Lingbo Electronic Privacy Policy

Introduction

Thank you for your interest in Wuxi Lingbo Electronic Technology Co., Ltd. and its affiliates (hereinafter referred to as "Lingbo Electronics" or "we"), as well as the various hardware, firmware, software, websites, applications, and services we provide (hereinafter collectively referred to as "products" or "services", collectively referred to as "Lingbo Electronic Products and Services"). This "Lingbo Electronic Privacy Policy" (hereinafter referred to as "this policy"/"this privacy policy") is intended to help you understand how we collect, use, and store your personal information and what rights you have. We fully understand the importance of personal information to you and will strive to protect your information security and hand over control to you.

Before you begin using Lingbo Electronic products and services, please read and fully understand this policy. By using Lingbo electronic products and services, you agree that we will use and process your related information in accordance with this privacy policy. You have the right to refuse to agree to this policy, but please be aware that if you choose to refuse, you may not be able to fully use Lingbo Electronics' related services and functions, or fail to achieve the intended service effects. This policy incorporates and is bound by the terms of use of Lingbo electronic products and services you use.

This policy describes:

1. The information we collect and use

We will collect and use personal information about you or third parties from you or third parties during your use of Lingbo electronic products and services, in accordance with laws and regulations and in accordance with the principles of legality, legitimacy, necessity, and good faith. The personal information we collect and use for you includes: (1) Information necessary for the core business functions of Lingbo electronic products and services, which is essential for the normal operation of products and services. If you refuse to provide it, you will not be able to use our products and services normally; (2) Information that may be collected for additional business functions. You may choose whether to authorize us to collect such information. If you refuse to provide it, you will not be able to use the relevant additional functions normally, but it will not affect your normal use of core business functions. We only collect and use necessary information and only to provide you with the corresponding product services. We guarantee that your personal information will not be used for other purposes.

We collect and use your personal information in the following scenarios:

1. Account registration and login

(1) When you register and log in to the Lingbo Electronic App, we will collect your following information: username, mobile phone number, email, password, to create your personal account and verify identity to ensure account security. This information is essential for the core business functions of Lingbo Electronic products and services. If you refuse to provide the above information, we will not be able to provide you with services.

(2) You may also choose to log in using a third-party platform account (such as WeChat). If you log in using a third-party platform account, we will obtain the relevant information (username, profile picture) under that third-party platform account with your authorization, and we will still require you to provide your mobile phone number for identity verification. If you refuse to provide the above information, you will not be able to log in using the third-party platform account, but this will not affect the normal use of other functions.

(3) Collecting and using your mobile phone number is to meet the requirements for authentic identity verification under relevant laws and regulations. Refusing to provide it may result in you being unable to register an account.

(4) After logging into your account, you can further improve your information, modify your nickname, avatar, etc. If you choose to change your profile picture, you need to provide your phone's photo album information.

2. Connection and control equipment

When you use the Lingbo Electronic App (such as the "Lingbo Intelligent Control" App) to connect to Lingbo Electronic product devices (including motor controllers, BMS battery management systems, etc.), we collect your device's location information, Wi-Fi list information, device serial number/SN code, device logs, device status, usage history, and Bluetooth information (including mobile MAC address, device name, device service information, Bluetooth signal strength), helping you connect your phone to your device and control the device via your phone. After connecting, you can monitor the operating status of your device (such as motor parameters, battery voltage, current, temperature, etc.) through the Lingbo Electronic App and perform remote control or parameter settings. This is a core business function of Lingbo Electronics' products and services. If you choose not to provide the above information, you will not be able to use this core function.

3. Maintain the operation of the application system

During your use of the Lingbo Electronics App, we will collect information about your mobile device, including: Mac address, CPU information, memory information, SD card information, and operating system version, to collect abnormal information about the application and report errors when problems arise, ensuring stable and secure system operation.

4. Equipment operation data

When you connect Lingbo Electronics' motor controller or BMS management system to your electric vehicle (such as electric motorcycles, electric golf carts, sightseeing vehicles, electric yachts, etc.), we may collect motor operating data (speed, torque, temperature, etc.) and battery management data (voltage, current, temperature, SOC estimates, SOH health status, etc.) to optimize product performance, provide fault diagnosis, and improve service quality.

5. Contact information

When you place an order or contact us for customer service, we may need your contact information, such as your name, email address, delivery address, and phone number.

6. Issue feedback

If you have a problem to report to us, you can more clearly describe your problem by uploading photos or videos. If you choose to upload photos or videos, we will collect your phone album information.

7. Push notifications

If you enable message notification permissions, to ensure that the Lingbo Electronic App receives message pushes (such as device alarms, firmware update notifications, etc.) properly when closed or running in the background, and to send commands to Lingbo electronic devices via Bluetooth, our app may use a self-start function (Android version only) and will also collect Bluetooth information from your mobile device. If the message notification permission is disabled, there will be no automatic start.

8. Other information

Details such as the timing, topics, and content of your communication with Lingbo Electronics.

2. Device permission call instructions

During the collection and use of the above personal information, we will mainly use the following mobile device permissions. Enabling any of these permissions authorizes you to collect and use relevant personal information to provide you with corresponding services. You may also choose to change the scope of consent or withdraw your authorization at any time. After withdrawing authorization, we will no longer collect personal information related to these permissions and will no longer be able to provide corresponding services. However, your decision to withdraw consent or authorization will not affect our previous collection and use of personal information based on your authorization. When we intend to use information for other purposes not specified in this policy, we will seek your consent in advance.

3. How we share, transfer, and publicly disclose your personal information

1. Sharing

We will not share your personal information with any company, organization, or individual other than Lingbo Electronics, except in the following cases:

(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

(2) We may share your personal information externally in accordance with laws and regulations, or as required by government authorities.

(3) Sharing with our affiliated companies: Your personal information may be shared with Lingbo Electronics' affiliated companies. We will only share necessary personal information and be bound by the purposes stated in this privacy policy. If affiliated companies wish to change the purpose of processing personal information, they will seek your authorization and consent again.

(4) Sharing with Authorized Partners: For the purposes stated in this policy, certain of our services will be provided by authorized partners. We may share certain personal information of yours with partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose.

2. Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

(2) In cases involving mergers, acquisitions, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue being bound by this privacy policy; otherwise, we will require the company or organization to seek your authorization and consent again.

3. Public disclosure

We will only publicly disclose your personal information under the following circumstances:

(1) After obtaining your explicit consent;

(2) Disclosure based on law: In cases of law, legal procedures, litigation, or mandatory requirements from government authorities, we may publicly disclose your personal information.

4. How We Protect Your Personal Information

1. We have implemented industry-standard security measures to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information.

2. We will take all reasonable and practicable measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension is required or permitted by law.

3. We will regularly provide employees with training on information security and data protection, and sign confidentiality agreements with all employees who come into contact with your personal information.

4. The internet environment is not 100% safe. We will make every effort to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, alteration, or destruction of information, resulting in harm to your legitimate rights and interests, we will bear corresponding legal responsibility.

5. In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions you can independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the incident-related information via email, letter, phone, push notification, etc. If it is difficult to notify each personal information subject individually, we will issue an announcement in a reasonable and effective manner.

5. Your rights

In accordance with relevant laws, regulations, standards, and practices in other countries and regions, we guarantee that you exercise the following rights regarding your personal information:

1. Access and correct your personal information

You have the right to access your personal information, except in cases stipulated by laws and regulations. If you wish to exercise your data access rights, you can view and edit your personal information in the "Personal Center" by logging into your account.

2. Deleting your personal information

You may request deletion of personal information from us in the following circumstances:

(1) If our handling of personal information violates laws and regulations;

(2) If we collect or use your personal information without obtaining your consent;

(3) If our handling of personal information violates our agreement with you;

(4) If you no longer use our products or services, or if you cancel your account;

(5) If we no longer provide you with products or services.

3. Change the scope of your authorized consent

Each business function requires some basic personal information to be completed. For the collection and use of additional personal information, you may grant or withdraw your authorized consent at any time. You can withdraw your consent by disabling device permissions or other means.

4. Cancel your account

You may cancel your previously registered account at any time. You can cancel your account by contacting our customer service or using relevant functions in the app. After canceling an account, we will stop providing you with products or services and delete your personal information at your request, except as otherwise provided by laws and regulations.

5. Respond to your above request

For security, you may need to provide a written request or other ways to prove your identity. We may first ask you to verify your identity before processing your request. We will respond within thirty days.

In the following circumstances, according to laws and regulations, we may not be able to respond to your request:

(1) Directly related to national security or national defense security;

(2) Directly related to public safety, public health, or major public interests;

(3) Directly related to criminal investigation, prosecution, trial, and judgment enforcement;

(4) There is sufficient evidence that you have subjective malice or abuse of rights;

(5) Responding to your request would cause serious harm to the legitimate rights and interests of you or other individuals or organizations;

(6) Involving trade secrets.

6. How do we handle children's personal information?

Our products, websites, and services are primarily aimed at adults. Children may not create their own user accounts without parental or guardian consent.

For cases where children's personal information is collected with parental consent, we will only use or publicly disclose such information when permitted by law, with the explicit consent of parents or guardians, or when necessary to protect the child.

If we discover that we have collected a child's personal information without prior verifiable parental consent, we will try to delete the relevant data as soon as possible.

7. How your personal information is transferred globally

Personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. We will not transfer your personal information abroad, except as otherwise provided by laws and regulations.

8. How this policy is updated

Our Privacy Policy may be subject to change. Without your explicit consent, we will not reduce your rights under this Privacy Policy. We will post any changes to this Policy on this page.

For major changes, we also provide more prominent notifications (including, for certain services, we send notifications via email explaining the specific changes to the privacy policy).

The significant changes referred to in this policy include but are not limited to:

(1) There have been significant changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and the methods of personal information being used;

(2) Significant changes in ownership structure, organizational structure, etc., such as business adjustments, bankruptcy mergers, and other changes in ownership;

(3) The main recipients of personal information for sharing, transferring, or publicly disclosing have changed;

(4) There have been significant changes in your rights to participate in personal information processing and how they are exercised;

(5) When our contact methods and complaint channels for personal information security change;

(6) When the personal information security impact assessment report indicates a high risk.

9. How to contact us

If you have any questions, comments, or suggestions regarding this Privacy Policy, or if you encounter any privacy-related issues while using Lingbo electronic products and services, you can contact us through the following methods:

Company Name: Wuxi Lingbo Electronic Technology Co., Ltd

Contact Address: Building A, No. 167 Jinghui West Road, Xin'an Street, Xinwu District, Wuxi City, Jiangsu Province

Contact number: 0510-66078688

Email:lb_service@lingbomc.com

We will review the issues as soon as possible and respond promptly after verifying your identity, generally within thirty days.

If you are dissatisfied with our response, especially if our personal information processing actions have harmed your legitimate rights and interests, you may file complaints or reports with regulatory authorities such as the Cyberspace Administration, Telecom, Public Security, and Industry and Commerce.