=E_189&hidetop=true&returnUrl=
Growth Marketing SDKDevice information (device model, IMSI, IMEI, device hardware serial number, MAC), location information, mobile phone number, application information, developer app's own process informationData analysis/SDK local collectionBeijing Volcano Engine Technology Co., Ltd.https://www.volcengine.com/docs/6285/72216
Umeng Statistical Analysis SDKDevice information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI/ICCID), location information, network informationData analysisNetwork permissionSDK local collectionYoumeng Tongxin(Beijing)Technology Limited.https://www.umeng.com/page/policy
Umeng Crash Analysis SDKMobile phone number, device information(IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI/ICCID), location information, network informationPerform APP performance monitoring and crash analysisNetwork permissionSDK local collectionYoumeng Tongxin(Beijing)Technology Limited.https://www.umeng.com/page/policy
SDK shared by RednoteDevice information (Android ID/IDFA/ operating system, system version, device model) , used for content sharingUsed for content sharing/SDK local collectionChant Information Technology Shanghai Co., Ltd. https://agree.xiaohongshu.com/h5/terms/ZXXY20230525001/-1
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