Effective Date: Dec 6, 2024
Updated Date: Dec 6, 2024
"ESwap" (hereinafter referred to as "the Service") is a software function and related service developed by Beijing Wandian New Energy Co., Ltd.(hereinafter referred to as "the Company" or "we"). We highly value the personal information and privacy protection of users (hereinafter referred to as "users" or "you") while using the Service. Therefore, we have formulated the "ESwap User Privacy Policy" (hereinafter referred to as "this Policy"). To effectively protect your personal rights, please be sure to carefully read and understand the entire content of this Policy before using the Service, and only start using it after fully understanding and agreeing to it. By using or continuing to use our services, you agree that we may collect, use, store, and share your relevant information in accordance with this Policy. If you have any questions about this Policy or related matters, please contact us through "ESwap" customer service.
1. ESwap: Refers to the ESwap official website, client (including Android app/iOS app/PC web pages, and other forms of terminal interfaces such as battery cabinet display screen interface), and related mini-programs (such as WeChat mini-programs).
2. ESwap Service Provider: Refers to the network and software technology service provider of ESwap, Shenzhen Hitech Power Technology Co., Ltd.
3. Personal Information: Refers to various information recorded by electronic or other means that can identify the identity of a specific natural person or reflect the activity status of a specific natural person alone or in combination with other information.
4. Personal Sensitive Information: Refers to personal information that includes name, mobile phone number, ID number, ID photo (front and back), personal biometric information, bank account, property information, whereabouts, transaction information, information of children under 14 years old (inclusive), etc. (We will prominently mark specific personal sensitive information in bold in this Privacy Policy).
5. Personal Information Deletion: Refers to the act of removing personal information in the system involved in the realization of daily business functions, making it impossible to retrieve or access.
This Policy will help you understand the following:
1、 How we collect and use your information
2、 How we use Cookies and similar technologies
3、 How we share, transfer, and publicly disclose your information
4、 How we protect your information
5、 How you manage your information
6、 How we handle information about minors
7、 How Your Personal Information is Transferred Globally
8、 How this Privacy Policy is updated
9、 How to contact us
When you use our products and/or services, we may need to collect and use your personal information, including the following:
1. To provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide such information, you will not be able to use our products and/or services properly.
2. To provide you with additional functions of our products and/or services, you may choose to authorize us to collect and use the information. If you refuse to provide it, you may not be able to use the related additional functions or achieve the desired function effect, but it will not affect your normal use of the basic functions of our products and/or services.
You understand and agree:
1. We strive to provide diverse products and services to meet your needs. Since we offer many types of products and services and the specific products/services chosen by different users vary, the corresponding basic/additional functions and the types and scope of personal information collected and used may differ. Please refer to the specific product/service functions for details.
2. To provide you with a better product and service experience, we are continuously working to improve our technology, and as a result, we may occasionally launch new or optimized features that may require the collection and use of new personal information or change the purpose or method of using personal information. In this regard, we will explain the purpose, scope, and method of use of the information collection separately through updates to this Policy, pop-ups, page prompts, etc., and provide you with an option to consent. We will collect and use the information after obtaining your express consent. If you have any questions, opinions, or suggestions during this process, you can contact us through the various contact methods provided by ESwap, and we will respond as soon as possible.
We will collect and use your personal information to achieve the functions described below:
To comply with laws and regulations, when you register to become our user,you need to provide a mobile phone number and/or third-party platform account information (e.g., WeChat mini-program requires your WeChat uid) to create a ESwap account.If you only need to use basic browsing services, you do not need to register as our user or provide the above information.
For services that require a ESwap account, we may verify your identity based on the information you provide to ensure that we are providing services to you personally.
When using ESwap, to maintain your basic profile and improve your service experience, you can complete network identity information (such as real-name authentication, etc.). If you do not provide this information, it will not affect your use of ESwap’s basic functions.
Account Information Display: If you already have a ESwap platform account, we may display your personal information in the ESwap platform services, as well as your actions in products and services related to the ESwap platform account, including a centralized display of your personal profile, discount rights, and transaction orders through the ESwap platform account. We will respect your choices regarding the ESwap platform services and ESwap platform account settings.
When using our services, to ensure your account security, understand product compatibility, identify abnormal account status, and provide you with a more tailored page display, we may request you to provide or automatically collect your usage information and store it as network log information, including:
Device Information:We will receive and record the device-related information you use based on your specific operations during software installation and usage (including device model, operating system version, device settings, device advertising identifier, mobile device identification code, MAC address, mobile application list, and other hardware and software environment information), and information related to the device's location (including the GPS location authorized by you, and sensor information such as WLAN access points, Bluetooth, and base stations).
Service Log Information:When using the services we provide, we will automatically collect and save the detailed usage information of your services as service logs. This includes browsing, clicking to view, payments, refunds, as well as IP address, browser type, operating system version, telecom operator, language used, access date and time, etc.
Please note that standalone device information and log information are not personally identifiable information. If we combine this type of non-personal information with other information to identify a specific natural person, or use it in combination with personal information, this type of non-personal information will be treated as personal information during the period of combination. Unless otherwise required by laws and regulations, we will anonymize and de-identify this information.
In addition, we may use your above information to continuously improve and optimize the features mentioned above.
To complete payment for paid services (such as paying for battery exchange services), you need to choose a payment method and provide a third-party payment platform account. We will share your ESwap platform account member name, order-related information, and relevant device information required for secure payment, as well as other necessary information required by anti-money laundering laws with the third-party payment platform company through the third-party payment platform software development kit (SDK) embedded in the application.
To ensure we promptly know and confirm your payment progress and status, and provide you with after-sales and dispute resolution services, you agree that we may collect payment account and payment progress-related information from the payment institution associated with the payment method you choose.
You need to understand and agree that, to protect your legitimate rights to the paid services and confirm your legal use of the services, we need you to authenticate your personal information before making a payment, including but not limited to your name, mobile phone number, geographic location, ID number, ID photo (front and back), and other personal sensitive information.
To ensure that the company can continue to provide stable, reliable, and safe battery exchange services, the information about the company's battery exchange cabinets, batteries, and other assets will be uploaded to the company’s server in real-time. This information includes, but is not limited to, the location information of battery exchange cabinets, battery location information, battery power, battery health status, etc. You understand and acknowledge that after you rent a company battery, the relevant information of the battery will still be uploaded to the company’s server in real-time. The company will collect and use the battery information for the purpose of monitoring asset health. You should understand and acknowledge the risk of indirectly exposing your trajectory information with this information. Meanwhile, the company will strive to minimize this risk through technical means, including but not limited to the anonymization of battery information and desensitization of client-server communication. If you still worry about this risk, you can choose not to rent and/or not use the company's batteries and related paid services and only use other basic services.
At the same time, you acknowledge and understand that in order to protect the legitimate rights and interests of you and the Company's assets, the Company may take legal and necessary protective measures under special circumstances, including but not limited to:
1） When you report that the battery has been stolen, or the Company proves that the battery has been stolen through evidence, the Company may share and publish the battery location information to related affiliates, partners or public security organs within the scope permitted by law, and has the right to take necessary actions to remotely power off the battery.
2） When you violate the Company's relevant service agreement (including but not limited to the user agreement, battery replacement service agreement, etc.), the Company may share and publish the battery location information to related affiliates, partners or public security organs within the scope permitted by law, and has the right to take necessary actions to remotely power off the battery.
When you contact us or submit a request for handling issues during or after sales, to ensure the security of your account and system, we may require you to provide necessary personal information to verify your identity as a user.
To facilitate communication with you, help you resolve issues as quickly as possible, or record the solutions and outcomes of related issues, we may retain your communication/call records and related content with us (including account information, order information, other information you provide to prove relevant facts, or contact information you leave). If you inquire, complain, or provide suggestions about a specific order, we will use your account and order information.
To reasonably provide and improve service quality, we may also use other information you provide when contacting customer service, or your responses to questionnaires you participate in.
To enhance the security of your use of services provided by us and our affiliated companies and partners, ensure the safety of the operating environment, and identify abnormal states of ESwap platform accounts, better protect the personal and property safety of you, other users, or the public from harm, and better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and intrusions, we have embedded an application security SDK developed by our affiliated companies in the application to collect your device information and service log information. We may use or integrate your user information, transaction information, and information shared by our affiliated companies and partners with your authorization or as required by law to comprehensively assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.
To enhance your experience, we may collect and use your personal information when providing you with the following additional services. If you do not provide the aforementioned information, it will not affect your use of basic services such as browsing on ESwap, but you may not be able to enjoy the user experience brought by these additional services. These additional services include:
1. Location Information: To help you conveniently find nearby battery swapping cabinets, we will provide services based on your geographic location. When you enable the device's location function and use our location-based services, we may collect and use your location information to help you find nearby battery swapping cabinets (including providing relevant services without you manually entering your geographic location, and estimating the actual distance between you and the battery swapping cabinets to facilitate your navigation decisions). We will use technologies such as IP addresses, GPS, and sensor technologies like WLAN access points, Bluetooth, and base stations to locate your actual location.We will only collect your current geographic location but will not associate your location information over time to infer your movement trajectory.
2. Camera-Based Additional Services: You can use this feature to scan the QR code on the battery swapping cabinet.Please be aware that even if you have agreed to enable the camera permission, we will only obtain photo information through the camera when you actively click the camera icon in the client (or scan the QR code icon).
3. Photo/Video Access and Upload Additional Services Based on Gallery (Photo/Video Library): You can use this feature to upload your photos/pictures/videos to change your avatar or provide proof when communicating with customer service.
You understand and agree that the aforementioned additional services may require you to enable location, camera, and gallery (photo library) access permissions on your device to collect and use information related to these permissions. You can view the status of these permissions in your device settings and decide to enable or disable them at any time.Please note that enabling any permission authorizes us to collect and use related personal information to provide you with the corresponding service, and disabling any permission indicates that you cancel the authorization, meaning we will no longer collect and use related personal information based on the corresponding permission and will not be able to provide you with the services corresponding to that permission. However, your decision to disable permissions will not affect the information collection and use conducted based on your previous authorization.
1. If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing this personal information to ESwap.
2. If we use the information for purposes not specified in this policy, or use information collected for a specific purpose for other purposes, or proactively obtain your personal information from third parties, we will obtain your consent in advance.
If we indirectly obtain your information from third parties, we will clearly require the third party in writing to obtain your consent before collecting personal information and inform you of the content of the shared information. If sensitive information is involved, we will seek your explicit confirmation before using it and require the third party to commit to the legality and compliance of the personal information source. If the third party violates this requirement, we will clearly require the third party to bear corresponding legal responsibilities; meanwhile, our professional security team will reinforce the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will protect indirectly obtained personal information with protection measures and methods no less stringent than those used to protect our own users' personal information.
3. Exceptions to Obtaining Authorization and Consent
You fully understand and agree that according to relevant laws and regulations, we do not need to obtain your authorization and consent to collect and use your personal information in the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or information retrieval:
1) Related to national security and defense security;
2) Related to public safety, public health, and significant public interests;
3) Related to criminal investigations, prosecutions, trials, and execution of judgments;
4) 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;
5) The personal information collected is information you have publicly disclosed to the public on your own;
6) Personal information collected from legally disclosed information, such as legal news reports, government information disclosure, etc.;
7) Necessary to sign and perform a relevant agreement or other written documents with you;
8) Necessary to maintain the safe and stable operation of the products or services provided, such as detecting and handling product or service failures;
9) Necessary for lawful news reporting;
10) Necessary for statistical or academic research conducted by research institutions based on public interest, and when providing academic research or descriptive results to the public, the personal information contained in the results has been de-identified;
11) Other circumstances as required by laws and regulations. Please be informed that according to applicable laws, if we process personal information using technical and other necessary measures to ensure that the data recipient cannot re-identify specific individuals and cannot restore the data, or if we de-identify the collected information for research, statistical analysis, and prediction, to improve the content and layout of ESwap, support business decisions, and enhance our products and services (including using anonymized data for machine learning or model algorithm training), such processed data usage does not require further notice to you and obtaining your consent.
4. If we cease to operate ESwap products or services, we will promptly stop collecting your personal information and notify you of the suspension of operations individually or through public announcement. We will delete or anonymize personal information related to the discontinued business. If children's personal information is involved, we will promptly inform the child's guardian of the suspension.
5. When you actively cancel your account, we will anonymize or delete your personal information as soon as possible in accordance with applicable laws and regulations.
To ensure the proper functioning of our website and to provide you with an easier browsing experience, we will store Cookies, Flash Cookies, or other local storage provided by browsers or related applications, which typically include identifiers, site names, and some numbers and characters (collectively referred to as "Cookies") on your computer or mobile device.
If your browser or browser add-on services allow, you can modify the acceptance level of Cookies or refuse our Cookies. For details, please refer to AboutCookies.org. However, if you do so, in some cases, it may affect your safe access to our website and may require you to change user settings every time you visit our website.
In addition to Cookies, we may also use other similar technologies such as web beacons, pixel tags, and ETags on our website.
For example, the emails we send to you may contain a link to the content of our website, and if you click on that link, we will track that click to help us understand your product or service preferences so that we can proactively improve the customer service experience. A web beacon is usually a transparent image embedded in a website or email. With the help of pixel tags in emails, we can know whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.
ETags (Entity Tags) are HTTP protocol headers transmitted between an Internet browser and an Internet server, which can replace Cookies. ETags can help us avoid unnecessary server load, improve service efficiency, and save resources and energy. At the same time, we may use ETags to record your identity so that we can better understand and improve our products or services.Most browsers provide users with the function to clear browser cache data, and you can perform corresponding data clearing operations in the browser settings function.However, please note that if you disable ETags, you may not be able to enjoy the best product or service experience.
We will not share your personal information with any company, organization, or individual outside of ESwap service providers, except in the following cases:
1. Sharing with explicit consent: With your explicit consent, we will share your personal information with others.
2. Sharing in legal circumstances: We may share your personal information in accordance with laws and regulations, as required for litigation dispute resolution, or as requested by administrative or judicial authorities.
3. Sharing at your own choice: If you purchase paid services through ESwap, we will share the necessary information related to the transaction from your order information with relevant service providers according to your choice to fulfill your transaction and after-sales service needs.
4. Sharing with affiliated companies: To facilitate us in providing you with products and services based on your ESwap platform account, identifying abnormal member account status, and protecting the personal and property safety of ESwap affiliated companies or other users or the public from harm, your personal information may be shared with our affiliated companies.We will only share necessary personal information, and if we share your sensitive personal information or if the affiliated companies change the purpose of using and processing personal information, we will again seek your authorization and consent.
5. Sharing with authorized partners:We may entrust authorized partners to provide certain services or perform functions on our behalf.We will only share your information for legitimate, proper, necessary, specific, and explicit purposes as stated in this privacy policy. Authorized partners can only access the information needed to perform their duties and cannot use this information for any other purpose. For information involving children’s personal information, we do not allow partners to subcontract.
Currently, our authorized partners include the following types:
1） Authorized partners for advertising and analytics services. Unless we have your permission, we will not share your personal identification information with partners who provide advertising and analytics services. We will entrust these partners to process information related to the coverage and effectiveness of advertisements, but we will not provide your personal identification information, or we will de-identify such information so that it does not identify you personally. These partners may combine the above information with other data they have legally obtained to perform the advertising services or decision-making recommendations we have entrusted.
2） Suppliers, service providers, and other partners. We send information to suppliers, service providers, and other partners that support our business, including providing technical infrastructure services entrusted by us, analyzing how our services are used, measuring the effectiveness of advertisements and services, providing customer service, facilitating payments, or conducting academic research and surveys.
3） To enable you to receive push notifications, share information on third-party platforms, use map services, play videos, and other necessary functional purposes, our applications will embed SDKs or other similar applications of authorized partners. For example, if you use a Huawei/Xiaomi/VIVO/Meizu mobile phone, the Push SDK of Huawei/Xiaomi/VIVO/Meizu needs to read your device identification number and network-related information for pushing and sending notifications; if you use a WeChat account to log in to our products, the WeChat SDK needs to collect your WeChat account, device identification number, and network-related information; if you use the information-sharing function to share information with third-party platforms such as WeChat, it will collect your device identification number and network-related information; if you use the map services provided by Gaode/Baidu/Tencent, the corresponding map services need you to enable device location permissions and collect device location-related information, device identification number, and network-related information.
4） We will strictly monitor the security of the information acquisition interfaces (APIs) and software development kits (SDKs) of authorized partners and agree on strict data protection measures with authorized partners, requiring them to handle personal information in accordance with our commissioned purposes, service descriptions, this privacy policy, and any other relevant confidentiality and security measures.
You can click to view the rules for third-party SDK information collection.
We will not transfer your personal information to any company, organization, or individual, except in the following cases:
1. Transfer with explicit consent: With your explicit consent, we will transfer your personal information to others；
2. Transfer in the event of mergers, acquisitions, or bankruptcy liquidation: If ESwap's service provider undergoes a merger, acquisition, or bankruptcy liquidation, or other situations involving mergers, acquisitions, or bankruptcy liquidation, if personal information is involved in the transfer, we will require the new company or organization holding your personal information to continue to be bound by this policy, otherwise, we will require the company, organization, and individual to seek your authorization and consent again.
We will only publicly disclose your personal information in the following situations:
1. With your explicit consent or based on your voluntary choice, we may publicly disclose your personal information;
2. If we determine that you have violated laws and regulations or seriously violated ESwap-related agreements and rules, or to protect the personal and property safety of ESwap users or the public from harm, we may disclose information about you, including relevant violations and the measures ESwap has taken against you, in accordance with laws and regulations or with your consent.
3. Disclosure required by law: We may publicly disclose your personal information under legal, legal process, litigation, or mandatory requests by competent government authorities.
In the following situations, sharing, transferring, or publicly disclosing your personal information does not require your prior authorization and consent:
1. Related to national security and national defense security;
2. Related to public safety, public health, and significant public interests;
3. Related to criminal investigation, prosecution, trial, and judgment execution;
4. To protect your or other individuals' life, property, and other major legal rights but it is difficult to obtain your consent;
5. Personal information that you disclose to the public by yourself;
6. Personal information collected from legally disclosed information, such as legitimate news reports, government information disclosure channels, etc. Please be aware that according to applicable laws, if we take technical measures and other necessary measures to process personal information, making it impossible for data recipients to re-identify specific individuals and unable to restore it, then the sharing, transfer, and public disclosure of such processed data do not require further notice to you and consent from you.
（1）We have implemented security measures that comply with industry standards and are reasonably feasible to protect your information, preventing unauthorized access, public disclosure, use, modification, damage, or loss of personal information. For example, data exchanged between your browser and our servers is protected by SSL protocol encryption; we also offer secure browsing via HTTPS protocol on the ESwap website; we use encryption technology to enhance the security of personal information; we employ trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we conduct security and privacy protection training courses to raise our employees' awareness of the importance of protecting personal information.
（2）We have an industry-leading data security management system centered around data, which enhances the security of the entire system in multiple dimensions, including organizational construction, system design, personnel management, and product technology.
（3）We take reasonable and feasible measures to avoid collecting irrelevant personal information to the best of our ability. We will only retain your personal information for the period necessary to fulfill the purposes described in this policy, unless the law requires mandatory retention. For example, the "E-Commerce Law of the People's Republic of China" requires that product and service information and transaction information be retained for no less than three years from the date of transaction completion. Our criteria for determining the aforementioned period include:
1. Completing the transaction purpose related to you, maintaining corresponding transaction and business records, and addressing any queries or complaints you may have;
2. Ensuring the safety and quality of services we provide to you;
3. Whether you agree to a longer retention period;
4. Whether there are other special agreements regarding the retention period.
Once your personal information exceeds the retention period, we will delete your personal information or anonymize it according to applicable legal requirements.
（4）The internet is not an absolutely secure environment. If you discover that your personal information, especially your account or password, has been leaked while using ESwap services, please contact ESwap customer service immediately so that we can take appropriate measures based on your request. Please use a complex password to help ensure the security of your account. We will do our best to ensure the security of any information you send to us. If our physical, technical, or administrative protection facilities are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, thereby causing harm to your legal rights, we will bear the corresponding legal responsibility.
（5）In the unfortunate event of a personal information security incident, we will inform you in accordance with legal and regulatory requirements. We will notify you of the basic situation of the security incident, its possible impact, the measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, and remedial measures for you. We will notify you of the incident-related situation via SMS, phone calls, push notifications, etc. If it is difficult to individually notify each personal information subject, we will take reasonable and effective ways to publish an announcement. At the same time, we will report the handling of the personal information security incident to the regulatory authorities as required.
We will make every effort to take appropriate technical measures to ensure that you can access, update, and correct your registration information or other personal information provided when using our services. Before accessing, updating, correcting, or deleting the aforementioned information, we may require you to verify your identity to ensure account security. You have the right to inquire, correct, manage, delete your information, and protect your privacy and security.
(1) Accessing Your Personal Information Except in cases where the law provides otherwise, we strive to ensure that you can access your personal information whenever you use our services. You can exercise your access rights in the following ways:
1. Account Information: If you want to access or edit the personal profile information in your account, change your password, add security information, etc., you can perform these operations in the product you are using.
2. Order Information: You can view or clear your related order information in our system.
(2) Correcting or Supplementing Your Personal Information If you need to update your personal information or find that we have processed your personal information incorrectly, you have the right to make corrections or updates. You can correct it yourself within our system, or submit your correction request to us through feedback and error reporting. Before you update or correct it, we may first require you to verify your identity before processing your request.
(3) Deleting Your Personal Information
1. You can delete your information through the settings or relevant functional controls in the product.
2. In the following situations, you can request the deletion of your personal information from us:
a) If our processing of personal information violates the law;
b) If we collect and use your personal information without obtaining your consent;
c) If our processing of personal information violates our agreement with you;
d) If you no longer use our products or services, or you voluntarily cancel your account;
e) If we terminate product operations and services.
If we decide to respond to your deletion request, we will also notify, to the best of our ability, the entities that have obtained your personal information from us, requesting them to delete it promptly (unless otherwise required by laws and regulations, or if these entities have independently obtained your authorization).
After you or we assist you in deleting the relevant information, due to applicable laws and security technology, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.
(4) Changing the Scope of Your Authorization
Each business function requires some basic personal information to be completed (see "Part I" of this Privacy Policy). In addition:
1. You can withdraw part of the authorization by unbinding, modifying personal settings, deleting related information, etc., or withdraw authorization by disabling the function.
2. After you withdraw consent or authorization, we will not be able to continue providing you with the corresponding services associated with the withdrawal of consent or authorization and will no longer process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the personal information processing that was carried out based on your consent or authorization before the withdrawal.
(5) Canceling Your Account
You can apply to cancel your account in the following ways:
1. Contact ESwap customer service for help, and we will assist you in applying to cancel your account. After you voluntarily cancel your account, we will stop providing products or services to you, delete your personal information as required by applicable laws, or anonymize it.
2. Constraints on Information System Automated Decision-Making
In certain business functions, we may make decisions based solely on non-human automated decision-making mechanisms, such as information systems and algorithms. If these decisions significantly affect your legal rights, you have the right to request an explanation from us. We will also provide appeal methods under the premise of not infringing on ESwap's trade secrets, other users' rights, or social public interests.
(6) Responding to Your Requests
To ensure safety, you may need to provide a written request or otherwise prove your identity. We may require you to verify your identity before processing your request. We will respond within 15 days. If you are not satisfied, you can initiate a complaint through ESwap customer service. For reasonable requests, we generally do not charge a fee, but for repeated requests or those beyond reasonable limits, we may charge a fee based on the situation. We may refuse requests that are not directly related to your identity, are repetitive without cause, require excessive technical means (e.g., requiring the development of new systems or fundamentally changing existing practices), pose a risk to others' legitimate rights, or are impractical. In the following situations, as required by laws and regulations, we will not be able to respond to your request:
1. Related to national security and defense security;
2. Related to public safety, public health, and significant public interests;
3. Related to criminal investigation, prosecution, trial, and enforcement of judgments;
4. Where there is sufficient evidence showing that the personal information subject has subjective malice or abuse of rights;
5. Where responding to your request will cause serious damage to your or others' legitimate rights and interests;
6. Involving trade secrets.
When using the services provided by the company, we assume you have the corresponding civil capacity. If you are a minor, we recommend that you ask your parents or guardians to read this Privacy Policy carefully and use our services or provide information to us with their consent.
Once we identify you as a child user, to ensure your riding safety, we will not provide electric bicycle rental and battery replacement services. For situations where we collect children's personal information with parental or guardian consent, we will only use, share, transfer, or disclose this information as permitted by laws and regulations, with explicit parental or guardian consent, or as necessary to protect the child.
If you are the parent or guardian of a child, please pay attention to whether the child under your care is using our services with your authorization and consent. If you have any questions about the personal information of the child under your care, please contact us through the contact information in Section 9.
The personal information we collect and generate during our operations in the People's Republic of China is stored within China, except in the following cases:
1. As explicitly required by laws and regulations;
2. Obtaining your explicit authorization;
3. Your personal voluntary conduct, such as cross-border transactions via the internet.
For the above situations, we will ensure that your personal information is adequately protected according to this Privacy Policy.
Our Privacy Policy may change.
Without your explicit consent, we will not restrict the rights you should enjoy under this Privacy Policy. We will display the latest version of the Privacy Policy on a dedicated page (e.g., "My → Privacy Policy" on the ESwap WeChat Mini Program).
For significant changes, we will also provide more prominent notifications (including notifying you via ESwap's announcements or even providing pop-up prompts).
The significant changes referred to in this policy include but are not limited to:
1. Major changes in our service model, such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;
2. Major changes in our control rights, such as changes in information controllers due to mergers and reorganizations;
3. Major changes in the main recipients of personal information sharing, transfer, or public disclosure;
4. Major changes in your participation in personal information processing and the way your rights are exercised;
5. Changes in the department responsible for handling personal information security, contact methods, and complaint channels.
If you have any of the following questions, please contact us via the phone number provided at the end of this agreement, and we will respond to your request within 15 days:
1. If you have any questions, opinions, or suggestions about the content of this policy or the protection of children's personal information, you can contact us through ESwap customer service;
2. If you discover that your personal information may have been leaked, you can complain or report it through ESwap customer service;
3. Any disputes arising from or related to this agreement shall be submitted by both parties to the Beihai Arbitration Commission for arbitration according to its current arbitration rules. The arbitration award is final and binding on both parties.
Customer Service Email: pkeswap@gmail
Beijing Wandian New Energy Co., Ltd.