I. Introduction
Wuhan KOTEIInformation Technology Co., Ltd. (hereinafter referred to as "we") places great importance on the protection of personal information and privacy. While providing you with products and/or services, we may collect and use your relevant information. This Privacy Policy aims to explain how we collect, use, store, share, and protect your personal information during our business operations. Please read this policy carefully to understand how we handle your personal information. If you have any questions or suggestions regarding this policy, please feel free to contact us.
By using our products and/or services or continuing to use them after we update this Privacy Policy (we will promptly notify you of updates), you agree to the content of this Privacy Policy (including the updated version) and consent to our collection, use, storage, and sharing of your relevant information in accordance with this Privacy Policy. This Privacy Policy constitutes a legally binding document between you and us and takes effect immediately for both parties. You may not claim that this ivacy Policy is invalid or request its revocation or modification on the grounds that you have not read its content or have not received answers to your inquiries from us. If you have any questions while reading this policy, please contact us. If you do not agree to any terms of this policy, please stop submitting your information.
II. Scope of Application
This policy applies to all personal information collected during our business operations (including but not limited to: name, phone number, address, identity information, personal location information, vehicle information, etc.), regardless of whether the information is provided by you voluntarily, collected by us through technical means, or obtained from other legitimate channels.
III. Collection of Personal Information
1. Methods of Collection
Voluntary Provision: Personal information you voluntarily provide to us during business interactions, such as registering an account, filling out forms, or submitting orders.
Automatic Collection: Certain information may be automatically collected through technical means while you use our products or services.
2. Purposes of Collection
We collect personal information primarily for the following purposes:
Providing Services: To offer you high-quality, personalized products or services, process your transaction requests, and ensure the normal operation and delivery of services.
Customer Communication: To communicate with you, respond to your inquiries, feedback, and complaints, and send you service-related notices and information.
Security Assurance: To ensure the security of our services, prevent, detect, and respond to security threats and fraudulent activities, and protect your and our legitimate rights and interests.
IV. Use of Personal Information
1. Principles of Use
We will use your personal information in accordance with the principles of legality, legitimacy, and necessity, only within the scope necessary to achieve the aforementioned collection purposes, and ensure that the methods of use comply with legal and regulatory requirements. When displaying your personal information, we will use methods such as content replacement and de-identification to desensitize your information and protect its security.
2. Specific Use Scenarios
Based on Your Consent: With your explicit consent, we will use your personal information in the manner and scope you have agreed to.
Performance of Contract: To ensure the secure and stable operation of our products or services or to realize related functions, we may use your personal information.
Compliance with Legal Obligations: Where required by law, we may use your personal information to comply with legal and regulatory requirements, respond to judicial authorities, or fulfill other legal obligations.
Other Purposes: If we intend to use your personal information for purposes not specified in this policy or to collect additional information for specific purposes, we will seek your consent in advance by having you actively check a box.
V. Storage of Personal Information
1. Storage Location
We will store your personal information on secure servers, which may be located in [specific country/region] or other regions with adequate security measures. If cross-border storage is involved, we will take corresponding measures to ensure that your personal information receives equivalent protection and comply with relevant laws and regulations regarding cross-border data transfers.
2. Storage Period
We will store your personal information only for the period necessary to achieve the purposes of collection. When the storage period expires or your personal information is no longer needed, we will delete or anonymize it in accordance with legal and regulatory requirements, unless otherwise stipulated by laws and regulations. Our criteria for determining the storage period include:
Specific requirements of laws, regulations, or supervision regarding data retention periods;
Completion of transaction purposes related to you, maintenance of corresponding transaction and business records, and response to your possible queries or complaints;
Ensuring the security and quality of the services we provide to you;
Whether you have consented to a longer retention period;
Whether there are other special agreements regarding the retention period.
If we terminate services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information after the termination of services or operations.
VI. Sharing, Transfer, Disclosure, and Transfer of Personal Information
1. Sharing
We may share your personal information with third parties under the following circumstances:
Service Providers: We may share your personal information with third-party partners who provide services to us to assist in completing transactions with you, providing services, or conducting data analysis. These third parties may use your personal information only to the extent necessary to perform their duties and must comply with strict confidentiality obligations.
Affiliated Companies: When necessary, we may share your personal information with our affiliated companies to achieve collaborative services or business integration. Affiliated companies will also comply with this Privacy Policy or similar privacy protection provisions.
Consent to Share: With your explicit consent, we will share your personal information with third parties in the manner and scope you have agreed to.
2. Transfer
We will not transfer your personal information to other companies, organizations, or individuals unless one of the following circumstances applies:
With Your Explicit Consent: Before transferring, we will obtain your explicit consent and inform you of the name or identity of the transferee, contact information, processing purpose, processing method, and types of personal information.
Based on Legal Requirements or Business Mergers: In accordance with legal provisions or in cases involving business transfers such as mergers, divisions, dissolution, or bankruptcy, we may transfer your personal information as part of the transferred assets. In such cases, we will thoroughly review the qualifications of the third party and require the transferee to continue complying with this Privacy Policy or to formulate and implement privacy protection measures no less protective than those in this policy.
3. Disclosure
We will disclose your personal information only under the following circumstances:
Legal Requirements: In accordance with legal provisions or requirements from government departments or judicial authorities, we may need to disclose your personal information. In such cases, we will, to the extent permitted by law, ensure that the disclosed information is limited to what is necessary and comply with relevant legal procedures.
Protection of Rights: When we deem it necessary to protect our own, your, or other third parties' legitimate rights and interests, such as preventing fraud, ensuring service security, or responding to emergencies, we may disclose your personal information, but such disclosure will be conducted within a reasonable and necessary scope.
4. Transfer
In principle, personal information collected and generated within the People's Republic of China will be stored within the territory of the People's Republic of China.
As we provide products or services through resources and servers distributed globally, this means that, after obtaining your authorization and consent, your personal information may be transferred to jurisdictions outside the country/region where you use the products or services or may be accessed from such jurisdictions.
These jurisdictions may have different data protection 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 may seek your consent for the cross-border transfer of personal information or implement security measures such as data de-identification before cross-border data transfers.
VII. Security Protection of Personal Information
1. Security Measures
We attach great importance to the security of your personal information and have adopted a series of technical and managerial measures to protect your personal information from leakage, tampering, loss, or improper use. These measures include but are not limited to:
Technical Measures: Using encryption technology to encrypt and transmit your sensitive information to prevent data from being stolen or tampered with during transmission and storage; implementing access control mechanisms to restrict access to your personal information to authorized personnel only; regularly conducting security vulnerability detection and repairs to ensure system security.
Managerial Measures: Establishing sound information security management systems, providing information security training to employees to enhance their security awareness and confidentiality awareness; setting strict information access and usage permissions to ensure that employees process your personal information only within the scope necessary to perform their duties; conducting strict security assessments and management of partners and requiring them to comply with corresponding security and confidentiality obligations.
2. Response to Security Incidents
In the unfortunate event of a personal information security incident, we will immediately activate an emergency plan, take reasonable and effective measures to investigate and handle the incident, and strive to minimize the impact on you. We will report the security incident to you and relevant regulatory authorities in a timely manner as required by laws and regulations, and inform you of the basic situation of the incident, possible impacts, measures we have taken or will take, and preventive suggestions you can adopt.
VIII. Your Rights
1. Right to Access: You have the right to access your personal information at any time to understand how we collect, use, and store your personal information. You can exercise this right through the account management functions we provide or by contacting our customer service personnel.
2. Right to Correction: If you find that the personal information we collect or store about you is incorrect or inaccurate, you have the right to request correction. You can submit a correction request to us through the methods described for the right to access and provide necessary supporting materials.
3. Right to Deletion: Under circumstances compliant with laws and regulations, you have the right to request the deletion of your personal information. For example, when the purpose of processing your personal information has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose, or when you withdraw your consent, or when we process personal information in violation of legal provisions, you can submit a deletion request to us. We will process your request in a timely manner in accordance with legal and regulatory requirements after receiving it.
4. Right to Withdraw Consent: For personal information processing activities based on your consent, you have the right to withdraw your consent at any time. You can withdraw your consent through the relevant function settings we provide or by contacting our customer service personnel. After you withdraw your consent, we will no longer process your personal information based on that consent, but this will not affect the legality of processing activities conducted based on your consent prior to withdrawal.
5. Right to Restrict Processing: In certain circumstances, you have the right to request that we restrict the processing of your personal information. For example, when you dispute the accuracy of personal information, you may request restricted processing during the verification period; when the legality of our processing of personal information is questioned, you may request restricted processing, etc. You can exercise this right by contacting our customer service personnel.
6. Right to Obtain a Copy of Personal Information: Under circumstances compliant with laws and regulations, you have the right to obtain a copy of your personal information. You can submit a request to obtain a copy of your personal information by contacting our customer service personnel, and we will provide it to you within a reasonable time.
7. Complaints and Reports: If you believe that your personal information rights may have been infringed or if you discover clues of infringement of personal information rights, you can contact us through the contact methods specified in [XII. Contact Information] of this Privacy Policy.
IX. Protection of Minors
Minors referred to by us are users under the age of 14.
We do not intentionally collect personal information of minors for any purpose. If you believe that we possess personal information of minors without parental/guardian consent, or if you are a parent or guardian of a user and wish to withdraw consent, please contact us through the contact methods specified in [XII. Contact Information], and we will delete such information.
X. Policy Changes
We may revise this Privacy Policy based on updates to laws and regulations, business development, or other reasonable reasons. The revised policy will be published on our official website, application, and other prominent locations, and we will notify you through pop-ups, push notifications, or other methods at appropriate times. Please check this policy regularly to stay informed about the latest changes in how we handle personal information. If you continue to use our products or services after policy changes, it means you agree to be bound by the revised policy.
XI. Dispute Resolution
We collect, use, and process your personal information based on the principles of voluntariness and legality. If you have any questions, please contact us through the contact methods specified in [XII. Contact Information]. We will actively address and resolve them. If a dispute indeed exists and cannot be resolved, you may submit arbitration to the Wuhan Arbitration Commission located in Wuhan, and the arbitration will be conducted in accordance with the currently effective rules of the commission.
XII. Contact Information
If you have any questions, suggestions, or complaints regarding this Privacy Policy or our handling of your personal information, please contact us through the following methods. We will process and respond to your feedback as soon as possible after receiving it to protect your legitimate rights and interests.
Email: tech@kotei.com.cn
Phone: 027-59598171
Mailing Address: Kotei Intelligent Connected Vehicle Software Industrial Park, No. 6 Gangbiantian First Road, East Lake New Technology Development Zone, Wuhan.