User’s Agreement

Update time: 07/07/2022
Implementation time: 07/07/2022
Our contact details
Name: FELO Technology(Shanghai)CO., Ltd

Address: Room D2-101, No6000 Shenzhuan Road, Songjiang District, Shanghai.

Phone number:  +86 021 67859325
E-mail:  gao-w@front-design. cn
Website:  www.felo-ev.com

If you have any questions or requests regarding your personal data, please contact our Data Protection Officer:
Name: Wei Gao
E-mail: gao-w@front-design.cn
Introduction

We, (FELO Technology(Shanghai)CO., Ltd. Room D2-101, No6000 Shenzhuan Road, Songjiang District, Shanghai.), wish to inform you how our
company processes your personal data when you use our website.

Topics:

· What personal data do we collect
· How do we collect your personal data and why
· How do we use your personal data
· How do we store your personal data
· What are your data protection rights
· How to contact the appropriate supervisory authority
· Changes to our privacy policy

What personal data do we collect

We currently collect and process the following personal data:

· User phone number
· Vehicle GPS positioning
· GPS positioning of mobile phone
· Vehicle track record
· Sim card ID

How do we collect your personal data and why

The personal data we process is provided to us directly by you. We collect and process your personal data when you:

· When you register your account through app online.
· Use app to bind vehicle and activate GPS positioning module.
· Use the GPS positioning module and open the vehicle track button on the FELO APP.

Under the General Data Protection Regulation (GDPR), the lawful basis we rely on for processing your personal data are:

a)Your consent. You have the right to remove your consent at any time. Please contact us at gao-w@front-design. cn if you wish to make a request.
b)Provide more intelligent services for users.
c)We have a legitimate interest that does not override your interests, rights or freedoms.

1)The purpose of registering app through mobile phone number is to quickly verify mobile phone number through SMS and improve the security of platform user registration.
2)The purpose of acquiring vehicle GPS position information is to provide vehicle position to you in real time and ensure vehicle safety. You have the right to reject to bind the APP and vehicle, we will not be able to obtain this information.
3)The purpose of recording the driving track of the vehicle is to facilitate you to record the driving route. If you are not willing to record, you can also turn off the function on the app side, we will not be able to obtain the information.
4)The purpose of acquiring SIM card information is to adapt to the services of mobile operators, and to transmit data at the vehicle, server and APP. You have the right to reject to bind the APP and vehicle, we will not be able to obtain this information.
5)The purpose of acquiring GPS positioning information of your mobile phone is to calculate the distance from you to the designated location (such as maintenance location) when you and your vehicle are at different locations.

How do we use your personal data

We process your personal data in order to
· Manage your account
· Provide account security verification and system notification through SMS
· Provide GPS positioning service for users

We treat your personal data with strict confidentiality. We exclusively share your data in a secure manner with the (international) organizations listed below:

Organization	Address
FELO	Room D2-101, No6000 Shenzhuan Road, Songjiang District, Shanghai.

Purpose	Safeguards
After service	end-to-end encryption and Adequacy decision, Account authority and password management

If we intend to process your personal data for other purposes than stated in this privacy notice, we provide you with any relevant information prior to the processing.
How do we store your personal data

Your personal data is securely stored for the duration of legal retention. Once this period has expired, we will delete your personal data.
We guarantee to have taken the appropriate technical and organizational measures to ensure an appropriate level of data protection.

Category of personal data	Retention period
User phone number	The user can delete the information by canceling the account, otherwise it will be saved permanently
Vehicle GPS positioning	3 months
Vehicle track record	3 months
Sim card ID	The user can delete the information by releasing the binding relationship between app and vehicle, otherwise it will be saved permanently
GPS positioning of mobile phone	Only get information in real time as needed, and do not save data on the server Account authority and password management

Storage location	Security precautions
Alibaba's cloud server in Frankfurt	Real time port security monitoring Firewall Anti-virus software Server-Side Encryption Client encryption Cloud data snapshot service
Alibaba's cloud server in Frankfurt	eal time port security monitoring Firewall Anti-virus software Server-Side Encryption Client encryption Cloud data snapshot service
Alibaba's cloud server in Frankfurt	eal time port security monitoring Firewall Anti-virus software Server-Side Encryption Client encryption Cloud data snapshot service
Alibaba's cloud server in Frankfurt	Real time port security monitoring Firewall Anti-virus software Server-Side Encryption Client encryption Cloud data snapshot service
Alibaba's cloud server in Frankfurt	Real time port security monitoring Firewall Anti-virus software Server-Side Encryption Client encryption

What are your data protection rights?

Your right of access – You have the right to request copies of your personal data that we process.

Your right to rectification – You have the right to request us to rectify your personal data if you think the information is inaccurate. You also have the right to request us to complete your personal data if you think the information is incomplete.

Your right to erasure – You have the right to request a deletion of your personal data in certain circumstances.

Your right to restriction of processing – You have the right to request us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to request a transfer of your personal data to another organization, or to you, in certain circumstances.

Please contact us at gao-w@front-design.cn if you wish to make a request.

How to contact the appropriate supervisory authority

If you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to contact the competent supervisory authority.

Name: Wei Gao
Mail: gao-w@front-design. cn
Address: Room D2-101, No6000 Shenzhuan Road, Songjiang District, Shanghai.

Changes to our privacy policy

We keep our privacy policy under regular review and public an update together with the latest version on our homepage. Our current privacy policy was last updated on February 10, 2020.