EShare Privacy Policy
Beijing Wandian New Energy Co., Ltd. ("EShare", the "Company", "we", "us" or "our") values your privacy and the protection of your personal data. This EShare Privacy Policy ("Policy") explains how we collect, use, store, process, share, transfer, protect and otherwise handle your personal data when you access or use EShare applications, websites, H5 pages, mini-programs, products and services in Pakistan.
Please read this Policy carefully before using EShare. By clicking "Agree", "Accept", "Register", "Login", "Continue", "Allow", "Unlock", "Pay", or by accessing or using EShare services, you acknowledge that you have read and understood this Policy and agree to the handling of your personal data as described in this Policy. If you do not agree, you should stop using EShare services.
This Policy should be read together with the EShare User Service Agreement and any additional notices, consent screens, permission prompts, product rules and service-specific terms made available to you from time to time.
1. Scope of This Policy
1.1 This Policy applies to EShare products and services operated by Beijing Wandian New Energy Co., Ltd. for Pakistan operations, including mobile applications, websites, H5 pages, mini-programs and related customer support, payment, account and ride services.
1.2 This Policy does not automatically apply to products or services provided independently by third parties, even if they are linked from EShare or integrated into EShare. Where a third party independently determines how your personal data is processed, that third party's privacy terms will also apply.
2. Definitions
2.1 "EShare" means the EShare platform and related products and services made available by the Company.
2.2 "Personal data" means any information relating to an identified or identifiable natural person.
2.3 "Sensitive personal data" means personal data that, because of its nature, requires a higher level of protection, including identity document information, facial verification data, precise location data, payment information, ride trajectory data, complaint evidence containing personal data and other data treated as sensitive under applicable law or our internal control standards.
2.4 "Processing" means collecting, recording, organizing, storing, using, disclosing, transmitting, transferring, deleting or otherwise handling personal data.
2.5 "Service providers" means vendors, partners, affiliates and contractors who process personal data on our behalf or receive data for specific service purposes.
3. What Personal Data We Collect
3.1 Data you provide directly to us
We may collect:
your name;
your mobile phone number;
one-time password or login verification information;
your email address where provided;
your identity document information and images;
your facial verification information where identity verification is required;
your payment-related account details provided through payment channels;
your customer support messages, complaint details, call records and submitted evidence;
your account preferences, profile information and settings;
any other information you choose to provide.
3.2 Data collected automatically when you use EShare
We may automatically collect:
device model;
operating system and app version;
device identifiers and network information;
IP address;
browser type;
language preference;
access timestamps;
crash logs;
service log information;
location-related signals;
usage events such as registration, login, page views, button clicks, unlock attempts, ride start, ride end, payment actions and customer support interactions.
3.3 Ride and transaction data
When you use ride services, we may collect:
vehicle identifier;
unlock and lock records;
ride start and end times;
ride duration;
ride route or trajectory data where generated by the service;
parking verification records;
ride area validation records;
pricing and billing information;
deposit status;
ride pass purchase and usage data;
refund, dispute and compensation records.
3.4 Location data
To provide nearby vehicle discovery, operating area validation, route assistance, parking compliance checks, fraud prevention and ride safety controls, we may collect your approximate or precise location data, depending on the permissions you grant and the services you use.
3.5 Data from third parties
Where permitted by law, we may receive data from:
payment processors;
identity verification service providers;
mapping and location service providers;
customer support providers;
affiliates and business partners;
law enforcement or regulatory authorities;
other third parties where you have authorized the sharing.
4. How We Use Your Personal Data
We process your personal data for the following purposes:
4.1 to register and manage your account;
4.2 to verify your identity and eligibility to use ride services;
4.3 to provide, operate and maintain EShare services;
4.4 to help you find vehicles, unlock vehicles, ride, park and complete trips;
4.5 to calculate charges, collect payments, manage deposits and process ride pass purchases;
4.6 to prevent fraud, abuse, unpaid orders, unsafe riding conduct and other misuse of the service;
4.7 to detect, investigate and address service faults, security incidents and legal or compliance risks;
4.8 to provide customer support, complaint handling, dispute resolution and after-sales assistance;
4.9 to send service notifications, security alerts, transaction confirmations, policy updates and operational messages;
4.10 to improve our services, optimize product design, analyze usage trends and enhance service quality;
4.11 to comply with applicable law, lawful requests, court orders, regulatory obligations and law enforcement requirements;
4.12 to establish, exercise or defend legal claims.
5. Legal and Operational Basis for Processing
Depending on the context, we process personal data because:
5.1 it is necessary to provide services you request;
5.2 it is necessary to perform our agreement with you;
5.3 you have given consent or authorization, including through app permissions or consent prompts;
5.4 it is necessary for fraud prevention, service security, risk control, user safety or operational integrity;
5.5 it is necessary to comply with legal or regulatory obligations;
5.6 it is otherwise permitted or required by applicable law.
6. Core Service Functions and Data Use
6.1 Account registration and login
To create and manage your account, we use your mobile phone number, verification information and related account records.
6.2 Identity verification
To enable regulated or restricted ride functions, we may collect your real name, identity document information, identity images, facial verification data and related verification results.
6.3 Nearby vehicle display and location-based services
To show nearby vehicles, service areas, parking points and route guidance, we use location information and device-related signals.
6.4 Ride operation and order management
To unlock vehicles, start and end rides, validate parking and generate orders, we process ride records, timestamps, vehicle information, route-related records and service log data.
6.5 Payments, deposits and ride passes
To process your payments and manage financial records relating to ride services, deposits and ride passes, we process transaction details, order information, payment confirmations and refund records.
6.6 Customer support and dispute handling
To answer your questions and resolve complaints, we may use your identity information, account information, order history, ride records, payment records and any evidence or explanation you provide.
6.7 Security, risk control and fraud prevention
To protect users, vehicles, public safety and our lawful interests, we may analyze account behavior, device information, payment signals, location-related records, ride patterns and abnormal service activities.
7. App Permissions and Optional Features
7.1 Location permission
If you enable location permission, we may collect and use location data to provide nearby vehicle search, ride validation, parking verification, operating area controls and anti-fraud functions.
If you disable location permission, some location-based functions or ride functions may become unavailable or work improperly.
7.2 Camera permission
If you enable camera permission, we may allow you to scan QR codes, submit ride evidence, complete identity verification or upload supporting documents.
7.3 Photo or file access
If you enable album, storage or file access, you may upload images, documents or other files for profile updates, identity verification, complaints or customer support.
7.4 Notifications
We may send push notifications, SMS, email or in-app notifications for order status, ride alerts, payment reminders, customer service updates, security notices and policy changes.
7.5 Optional promotional and marketing features
Where permitted by law, we may send marketing, campaign or benefit information. Where required, we will provide a choice to opt in or opt out.
8. Cookies and Similar Technologies
8.1 When you use our websites, H5 pages or browser-based services, we may use cookies, SDKs, scripts, local storage and similar technologies to maintain session status, remember preferences, improve security, analyze traffic and optimize service performance.
8.2 You may control cookies through your browser settings where available. However, disabling certain technologies may affect the proper functioning of EShare services.
9. How We Share Personal Data
We may share your personal data only where reasonably necessary and permitted by law.
9.1 With service providers
We may share relevant data with vendors and partners that help us provide:
identity verification;
mapping and geolocation services;
payment processing;
customer support;
cloud hosting and technical infrastructure;
security services;
messaging and notification services;
analytics and troubleshooting support.
9.2 With affiliates
We may share data with our affiliates where necessary for account support, customer service, risk control, internal administration, service continuity or lawful business operations.
9.3 With ride operation or business partners
Where ride services involve local partners, operators or authorized field support teams, we may share limited data necessary to support ride operations, complaint resolution, asset recovery, safety response or compliance.
9.4 With regulators, courts, law enforcement and competent authorities
We may disclose personal data where required by law, legal process, lawful request, court order, regulatory requirement or where necessary to protect rights, safety and security.
9.5 With your authorization
We may share your data with other third parties when you expressly direct or authorize us to do so.
10. How We Transfer Personal Data
10.1 We do not sell your personal data.
10.2 We may transfer personal data to another entity in connection with a merger, acquisition, financing, restructuring, business transfer, outsourcing arrangement or sale of assets. If that happens, we will require the receiving party to continue protecting your personal data in a manner consistent with applicable law and this Policy.
11. Public Disclosure
We generally do not publicly disclose your personal data except:
11.1 where you have expressly chosen or directed public disclosure;
11.2 where disclosure is required by law or lawful authority;
11.3 where disclosure is necessary to investigate serious misconduct, protect public safety, recover assets, prevent fraud or defend legal rights, to the extent permitted by law.
12. Cross-Border Processing and Storage
12.1 EShare may use technical infrastructure, vendors, affiliates or service arrangements that involve processing, storage, remote access or support from outside Pakistan.
12.2 Where cross-border processing is necessary, we will take reasonable steps to ensure that your personal data remains subject to appropriate confidentiality and security protections consistent with applicable law and this Policy.
12.3 By using EShare services and where legally required by the service design, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan for service delivery, customer support, technical maintenance, security review, payment support or internal administration.
13. Data Retention
13.1 We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including service delivery, dispute handling, security review, legal compliance, fraud prevention and recordkeeping.
13.2 Different categories of data may be retained for different periods depending on:
the nature of the data;
the service involved;
whether there is an active dispute, complaint, claim or investigation;
applicable legal, accounting, tax, regulatory or audit requirements;
our need to maintain service integrity and prevent fraud.
13.3 When retention is no longer necessary, we will delete, anonymize or securely isolate the relevant data, subject to legal and technical limitations.
14. How We Protect Personal Data
14.1 We implement reasonable technical, administrative and organizational measures designed to protect personal data from unauthorized access, use, disclosure, alteration, loss or destruction.
14.2 Such measures may include access controls, logging, encryption in transit where appropriate, role-based restrictions, security monitoring, secure development practices and internal training.
14.3 No internet or electronic storage system is absolutely secure. Although we work to protect your personal data, we cannot guarantee absolute security.
14.4 If we become aware of a personal data security incident, we will take reasonable response measures and, where required by applicable law, notify affected individuals or authorities.
15. Your Choices and Rights
Subject to applicable law, service design and reasonable verification of your identity, you may have the following rights:
15.1 access to personal data we hold about you;
15.2 correction or update of inaccurate or incomplete data;
15.3 deletion of certain personal data where retention is no longer necessary or processing is not justified;
15.4 withdrawal of consent for specific processing activities based on consent;
15.5 deactivation of app permissions such as location, camera or album access through your device settings;
15.6 objection or complaint regarding certain processing practices where applicable;
15.7 account cancellation, subject to the settlement of outstanding obligations and applicable retention requirements.
Where we cannot fully comply with a request because of legal obligations, unresolved disputes, fraud prevention needs, technical limitations or the rights of others, we may deny or limit the request to the extent permitted by law.
16. How to Exercise Your Rights
16.1 You may review or adjust certain information through your account settings or product interfaces where such functions are available.
16.2 You may contact us to request access, correction, deletion, consent withdrawal, complaint handling or account cancellation.
16.3 For security reasons, we may require identity verification before processing your request.
16.4 We will respond within a reasonable period, subject to the complexity of the request and applicable legal requirements.
17. Minors
17.1 EShare ride services are generally not intended for individuals under eighteen (18) years of age unless applicable law expressly permits otherwise and our service design allows it.
17.2 If we become aware that personal data has been collected from an individual who is not permitted to use the relevant service, we may take steps to restrict the account, stop service access and delete or isolate the data as appropriate.
17.3 If a parent or legal guardian believes that a minor has provided personal data to us improperly, they may contact us to request review and handling.
18. Third-Party SDKs, Tools and Integrations
18.1 EShare may use SDKs, APIs or similar tools supplied by third parties for functions such as mapping, payments, notifications, identity verification, analytics, crash reporting and customer support.
18.2 Those tools may collect device, network, usage or transaction-related information as needed for the relevant function.
18.3 We will seek to ensure that such third parties are bound by appropriate contractual, confidentiality and security obligations where they process personal data for us.
18.4 Where required, we may provide separate SDK notices, permission prompts or product-level disclosures.
19. Exceptions and Legal Disclosures
We may process, share or disclose personal data without additional consent where permitted or required by applicable law, including where necessary to:
19.1 comply with legal obligations or lawful requests;
19.2 protect life, health, safety or significant lawful interests where consent cannot reasonably be obtained in time;
19.3 investigate fraud, abuse, unpaid obligations, theft, vandalism, threats to ride safety or violations of our service rules;
19.4 establish, exercise or defend legal rights or claims;
19.5 support public safety or cooperation with competent authorities.
20. Changes to This Policy
20.1 We may update this Policy from time to time to reflect changes in law, regulation, business operations, service design, risk control practices, technical infrastructure or data handling practices.
20.2 The updated version will be posted through appropriate channels such as the app, website, H5 page, mini-program or related notice interface.
20.3 Where required by law or where changes materially affect your rights, we will provide a more prominent notice before the updated Policy takes effect.
20.4 Your continued use of EShare after the effective date of an updated Policy means that you acknowledge the updated version, except where applicable law requires renewed consent.
21. Governing Framework and Disputes
21.1 This Policy forms part of the broader privacy and data handling framework for EShare services in Pakistan.
21.2 Questions, complaints or disputes relating to privacy or personal data handling should first be raised with us through the contact details below.
21.3 Where a privacy dispute cannot be resolved through communication, the governing law and dispute resolution arrangement stated in the EShare User Service Agreement shall apply, unless mandatory law provides another forum or remedy.
22. Contact Us
If you have questions, concerns, complaints or requests relating to this Policy or your personal data, please contact us through the official customer service channels made available within EShare products.
Beijing Wandian New Energy Co., Ltd.