Car Key+ Privacy Policy Car Key+ is a product developed by Dongguan Fengli Technology Co., Ltd. ("we," "us," or "our") that provides Internet of Vehicles (IoV) services. This Privacy Policy explains how we collect, use, store, and protect your personal information and informs you of your rights. It covers the following: 1.What Personal Information We Collect 2.Use of Cookies and Similar Technologies 3.How We Use Your Personal Information 4.How We Entrust Processing, Share, Transfer, and Disclose Your Personal Information 5.How We Protect Your Personal Information 6.Your Rights 7.Protection of Minors' Information We understand the importance of personal information to you and are committed to protecting its security and reliability. We strive to maintain your trust by adhering to the following principles: accountability, purpose limitation, consent, data minimization, security integrity, individual participation, and transparency. We promise to adopt appropriate security protection measures in accordance with industry standards to protect your personal information. Please read this Privacy Policy carefully before using our products or services. 1. What Personal Information We Collect Personal information refers to any information recorded electronically or otherwise that can identify a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person. 1.1 During APP Registration: When you register for the Car Key+ APP, we collect your mobile phone number to serve as your account login name. We use an SMS verification code to validate your identity. Collecting your phone number is necessary to fulfill relevant legal requirements for real-name registration. We also collect your login password. Your password is sensitive information; we collect it to authenticate your identity and authorize sensitive operations like password changes. If you do not provide this information, you may not be able to use our services normally. You may also choose to upload an avatar, provide a username, nickname, gender, and birthday to enhance your profile. Providing this information is optional and not required for registration or use of our other services. 1.2 During APP Login: You can log in to the Car Key+ APP using your email address and password. We collect this information to facilitate your login and protect your account security. 1.3 During Service Use: When you use Car Key+ services, we collect your unique device identifier, software version number, operating system version, network service provider, network access type and status, International Mobile Equipment Identity (IMEI), list of installed applications, MAC address, device model, device type, device version, device accelerometer data, operation logs, and service log information. This information is collected to identify abnormal account status, understand product compatibility, ensure the secure and stable operation of our services, improve and optimize your service experience, and protect your account security. If you disagree with the collection of this information, you may not be able to complete risk control verification. 1.4 Account Deletion: If you need to delete your account, please go to the Car Key+ APP, enter "Personal Center," click on your user avatar to access the "Personal Information" page, where you will find the "Delete Account" function. Click "Delete Account" and verify your phone number to proceed with account deletion. (Note: Original had two sections 1.4, merged logically). 1.5 Vehicle Control Services: When you use vehicle control services, we collect your unique device identifier, Bluetooth MAC address, operation logs, and information related to the opening/closing of doors, windows, sunroof, headlights, and the locking/unlocking of doors. To verify your identity for these functions, you may choose to use a static password or fingerprint authentication. The fingerprint verification is performed on your device; we only receive the verification result and do not collect your fingerprint data. If you prefer not to use fingerprint verification, you can use alternative methods. If you do not consent to the collection of this information, you may not be able to use the vehicle control features, but this will not affect your use of our other services. 1.6 Location Services: When you use location services, we collect your vehicle's location information to allow you to view it and navigate to it. Vehicle location is sensitive information. If you do not consent to the collection of this information, you may not be able to use the location services, but this will not affect your use of our other services. 1.7 Legal Exceptions: In accordance with relevant laws, regulations, and national standards, we may collect and use your personal information without your prior consent in the following circumstances: (1) Where it is directly related to national security or national defense security; directly related to public security, public health, or significant public interests; (2) Where it is directly related to criminal investigation, prosecution, trial, or execution of judgments; (3) Where it is necessary to protect your life, property, reputation, or other significant legitimate rights and interests, but obtaining your consent is difficult; (4) Where the personal information is disclosed by you to the public on your own initiative; (5) Where the personal information is collected from legally publicly disclosed information, such as legitimate news reports or government information disclosure channels; (6) Where it is necessary for concluding or performing a contract at your request; (7) Where it is necessary for maintaining the safe and stable operation of our products or services, such as discovering and handling product or service failures; (8) Where it is necessary for legitimate news reporting; (9) Where it is necessary for statistical or academic research in the public interest, and the results of such research are provided to the public after de-identification of the contained personal information; (10) Other circumstances prescribed by laws and regulations. 1.8 Car Key+ Permissions (1) Read/Write Storage Permission: This permission is requested upon app installation to ensure stable operation. We commit to only reading and writing necessary information. (2) Camera & Photo Library Permissions: Required when using functions like Scan, Avatar setting, or photo/video feedback for uploading images. If you do not grant these permissions, you cannot use the specific related functions, but other app services remain available. (3) Location Permission (Precise): After login, you can choose to enable this permission to receive service recommendations based on your location. If you decline, you will not receive such recommendations, but other app services remain available. (4) Read Phone State Permission: Requested during login to read device identification information, device status, and device environment information for risk control and device authentication. Denying this permission may prevent you from completing risk control verification and using features like Bluetooth keys that require device verification. (5) Auto-Start: Used to ensure you receive push notifications on time. Disabling auto-start in your device settings (e.g., Settings > Apps > Auto-Start Management) may prevent notifications from working correctly. 2. Use of Cookies and Similar Technologies When you use the Car Key+ APP services, we may use cookies and similar technologies to identify you. Cookies are small data files that can save you from re-entering registration information, help assess your account's security status, and provide a smoother access experience. We will not use cookies for any purposes other than those described in this policy. Please understand that some services can only be implemented using cookies. You can manage or delete cookies based on your preferences. Modifying your browser settings or clearing all cookies within the app may affect the convenience and security of your service usage. 3. How We Use Your Personal Information To comply with applicable laws and regulatory requirements, provide services to you, ensure service quality, and protect your account security, we use your information in the following circumstances: (1) To achieve the purposes described in Section 1 ("What Personal Information We Collect"); (2) To report to relevant authorities as required by laws, regulations, or regulatory requirements; (3) To invite you to participate in customer surveys related to our services; (4) To ensure service security and help us better understand our application's performance, we may record information such as application usage frequency, crash data, overall usage, performance data, and application source. We do not combine information stored in analytics software with personally identifiable information you provide within the application. (5) If we use your personal information for purposes beyond what was initially stated or directly related, we will inform you again and obtain your explicit consent before such use. 4. How We Entrust Processing, Share, Transfer, and Disclose Your Personal Information 4.1 Entrusted Processing: Certain specific modules or services within the Car Key+ APP may be provided by external suppliers. For example, we may engage service providers to assist with customer support. We sign strict confidentiality agreements with companies, organizations, and individuals that process personal information on our behalf, requiring them to adhere to confidentiality obligations, implement effective security measures, and prohibiting them from using the information for unauthorized purposes. 4.2 Sharing: We do not share your personal information with any company, organization, or individual outside our company, except in the following cases: (1) With your explicit consent: We may share your personal information with third parties after obtaining your prior consent; (2) Necessary for providing services: Some products or services may be provided by third parties (e.g., suppliers, contractors, agents, developers) or jointly by us and a third party. Sharing your information is necessary to provide the requested product or service. If we share your information with such third parties, we require them to handle the information with effective confidentiality and security measures. (3) With your explicit consent, we may share your information with third parties within the scope permitted by law and your authorization. (4) We may be required to share your personal information due to laws, regulations, legal processes, litigation, or mandatory requirements from governmental authorities. 4.3 Transfer: We will not transfer your personal information to any other company, organization, or individual, except in the following cases: (1) With your explicit consent: After obtaining your explicit consent, we may transfer your personal information; (2) During mergers, acquisitions, or bankruptcy liquidation: If a transfer of personal information is involved, we will require the new holder of your information to be bound by this Privacy Policy, or we will require them to seek your authorization and consent again. 4.4 Public Disclosure: We will only publicly disclose your personal information under the following circumstances: (1) With your explicit consent; (2) Based on law: We may disclose your personal information if required by law, legal process, litigation, or mandatory government requests. 4.5 Exceptions to Consent Requirement: According to relevant laws, regulations, and national standards, in the following circumstances, we may share, transfer, or publicly disclose your personal information without seeking your prior consent: (1) Directly related to national security or defense security; (2) Directly related to public security, public health, or significant public interests; (3) Directly related to criminal investigation, prosecution, trial, or execution of judgments; (4) Necessary to protect your life, property, or other significant legitimate rights and interests where obtaining your consent is difficult; (5) Personal information you have voluntarily disclosed to the public; (6) Personal information collected from legally disclosed information, such as legitimate news reports or government information disclosure. 5. How We Protect Your Personal Information We value the security of your personal information and strive to implement appropriate measures to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction. Specifically, we take the following measures: (1) We use industry-standard security safeguards to protect the personal information you provide, preventing unauthorized access, disclosure, use, modification, damage, or loss. We take all reasonably feasible measures, such as trusted protection mechanisms against malicious attacks, encryption during transmission using SSL, encryption of sensitive information, and data anonymization to protect your data. (2) We deploy access control mechanisms to ensure only authorized personnel can access personal information. We limit the number of authorized personnel based on business needs and implement hierarchical permission management. All access to personal data is logged and regularly audited by administrators. (3) In the event of a personal information security incident, we will act according to the law by initiating emergency plans to prevent the incident from expanding. We will notify you via push notifications, announcements, etc., of the basic situation and potential impact of the incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures for you. We will also report the handling of the incident to regulatory authorities as required by laws and regulations. 6. Your Rights You have rights regarding your personal information, subject to certain exceptions under applicable law. 6.1 Access and Correction: You have the right to access and correct your personal information. You can usually do this yourself within the app: (1) Profile Information: Enter the Car Key+ APP, click "Me," then click your avatar to view and edit your avatar, nickname, gender, and phone number. (2) Vehicle Information: Enter the Car Key+ APP, click "Me," then click "Vehicle Management" to access the vehicles linked to your account. Click on a vehicle to view and edit details like vehicle nickname, license plate number, and model. 6.2 Other Rights: Depending on your jurisdiction, you may also have the right to: * Request deletion of your personal information. * Restrict or object to the processing of your personal information. * Data portability (receiving your data in a structured, machine-readable format). * Withdraw your consent where processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise these rights, please contact us using the details provided in the "Contact Us" section (which should be added to your policy elsewhere). We will respond to your request in accordance with applicable laws. 7. Protection of Minors' Information We highly value the protection of minors' personal information. In accordance with relevant laws, we do not knowingly collect personal information from minors under the age of 18. If you are a minor, please do not provide us with your personal information without consent from your parent or guardian. If we become aware that we have collected personal information from a minor without verifiable parental consent, we will take steps to delete that information as soon as possible.