Privacy Policy of SDLG SERVICE

Dear SDLG SERVICE users: Thank you for using our software, SDLG SERVICE (hereinafter referred to as the "Application"). Thank you very much for your interest in our company. Please read the Privacy Policy of SDLG SERVICE (hereinafter referred to as the "Policy") carefully before using the Application.

Effective date: November 5, 2020

Last updated and issued on: June 20, 2023

The Application will protect the personal information of all users of the Service and treat it with a high degree of diligence and prudence. Except as otherwise specified in the Privacy Policy, the Application will not disclose or provide such information to third parties without your prior permission. The Application will update the Privacy Policy from time to time.

Please carefully read the Privacy Policy (especially the bolded text). You are deemed to have agreed to the entirety of the Privacy Policy upon your agreement to the Privacy Agreement of the Application. The Privacy Policy is an integral part of the Privacy Agreement of the Application.

The Policy will help you understand the following:

I. Applicable Scope of Personal Information

II. How Do We Collect and Use Personal Information

III. Information Storage and Exchange

IV. Personal Information That We May Share, Transfer or Disclose

V. Information Security

VI. Change of the Privacy Policy

VII. Your Rights

VIII. Our Contact Information

I. Applicable Scope

(I) When you register an account of the Application, you need to provide personal registration information, including but not limited to mobile phone number, as required by the Application;

(II) When you use the Application's network services or access the Application's platform, the Application will automatically receive and record information on your mobile phone, including but not limited to your IP address, mobile phone type, access date and time, hardware and software feature information and other data;This application will also receive the operating parameters obtained by the vehicle T-BOX (GPS module), including but not limited to vehicle position, working time, fuel consumption statistics, fault codes, and other data.

(III) The Application will obtain the personal data of users from business partners through legal means.

II. How Do We Collect and Use Personal Information

We will only collect and use your personal information for the following purposes as specified in the Privacy Policy:

1. Help you complete your registration and login

(1)To facilitate our provision of services for you, you need to provide basic user information, including your mobile number, and create your account and password.

(2)To facilitate our provision of services for you and prevent others from maliciously logging in to the Application by using your account, you need to provide your mobile phone's IMEI.

2.To enable you to use the services provided by third-party companies and achieve better user experience,in our business operations and in order to provide services for you, we may need to use your personal data, process your personal data and transmit your personal data to third parties, includes service providers, agents, affiliated companies, and other third parties. We are committed to ensuring that third parties and our affiliated companies protect your personal data from unauthorized access or any risks of the same nature, and only process your personal information for the purposes disclosed in this privacy policy, and use sufficient security measures to protect your personal information which may be located overseas. Which is detailed in "Sharing with authorized partners" of Article IV of the Policy.

3. You understand and agree that some individual services may require you to enable certain access permissions (e.g., permissions to access your location information, camera, photo albums and local storage) on your device to enable the collection and use of the information covered by such access permissions. When you need to disable this function, most mobile devices will support your requirement. Please refer to or contact your mobile device service provider or manufacturer for the specific method. Please note that you are deemed to have authorized us to collect and use relevant information to provide you with corresponding services by enabling any permission, or have cancelled such authorization by disabling any permission, in which case we will no longer collect and use relevant information based on the corresponding permission or provide you with services corresponding to such permission. However, your decision to disable the permission will not affect the previous collection and use of information based on your authorization.

The permissions that you need to enable are described as follows:

（1）(1) Location information: We access your location information, based on which we provide you with customized features, and we will use the location information when you use functions such as reporting a device repair.

（2）Camera permission:We obtain such permission, so that you can use the camera for scanning QR codes or shooting in scanning, uploading attachments and other scenes. We will use the camera permission to take photos when you use the functions of making anti-counterfeiting queries by scanning, entering the device number of additional devices by scanning codes, and giving feedback on problems by uploading photos.

（3）Permission to access photo albums:We access your photo albums to enable you to access and upload photos, pictures or videos in your mobile phone. We will only access your photos or videos for use or uploading when you are giving feedback on any problem by uploading any attachment.

（4）Local storage permission:We will access your local memory to store your operations on the Application and other information.

（5）Calling permission:We use your mobile phone's calling function to quickly call the service personnel and to make information complaints. We will use the calling permission to make a call when you report a repair, use personal information complaint channels, and use other functions.

Permissions required by the Application can be granted at your discretion. To enable or disable any permission, please follow the following steps:

a. Click settings

b. Find the Application in the application list

c. Click the Application to view or modify permission settings

Note: If you disable the location information permission, some functions that require location information will not be available while other functions will not be affected. Please operate with caution.

4.Notice on sensitive personal information

The above information provided by you or collected by us may contain your sensitive personal information such as your name, telephone number and location information. Please be cautious and aware of your sensitive personal information. When you agree to the Privacy Policy of the Application, it will be deemed that we can process your sensitive personal information for such purposes and in such manner as specified in the Policy.

5.Pushing messages to you

Provide you with notices. We may provide you with notices relating to the services when necessary. If you do not wish to continue receiving messages from us, you may require us to stop pushing them by, for example, modifying the settings in your mobile device, except where we are required by law to send messages.

6.Exceptions for obtaining authorization or consent

In accordance with relevant laws and regulations, your authorization or consent is not required for the collection of your information under the following circumstances:

(1) Where it is related to national security and national defense security;

(2) Where it is related to public safety, public health or major public interests;

(3) Where it is related to criminal investigations, prosecutions, trials, enforcement of court decisions, etc.;

(4) Where it is difficult to obtain your consent but the purpose is to protect the vital legitimate rights and interests of the information subject or other individuals such as life and property;

(5) Where the collected information is disclosed to the public by you on your own initiative;

(6) Where the information is collected from lawfully and publicly disclosed channels, such as lawful news reports and government information disclosure;

(7) Where it is necessary for signing a contract at your request;

(8) Where it is necessary for maintaining the safe and stable operation of the services offered by the Application, such as identification or disposal of product or service failures;

(9) Where it is necessary for lawful news reports;

(10) Where it is necessary for an academic research institution to conduct statistical or academic research in the public interest, and when academic research or description results are made available to the public, the information contained in the results is de-identified;

(11) Other circumstances as stipulated by laws and regulations.

III. Information Storage and Exchange

The information and materials about you collected by the Application will be stored on the server(s) of the Application and/or its affiliates.

IV. Personal Information That We May Share, Transfer or Disclose

(I) Sharing

We will not share your personal information with companies, organizations and individuals other than the provider of the Application, except under the following circumstances:

1. Sharing under legal circumstances: We might share your personal information externally according to laws and regulations, the needs for litigation or dispute resolution or the requirements put forward by administrative and judicial authorities under the law;

2. Sharing with explicit consent: We will share your personal information with other parties with your explicit consent.

3. Fulfilling the purposes set out in Article 2 "How Do We Collect and Use Personal Information" of the Policy;

4. Sharing with authorized partners: Some of our services will be provided by authorized partners solely for the purposes stated in the Policy. We may share some of your user information with our partners to provide better customer services and user experience. We will only share your user information for lawful, legitimate, necessary, specific and explicit purposes, and will only share the user information that is necessary to provide services. In order to better operate and improve our technology and services, you agree that we and our authorized partners may use the information collected for other services and purposes, subject to applicable laws and regulations. For example, when we provide message pushing services, we will collect the device identifier (IMEI/Mac/android ID/IDFA/OPENUDID/GUID and SIM's IMSI), which is used to uniquely identify the device, to push messages to the target device. When using the sharing feature, we collect device identifier (IMEI/Mac/android ID/IDFA/OPENUDID/GUID and SIM's IMSI) and public information on social media accounts to share messages with the target device and designated social media accounts.We have listed on a case-by-case basis relevant software development kits (SDKs) and privacy policies of authorized third-party partners who may use user information. Please refer to the Third-Party SDK Usage for SDLG SERVICE

(II) Transfer

1. As our business continues to grow, we may enter into mergers, acquisitions, asset transfers or similar transactions, and your information may be transferred as part of such transactions. We will require the new company or organization that holds your personal information to continue to be bound by the Policy; otherwise we will require the new company or organization to seek your authorization or consent again. If the purpose of using personal information changes, we will ask the company or organization to obtain your explicit consent again.

2. We will share your personal information with other parties with your explicit consent.

(III) Disclosure

We will disclose your personal information only under the following circumstances and subject to safety precautions in line with industry standards:

1. We will disclose such information as specified by you in such manner as explicitly agreed by you according to your needs.

2. If we are required to provide your information by laws, regulations or mandatory administrative law enforcement or judicial requirements, we may disclose your information according to the required type of information and in the required manner. Subject to laws and regulations, when we receive a request for disclosure of information as described above, we will require that the recipient must produce an appropriate legal document, such as a summons or letter of inquiry. We firmly believe that the information that we are required to provide should be as transparent as possible to the extent permitted by law. We will review all requests carefully to ensure that they have a legitimate basis and only cover data that law enforcement authorities have a legitimate right to obtain for specific investigation purposes.

V. Information Security

(I) The accounts on the Application are all under security protection, please keep your mobile phone number and password properly. The Application will ensure that your information is not lost, misused or altered by security measures such as encryption of your password. Notwithstanding the above security measures, please note that there are no "perfect security measures" on the information network.

(II) We only allow employees and partners of the Application who are necessary to know such information to access your personal information, and have set up strict access permission control and monitoring mechanisms for this purpose. We also require all persons who may come into contact with your personal information to fulfill the corresponding confidentiality obligation. Those who fail to fulfill the obligation may be subject to legal liability or suspension of the cooperation relationship with the Application.

(III) We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected.

(IV) The Internet is not an absolutely secure environment, and it is not possible to determine whether means of communication with other users such as e-mail, instant messaging, social networking software or other service software are fully encrypted. We recommend that you should use complex passwords when using such means and take care to protect the security of your information.

(V) The Internet environment is not 100% safe. We will do our best to ensure or guarantee the security of any personal information you send to us. If your legitimate rights or interests are damaged due to any unauthorized access to, or public disclosure, falsification or destruction of your personal information as a result of damage to our physical, technical or managing or protective facilities, we will bear corresponding legal liability.

(VI) Technical measures for data security

1. We will use safety precautions in line with industry standards, including reasonable systems and specifications and security technologies, to prevent unauthorized access or modification to your personal information and avoid the damage to or loss of data.

2. Our services adopt a variety of encryption technologies. We will use encryption technology SSL, etc. to protect your personal information, adopt encryption technologies to encrypt and save your personal information and isolate it through isolation technologies.

3. In the use of personal information, such as information display and associated information calculation, we will use a variety of data desensitization technologies to enhance the security of information in use.

4. We will also use strict data access permission control and multiple identity authentication technologies to protect personal information and avoid unauthorized use of data.

VI. Change of the Privacy Policy

(I) If we decide to change the Privacy Policy, we will post those changes in the Policy, on our website and at locations as we deem appropriate so that you are aware of how we collect and use your personal information, who can have access to it and under what circumstances we will disclose it.

(II) We reserve the right to modify the Policy at any time, so please check it frequently. If we make major changes to the Policy, we will post an updated version of the Policy on the Application and notify you in a pop-up before the changes take effect, so that you can keep up to date with the latest content of the Policy. By clicking the consent button in the pop-up window, you acknowledge that you have fully read, understood and accepted the revised Policy and agreed that we will collect, use, store and share your personal information in accordance with the revised Policy.

To prevent disclosure of your personal information, such as contact information or postal address, to third parties, please protect your personal information properly and provide it to others only when necessary. If you find a leakage of your personal information, especially the account name or password on the Application, please contact the customer service of the Application immediately so that the Application can take appropriate measures.

VII. Your Rights

During your use of the APP, in order to make it easier for you to access, correct and delete your personal information, and to protect your right to withdraw your consent to the use of personal information and to de-register your account, we have provided you with the corresponding operation settings in the product design. You can refer to the following guidelines for operation. In addition, we have also set up a complaint and reporting channel, and your comments will be dealt with in a timely manner.

(I) Access to personal information

1. Access to basic information such as nickname, name and mobile phone number: