[Special Notice]
This policy applies solely to the products and services provided by Refone Auto Power Co., Ltd. and its affiliates (hereinafter referred to as "we", "us", or "Refone"), including their extended functions (hereinafter referred to as "Refone Services"), such as the Refone website, official WeChat account, video channels, and any new forms of products and services offered as technology evolves. If a specific product or service we provide has a separate privacy policy or special provisions in its corresponding legal notice, that product's privacy policy shall take precedence. For matters not covered by that product's or service's privacy policy and user service agreement, this policy shall apply. If our affiliates' products or services utilize Refone-provided products or services but do not have an independent privacy policy, this Privacy Policy also applies to such products or services.
Please carefully read the *Refone Privacy Policy* (especially the bolded content) and ensure you understand our rules for processing your personal information. If you have any questions during your reading, you may consult us through the contact methods provided in the *Refone Privacy Policy*.
Introduction
Welcome to the Refone Auto Power Co., Ltd. website (the "Site").
This Site is provided and controlled by Refone Auto Power Co., Ltd. ("we"), and our registered address is No.108 Yanyu East Road, Yanqiao Intelligent Industrial Park, Wuxi 214174, Jiangsu, China.
We attach great importance to user privacy and the protection of personal information. When you use our products and/or services, we may collect and use information related to you. Through this *Refone Privacy Policy* (this "Privacy Policy"), we aim to explain how we collect, use, store, share, and transfer such information when you use our products and/or services, as well as the ways we provide for you to access, update, delete, and protect this information.
This Privacy Policy will help you understand the following:
1. What types of information we collect
2. How we use your information
3. How we share your information
4. Entrusted processing
5. How we protect your information
6. How long we retain your information
7. Protection of minors' personal information
8. Notices and revisions
9. Third-party links
10. Contact us
Table of Contents
1. What types of information we collect
2. How we use your information
3. How we share your information
4. Entrusted processing
5. How we protect your information
6. How long we retain your information
7. Protection of minors' personal information
8. Notices and revisions
9. Third-party links
10. Contact us
1. What types of information we collect
When you use this Site, we may collect the following categories of information:
Information you provide to us.
We may collect personal information that you provide to us. When you send us a message through the "Contact Us" page on this Site, you will need to provide your personal identification and contact information, such as your name, email address, phone number, country and city of residence, etc. You may also provide us with your employment information, such as your employer and job title. We may also obtain information about you from your communications with us, such as your comments, questions, feedback, and other content you provide while using the features of this Site.
Information we collect about you.
During your use of this Site, we may automatically collect certain information about you. This information may include:
- Technical and device information. We may collect certain technical information about you and your device. This may include, but is not limited to, your IP address, system time zone, system language, and other system or network identification information.
- Operational and behavioral information. We automatically collect information generated during your visits to this Site and record your activity on the Site, including the time you spend on the Site, which parts of the Site you visit, and what information you access.
- Cookies and similar technologies. This Site may use "Cookies" and other tracking technologies to store information provided by users of the Site. Cookies are pieces of information sent by a web server to a user's browser. Cookies may include information such as user preferences, time spent on the Site, and pages visited. We use this information to identify you and to customize and improve your experience on this Site. You can manage Cookie settings on your device through most browsers' built-in functions. For example, you can set your browser to notify you when Cookies are received, or you can choose to block Cookies with your browser. However, please note that not accepting Cookies may limit your ability to use certain features of this Site. Additionally, please be aware that this Site currently does not respond to "Do Not Track" signals from your browser.
Information we collect from third parties.
We may obtain personal information about your use and access of this Site from third-party platforms and our service providers, such as your system's country/region, device brand and model, browsing records, browsing history (including other services you accessed to reach our Site), search records, and click records.
2. How we use your information
We may use your information in the following aspects:
Based on our legitimate interests in providing this Site, we may use your information for the following purposes:
- To review your opinions or questions and provide you with appropriate services;
- To enforce our terms and policies;
- To process and respond to your requests, inquiries, applications, complaints, and feedback;
- To provide support and respond to your requests, feedback, and inquiries;
- To monitor, operate, maintain, and manage this Site;
- To address and resolve technical issues and malfunctions on this Site;
- To ensure the effective and efficient operation of this Site;
- To detect, prevent, or otherwise address security, fraud, or technical issues;
- To improve and enhance the functionality and performance of this Site and related services;
- To properly manage and operate our relationship with you;
- To manage our business; and to protect, enforce, or defend our rights and interests (including our rights and interests regarding violations of our terms and conditions);
- For academic research purposes;
- For purposes consistent with public interests under applicable laws and regulations, or public health emergencies.
We may also use your information for purposes of fulfilling our legal obligations and responsibilities. With your consent or where permitted by laws and regulations, we may process your information for other purposes disclosed to you.
3. How we share your information
We may share your information with the following third parties:
- Service providers. We may share your information with third parties that provide services to us for the operation and maintenance of this Site, such as website hosting service providers, development service providers, and cloud service providers.
- Our affiliates. In order to provide this Site, we may share your information with any member of our company, subsidiaries, or affiliates, including for purposes such as preventing illegal use and supporting users.
- Law enforcement agencies and competent authorities. We may share your information with competent authorities, courts, third parties, and other institutions in accordance with court orders, subpoenas, legal preparation requirements, regulatory requirements, or where legally permitted or required, including when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats to the physical safety of any person.
- Sale or merger. We may disclose your information to any third party in the following circumstances:
- A third party that acquires or intends to acquire all or part of our assets or shares;
- A third party that is acquired by us in whole or in part;
- A third party with which we merge; or
- A third party that succeeds to all or part of our business.
In each such case, the third party is legally obligated not to disclose or use your information without our authorization.
Please note that information you voluntarily share or even publicly disclose while using our services may involve your or others' personal information or even sensitive personal information. Please consider carefully and make decisions when sharing.
4. Entrusted processing
We may entrust authorized partners to process your personal information in order to provide you with corresponding products or services. However, we will only share your personal information for legitimate, lawful, necessary, specific, and explicit purposes, and will only share the personal information necessary to provide the products or services. If our partners use your personal information for purposes not entrusted by us, they will seek your separate consent.
Our partners include the following types:
- Technology service providers. We may provide your personal information to third parties that support our functions, including vendors that provide infrastructure technology services, data analysis services, and data processing services.
- Advertising and analytics partners. We will comply with laws, regulations, and industry standard security technologies, and entrust these partners to process information related to ad delivery, coverage, and effectiveness.
For partners entrusted to process personal information, we will sign data protection agreements with them, requiring them to process personal information in accordance with the agreement, this Privacy Policy, and applicable laws and regulations.
5. How we protect your information
We implement security measures in accordance with this Privacy Policy and have physical, electronic, and managerial procedures in place to protect and safeguard the information we process about you. However, no data transmission over the internet is absolutely secure, and we cannot guarantee the absolute security of your information. Any transmission of your information to us is at your own risk.
6. How long we retain your information
During your use of this Site's services, your personal information will be retained for the period necessary to fulfill the purposes described in this Policy, while also taking into account mandatory retention periods under laws, such as the *Electronic Commerce Law of the People's Republic of China*, which requires that product and service information and transaction information be preserved for no less than three years from the completion of the transaction. After the retention period expires, we will delete your personal information or anonymize it in accordance with applicable laws.
We may also retain your information when we have other lawful purposes, for example, when we are obligated to retain personal information due to laws, regulations, administrative or judicial mandatory requirements, contractual obligations, or similar obligations. We respect and highly value your rights regarding your personal information, including:
- Right of access. You have the right to request confirmation of whether we process your personal information and to request a copy of your personal information.
- Right of rectification. If any of your personal information we have collected is incomplete or inaccurate, you may request that we correct or update such information.
- Right of deletion. Under specific circumstances, you may request that we delete all or part of your personal information.
- Withdrawal of consent. If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. However, if your consent is withdrawn, you may not be able to use some features of this Site and our services.
You may contact us in accordance with Section 10 (Contact Us) of this Privacy Policy to exercise any of your rights. To protect your privacy, we may ask you to provide additional information to verify your identity before processing your request.
7. Protection of minors' personal information
Refone attaches great importance to the protection of minors' personal information. If you are a minor under the age of 18, you should obtain prior consent from your guardian before using our products and/or services. Refone protects minors' personal information in accordance with relevant national laws and regulations.
We do not actively and directly collect personal information from minors. For personal information of minors collected with the consent of a guardian, we will only use, share, transfer, or disclose such information as permitted by law, with the guardian's consent, or as necessary to protect the minor.
8. Notices and revisions
We reserve the right to revise this Privacy Policy at any time at our sole discretion. We will notify you of any material changes to this Privacy Policy through notices posted on this Site, and such changes will apply only to information collected after the revised Privacy Policy takes effect. Any revision to this Privacy Policy will become effective immediately upon posting. We encourage you to periodically review this Privacy Policy to stay informed of changes and understand how we protect your personal information.
9. Third-party links
This Privacy Policy does not apply to any other websites or platforms unless the context otherwise indicates. Please note that this Site may contain links to other websites, platforms, or products whose privacy policies and practices differ from ours. These links are provided solely for your convenience and for additional information, and do not imply affiliation, endorsement, or approval of the content on third-party sites. If you provide your information to any such third parties or interact with their websites, we are not responsible for the collection and processing of your information by them.
10. Contact us
If you have any questions about this Privacy Policy, please contact us through our official website.
Generally, we will respond within 15 days. If you are not satisfied with our response, particularly if our processing of your personal information harms your legitimate rights and interests, you may also file a complaint or report to the cyberspace administration, telecommunications, public security, and industry and commerce regulatory authorities.
Appendix: Examples of Personal Information and Sensitive Personal Information (not collected by the Refone website, official WeChat account, or video channels; provided for illustrative purposes only)
- Personal Information: Various types of information recorded electronically or otherwise that relate to an identified or identifiable natural person, excluding anonymized information.
- Sensitive Personal Information: Personal information that, once leaked or illegally used, may easily infringe upon the dignity of a natural person or harm their personal or property safety, including biometric data, religious beliefs, specific identities, medical health data, financial accounts, location tracking information, and personal information of minors under 14 years old.
- Device Information: Including device identifiers (IMEI, IDFA, AndroidID, MAC, OAID, IMSI, and other device-related information), application information (app crash logs, notification switch status, installed app list, and other app-related information), device parameters and system information (device type, device model, operating system, and related hardware information), and device network environment information (IP address, WiFi information, base station information, and other network-related information).
