ZERON Privacy Policy
Updated: September 20, 2026
Effective: April 30, 2024
Introduction
Jiangsu ZERON Automotive Technology Co., Ltd. (hereinafter referred to as "ZERON" or "we") values and is committed to protecting users' personal information and privacy. We (including our affiliated companies and specific partners; for a detailed list, please click here: *List of Affiliated Companies and Partners*) provide ZERON products and services to you through the ZERON official website, ZERON App, and other platforms or scenarios that we may offer now or in the future, through which we may process personal information related to you. This Privacy Policy is designed to explain to you how we collect, use, store, share, and protect your personal information, as well as how you can exercise your rights.
We provide ZERON products/services to you through the ZERON official website, ZERON App, and other platforms or scenarios that we may offer now or in the future, through which we may process personal information related to you. This Privacy Policy is closely related to your use of our various products/services. The personal information we collect and process may vary depending on the specific product/service scenario, and the specific scenario of your use of the product/service shall prevail. Before using our products/services, please be sure to carefully read and confirm that you fully understand the contents set out in this Privacy Policy, so that you can make choices you deem appropriate based on the guidance of this Privacy Policy.
We will collect and use your information in accordance with this Privacy Policy when you use the corresponding products/services, but we will not collect personal information in a mandatory bundled manner solely because you have agreed to this Privacy Policy. The actual circumstances of the products/services you use shall prevail. If a specific product/service has a separate privacy policy, that separate privacy policy will take precedence. We strive to use concise and easy-to-understand language, and for clauses that have a significant bearing on your rights and interests and the personal sensitive information involved, **we use bold text to highlight them conspicuously to draw your attention. Please read them carefully.
If you have any questions, comments, or suggestions regarding this Privacy Policy, you may contact us through the contact information provided in the "Contact Us" section of this Privacy Policy.
This Privacy Policy will help you understand the following:
I. How We Collect and Use Your Personal Information
II. How We Provide, Transfer, and Publicly Disclose Your Personal Information
III. How We Store Your Personal Information
IV. How You Manage Your Personal Information
V. How We Protect Your Personal Information
VI. Protection of Minors' Personal Information
VII. Updates to the Privacy Policy
VIII. Contact Us
I. How We Collect and Use Your Personal Information
We will follow the principles of lawfulness, legitimacy, and necessity, and based on the following purposes described in this Privacy Policy, collect and use your personal information that you actively provide during the use of products/services, that is generated from the use of products/services, or that is obtained from third parties with your authorization, in order to enable you to enjoy our products/services, communicate with you, and improve or optimize our products/services.
We adhere to the following principles in protecting your personal information: lawfulness, legitimacy, necessity, good faith, reasonable and clear purposes, consent, data minimization, security, individual participation, and transparency. We also adopt appropriate security measures to protect your personal information.
As our business develops, the products/services we provide may be adjusted and changed. If we intend to use your personal information for other purposes not specified in this Privacy Policy, or to use information collected for specific purposes for other purposes, we will inform you in a reasonable manner and obtain your consent again before such use, unless there are other lawful bases or legitimate reasons for processing your personal information.
(1) Scenarios of Personal Information Collection for ZERON Products/Services
1. Account Registration and Login
When you register for or log in to a ZERON App account, we will collect your mobile phone number to verify your identity and to create your ZERON account. Phone numbers are sensitive personal information. Refusal to provide this information will prevent the ZERON App functions from working properly, but will not affect your normal use of the vehicle. We will store this information for the duration of your use of our products and/or services. You may also contact us through the contact information specified in this Privacy Policy to separately request a storage period setting for sensitive personal information.
If you register an account through the ZERON App or ZERON WeChat Mini Program, you may log in to and use vehicle-side functions. The following sections describe the collection and processing of personal information in relevant scenarios.
2. Account and Security Management
To provide you with better services (such as related sharing functions), you may voluntarily choose to set your profile picture, nickname, and login password during account registration. Refusal to provide this information will not affect your normal use of the basic functions of the ZERON App.
3. Vehicle Use and Remote Vehicle Management
During your use of the vehicle, to achieve the purpose of your vehicle driving and riding and the use of related on-board products/services, we will collect and use your vehicle information, vehicle condition information, on-board SIM card-related information, interior and exterior camera image data, and charging/battery swap and maintenance information. This information will be used to ensure the continuous safe operation of the vehicle, identify and resolve potential issues, investigate accidents, and fulfill legal obligations. Among this, interior and exterior camera image data may include facial information captured by cameras, and charging/battery swap and maintenance information may include vehicle location and route information (i.e., location information). The aforementioned information is sensitive personal information. The purpose of collecting such information is to help vehicle users and managers, including you, ensure the continuous safe operation of the vehicle, identify and resolve potential issues, and improve vehicle operational efficiency. Refusal to provide the aforementioned information will prevent you from using the functions related to the [ZERON Automotive App], but will not affect your normal use of other functions of our products or services. We will store this information for the duration of your use of our products and/or services. You may also contact us through the contact information specified in this Privacy Policy to separately request a storage period setting for sensitive personal information.
If you are the vehicle owner, you can remotely manage your vehicle (including viewing real-time vehicle data, setting vehicle information functions, etc.) through the ZERON App on your personal mobile phone.
When you use remote vehicle management, we need to record your vehicle status information, including door lock, window, air conditioning, headlight, or horn open/close or lock/unlock status, historical vehicle driving data, vehicle location information, vehicle runtime, vehicle power consumption, license plate number, vehicle nickname, and vehicle VIN, which will be processed and synchronized to the ZERON App for display. You may authorize us to access your location information. With your permission, we will obtain your location information via GPS.
3.1 Bluetooth Phone
When you connect your mobile phone via the vehicle Bluetooth function and make or answer calls, we need to collect audio signals during the call through the vehicle microphone and transmit them to your mobile phone in real time via the Bluetooth protocol to enable calling. This function requires microphone permission. If you do not enable microphone permission, the Bluetooth phone function will not work properly, but this will not affect your use of other functions.
To enable you to view the name and number of the contact during a call on the vehicle screen, we need to read contact information from your mobile phone and perform local matching for display during the call. This function requires contacts permission.
To enable you to view the number of an incoming or outgoing call on the vehicle screen, we will temporarily read the number generated by the current call. During your use, we will temporarily store call records and contact information; when the Bluetooth connection is disconnected, the temporarily stored information will be automatically deleted. We will not store your call audio, call records, or contact information on the vehicle on a long-term basis. We will not transmit the aforementioned audio data outside the vehicle; call audio is used only for real-time transmission of the current call and no original data will be retained after the call ends.
3.2 Fatigue Monitoring
In accordance with the requirements of the Motor Vehicle Driving Recorder (GB/T 19056-2021), to provide driver fatigue detection services, we need to collect facial images captured by the in-vehicle camera. The recognition process is completed and processed locally on the vehicle and provided to the relevant regulatory authorities. The camera images and analysis results will not be transmitted back to our servers.
3.3 Nearby Services
When you use features such as "Find Nearby Charging Stations," "Find Nearby Service Centers," or "Find Nearby Repair Stations" in the vehicle-side App or Mini Program "My ZERON," we need to collect your current vehicle location (or a location you manually select) and vehicle network access permission to return a list of nearby service points. You may choose not to enable location permission; if you do not enable it, the above functions will not work properly, but this will not affect your use of other functions. The above map and navigation services are provided by our partner Amap Software Co., Ltd. ("Amap"). To provide navigation services, Amap needs to collect and process your vehicle location and destination information.
3.4 Roadside Assistance
When you use roadside assistance, we will obtain the current vehicle location and contact information you provide to our customer service and provide this information to our rescue partner service providers so that rescue personnel can contact you and arrive at the scene quickly.
3.5 Customer Service
When you use the customer service function (including online customer service and telephone customer service) in the vehicle-side App or Mini Program "My ZERON," or contact us through feedback or by submitting a ticket, we will collect your account information, inquiry or complaint content, and the ticket content, screenshots, or attachments you submit, in order to handle your issue. When you use the telephone customer service function in our products, we need to use your phone permission (or the device calling function). If you do not enable it, the above function will not work properly, but this will not affect your use of other functions.
3.6 Over-the-Air (OTA) Updates
To enhance driving safety and continuously optimize vehicle functions, we may provide over-the-air (OTA) updates for the vehicle system from time to time. This requires identification of your vehicle identification number (VIN), system version, and vehicle status information, and we will record the update status.
3.7 Vehicle Networking Card Real-Name Authentication
When you use vehicle networking functions, applicable laws and regulations require you to complete real-name authentication for the vehicle networking card. We will collect your name, mobile phone number, ID number, vehicle identification number (VIN), ID photo, and personal verification video to complete the vehicle networking card real-name registration. The above information is necessary for completing the vehicle networking card real-name registration. If you do not complete authentication, you may be unable to use vehicle networking functions, but this will not affect your use of other services we provide. We will also collect your vehicle activation status, vehicle networking card real-name order number, and real-name status so that you can view the vehicle activation and network connection status in the App.
3.8 Data Transmission to Regulatory Authorities
In accordance with the Road Transport Vehicle Dynamic Supervision and Management Measures and the Motor Vehicle Driving Recorder (GB/T 19056-2021), we collect vehicle identification numbers (VINs), facial features, and voiceprints for upload to government regulatory platforms as required. In accordance with the Road Transport Vehicle Satellite Positioning System Terminal Communication Protocol and Data Format (JT/T 808-2019), we collect location information for upload to government regulatory platforms as required. In accordance with the Electric Vehicle Remote Service and Management System Technical Specification Part 3: Communication Protocol and Data Format (GB/T 32960.3-2025), we collect vehicle identification numbers (VINs) and location information for upload to government regulatory platforms. As a vehicle manufacturer and system supplier, we must comply with national laws, regulations, and regulatory requirements concerning road motor vehicles, vehicle networking, and related matters. Accordingly, we may transmit or report the above information to government authorities in accordance with applicable laws.
Such data transmission is based on statutory obligations or authorizations and generally does not rely on your separate consent. However, we will use our best efforts to protect the security of your personal information within the scope permitted by law and will provide only the minimum necessary data set within the scope and time period required by regulation.
4. Operational Safety and Security
To ensure the stability and security of vehicles, related products/services, and your account, and to improve operational quality and efficiency, we may use the following information obtained during your use of our products/services for identity verification, account security assessment, security prevention and detection, prevention or prohibition of illegal activities, identification of product issues, optimization of product experience, and other applications permitted by laws and regulations: your vehicle information, device information (device model, device ID (IMEI, MAC address, Android ID, IDFA, GUID, IMSI, IP, ICCID, hardware serial number, device serial number), device manufacturer, screen width and height, screen resolution, software version information, operating system and version, running processes), service logs (search, click, browse information and time, IP address, mobile network information), operation logs, operational status, installed application list, device sensors, and other information that you have authorized or consented to share, or that can be legally shared. At the same time, to prevent malicious programs and ensure operational quality and efficiency, we will collect running processes of the software or data stored in the device.
5. Business Operation Analysis and Improvement
For the information we have collected (your usage of our products/services, vehicle information, device information, log information, activity information), we may conduct research, processing, training, statistics, and analysis through technical means after anonymization or de-identification to form information and reports that do not contain personally identifiable information. These may be used for normal business operation purposes such as corporate auditing, or used to improve and optimize our products/services, conduct new product research and development, or provide reference for business decisions. For purposes of research and development, user group analysis, and product/service improvement, we may provide or disclose the aforementioned statistical information and reports that do not contain your personal identifiable information.
(2) How We Use Cookies and Similar Technologies
Cookies and similar device information identification technologies are commonly used technologies on the Internet. When you use our products/services, we may use related technologies to send one or more cookies or anonymous identifiers ("Cookies") to your device to collect, identify, and store information about your access and use of our products/services. We primarily use Cookies to ensure the security and efficient operation of products and services, help you obtain a more convenient access experience, improve products and services, and simplify the steps and processes for you to fill in forms. We will not use Cookies for any purposes other than those stated in this Privacy Policy.
You can manage or delete Cookies according to your preferences. Most browsers automatically accept Cookies, but you can usually modify your browser settings to refuse Cookies as needed. In addition, you can also clear all Cookies saved in the software, but you may consequently be unable to use functions or services that rely on Cookies.
(3) System Permissions Requested by the ZERON App
During your use of this product's related services, the operating system permissions related to personal information that we will request from you are as follows. After permissions are granted, you can view the status of each permission in the Mini Program by going to the upper right corner "[...] - [Settings]", on iOS devices under "[Settings] - [Privacy & Security]", and on Android devices under "[Settings] - [Security & Privacy]". You can enable or disable some or all system permissions at any time.
| Permission | Purpose of Permission Request | Can User Disable |
|---|---|---|
| Phone | Make customer service calls | Yes |
| Files/Storage | Change profile picture, upload feedback-related information | Yes |
| Location | Find nearby sales consultants when applying for a test drive, locate and view distance to charging stations and the vehicle | Yes |
The vehicle-side functions may also use the following permissions: Contacts (to find contacts in your address book for calling), Phone (to make customer service calls), and Network (to search for nearby service stations).
The above permissions will only be activated with your explicit authorization and will only collect your personal information when required by the relevant function or service. If you disable relevant permissions, we may not be able to provide you with the functions corresponding to those authorizations. You can manage the relevant permissions in your system settings according to your actual needs.
Please note that enabling any permission means you authorize us to collect and use the relevant personal information to provide you with the corresponding service. Once you disable any permission, it means you have revoked the authorization. We will no longer continue to collect and use the relevant personal information based on that permission, nor can we continue to provide the service corresponding to that permission. Your decision to disable a permission will not affect the personal information collection and use previously carried out based on your authorization.
(4) Other Rules for Collecting and Using Personal Information
Please be fully aware that according to laws and regulations, when the following legitimate reasons exist, we do not need to obtain your authorized consent to collect and use your personal information:
1) Where it is necessary for the conclusion or performance of a contract to which you are a party;
2) Where it is necessary to perform statutory duties or obligations, such as those directly related to national security, national defense security, public security, and judicial investigation, prosecution, trial, and enforcement of judgments;
3) Where it is necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;
4) Where personal information is processed within a reasonable scope for public interest purposes such as news reporting and public opinion supervision;
5) Where personal information that you have disclosed yourself or that has been otherwise lawfully disclosed is processed within a reasonable scope in accordance with the provisions of the *Personal Information Protection Law of the People's Republic of China*;
6) Other circumstances provided for by laws and administrative regulations.
II. How We Provide, Transfer, and Publicly Disclose Your Personal Information
(1) Provision to Third Parties
We will treat your personal information with a high degree of fiduciary duty. We will not provide your personal information to any company, organization, or individual outside of ZERON unless we have obtained your authorized consent or there are other lawful bases in accordance with applicable laws and regulations.
To provide vehicle networking activation services, the vehicle networking service operator will collect your name and address; vehicle information: vehicle identification number (VIN) and vehicle networking card number (ICCID), to complete real-name authentication in accordance with national laws and regulations, and will transmit the above personal information to the MIIT vehicle networking card platform. Our current partner is Beijing Changxiang Longteng Technology Development Co., Ltd. (registered address: No. 182, Magezhuang South Street, Xiagezhuang Town, Pinggu District, Beijing; contact: 010-89743082).
Some of the products/services we provide require the participation of third parties to be completed. Therefore, we may provide some or all of your personal information to our affiliated companies and specific third-party service providers or partners to ensure and optimize the products/services we provide to you. You agree that we share personal information necessary to provide products and services to you with our affiliated companies and specific third-party service providers or partners. We will strictly restrict and manage the provision of personal information to third parties in accordance with laws and regulations. For scenarios where your personal information is processed on our behalf, we will sign relevant processing agreements with the entrusted party in accordance with legal provisions, require them to process your personal information according to our requirements and this Privacy Policy, and supervise their personal information processing activities. The recipients to whom we provide your personal information include third parties providing vehicle purchase/delivery support services, third parties providing vehicle owner services, suppliers providing technical services and research and development, and third-party logistics services for our online store. You can obtain specific information by consulting the *List of Affiliated Companies and Partners*. We will not provide your personal information to third parties unless:
1) We have obtained your explicit consent or authorization in advance.
2) It is required by mandatory requirements of applicable laws, regulations, or administrative or judicial authorities or government agencies. For example: ① Providing your information as required by laws and regulations, legal procedures, or competent administrative and judicial authorities; ② As required by laws and regulations, we will conduct necessary vehicle data monitoring and connect it to the government new energy vehicle data collection/monitoring platform and the data collection/monitoring platform of ZERON and its affiliated companies.
3) It is to handle disputes between you and others at your request.
4) Rights protection. Where it is necessary to protect the interests, property, or safety of us, our affiliates or partners, you, other users, or the public from damage within the scope required or permitted by laws and regulations.
5) Research on new projects and services. To provide you with better services, ZERON may explore and advance potential business cooperation projects with third-party partners and may share some of your personal information with potential business partners after appropriate processing such as de-identification and anonymization.
Unless we obtain your consent, we will not provide your sensitive personal information to any third party.
(2) Transfer
We will not transfer your personal information to any company, organization, or individual unless we obtain your explicit consent. In the event of transactions involving our merger, acquisition, division, dissolution, asset transfer, etc., where the transfer of personal information is involved, we will inform you of the name and contact information of the recipient before transferring your personal information and require the company, organization, or individual receiving your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require that company, organization, or individual to seek your authorization and consent again.
(3) Public Disclosure
We will comply with relevant laws and regulations and keep your personal information confidential. We will not actively disclose personal information that you have not disclosed yourself, unless required by laws and regulations or with your separate consent.
(4) Third-Party SDKs
To provide you with more professional and secure functions and services, third-party plug-ins (including but not limited to Software Development Kits (SDKs) deployed in this product) may be integrated into this product. Regarding how third parties collect and use your personal information, we recommend that you refer to the relevant third-party service agreements and personal information protection policies.
The integration of third-party plug-ins in this product is as follows:
| SDK Name | SDK Provider | Function/Purpose | Types of Personal Information Collected | Collection Method | Sensitive Permissions Requested | Privacy Policy Link |
|---|---|---|---|---|---|---|
| Amap Open Platform Positioning SDK | Amap Software Co., Ltd. | Lead collection for test drives, car purchase customer service and service communication personnel, locate and view distance to charging stations and the vehicle | Location information (latitude/longitude, precise location, approximate location) [obtained via IP address, GNSS information, WiFi status, WiFi parameters, WiFi list, SSID, BSSID, base station information, signal strength information, Bluetooth information, sensor information (vector, acceleration, pressure), device signal strength information acquisition, external storage directory], device identification information (IMEI, IDFA, IDTV, Android ID, MEID, MAC address, OAID, IMSI, ICCID, hardware serial number), current application information (application name, application version number), device parameters and system information (system properties, device model, operating system, carrier information) | Interface Transmission | Location Permission | https://lbs.amap.com/pages/privacy/ |
III. How We Store Your Personal Information
In accordance with laws and regulations, we will store your personal information collected and generated during our operations within the territory of China, in a data center located in Shanghai under our control. We will not transfer your personal information overseas. If we transfer it overseas, we will strictly comply with relevant laws, regulations, and policy requirements or separately obtain your authorized consent.
We will retain your personal information only for the period necessary to achieve the purposes described in this Privacy Policy, within the scope required by laws and regulations, and for the reasonable period necessary to conduct our business, unless otherwise stipulated by laws and regulations or separately authorized and agreed to by the personal information subject. The storage period of your personal information may vary depending on the products/services you use. Our criteria for determining the storage period of personal information are mainly based on the following:
1) To fulfill the purposes of the products and services related to you, maintain the corresponding product and business records, and respond to your potential inquiries or complaints;
2) To ensure the security and quality of the services we provide to you;
3) Whether you agree to a longer retention period;
4) Compliance with relevant requirements regarding statutes of limitations;
5) Whether there are other special agreements or legal and regulatory provisions regarding the storage period. After the storage period expires, we will delete or anonymize your personal information.
IV. How You Manage Your Personal Information
We highly value your management of your personal information. According to applicable laws and regulations, we will take appropriate technical measures to ensure you can exercise the following rights regarding your personal information. When you exercise your rights, we may require you to provide proof of identity to ensure the confidentiality and security of customer information. We will reply with our processing opinion or result within fifteen (15) days of receiving your request and verifying your identity. If you request deletion of your sensitive personal information, we will reply within ten (10) working days.
(1) Access, Copy, Correct, Supplement, and Delete Your Personal Information
If you wish to access or copy your personal information, including but not limited to ZERON account information, vehicle usage data, etc., you may submit an access or copy request through the contact information in the "Contact Us" section of this Privacy Policy. If you request to transfer your personal information to a personal information processor designated by you, and it complies with relevant national regulations and is technically feasible, we will provide a means for the transfer. Based on certain exceptions, we may deny your request within the scope permitted by applicable laws and regulations.
1) Access and manage personal information in "My → Settings → Account Management," including profile picture, nickname, login password, and account cancellation;
2) Access and manage the ZERON App's use of your mobile phone permissions in "My → Settings → Permission Management," including network, location, photos, camera, notifications, storage.
When you discover that the personal information we process about you is incorrect or incomplete, you have the right to correct or supplement the incorrect or incomplete information, provided that your identity is verified and the correction or supplement does not affect the objectivity and accuracy of the information. You may submit a correction or supplement request through the contact information in the "Contact Us" section of this Privacy Policy, or for personal information collected through ZERON Automotive, you can correct or supplement your relevant personal information as follows:
1) Correct or supplement personal information: Correct or supplement your profile picture, nickname, and password in "My → Settings → Account Management."
2) Correct or supplement permission management: Correct or supplement whether to allow the ZERON App to use your mobile phone permissions, including network, location, photos, camera, notifications, storage, in "My → Settings → Permission Management."
Under the following circumstances, you may submit a request to delete your personal information through the contact information in the "Contact Us" section of this Privacy Policy, except where personal information has been anonymized or laws and regulations provide otherwise. Your identity will need to be verified for deletion, and please specify the specific types of personal information to be deleted. We will decide whether to respond to your request in accordance with national laws, regulations, and regulatory requirements:
1) If the purpose of our processing of your personal information has been achieved, cannot be achieved, or it is no longer necessary to retain it for the purposes of processing;
2) If we stop providing the relevant products or services, or the retention period for personal information has expired (e.g., if you have ceased using our products or services, or if you have canceled your account);
3) If you withdraw your consent;
4) If our processing of personal information violates laws, administrative regulations, or our agreement with you;
5) Other circumstances stipulated by laws and administrative regulations.
When your personal information is deleted from our services, we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.
(2) Managing Your Authorization Scope
Each product/service function requires some basic personal information to be completed. For personal information collected and used additionally based on your authorized consent, you can give or withdraw your authorized consent at any time. After you withdraw your consent, we will stop collecting the relevant personal information. You can contact us to withdraw your consent through the contact information in the "Contact Us" section of this Privacy Policy.
Please understand that since various functions and services require their corresponding necessary personal information to be completed, when you withdraw your consent or authorization, we will no longer be able to provide you with the product/service functions corresponding to the withdrawn consent or changed authorization scope, 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 previously carried out based on your consent or authorization.
(3) Canceling Your ZERON Account
You can cancel your previously registered ZERON account through the contact information in the "Contact Us" section of this Privacy Policy. We will decide whether to respond to your request in accordance with national laws, regulations, and regulatory requirements. After you cancel your account, we will stop providing you with our products/services. Unless otherwise provided by law, account cancellation may result in the clearing of all your user data and account information, which will be unrecoverable.
After you cancel your account, we will delete your personal information or perform anonymization processing according to applicable legal requirements and your specific request.
(4) Responding to Your Requests
We generally do not charge fees for reasonable requests. However, for requests that are repeated multiple times or exceed reasonable limits, we may charge a certain cost fee depending on the circumstances. We may reject requests that are baselessly repetitive, require excessive technical means (e.g., developing new systems or fundamentally changing established practices), pose risks to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).
Notwithstanding the above provisions, we will be unable to respond to your request in the following circumstances:
1) Where it is necessary for the conclusion or performance of a contract with you;
2) Where it is necessary for us to fulfill responsibilities or obligations stipulated by laws and regulations;
3) Where it is directly related to national security or national defense security;
4) Where it is directly related to public safety, public health, or major public interests;
5) Where it is directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
6) Where it is necessary to protect the life, health, and property safety of you or others in an emergency;
7) Where personal information is processed within a reasonable scope for public interest purposes such as news reporting and public opinion supervision;
8) Where there is sufficient evidence that you harbor subjective malice or abuse your rights;
9) Where personal information that you have disclosed yourself or that has been otherwise lawfully disclosed is processed within a reasonable scope in accordance with the provisions of the *Personal Information Protection Law of the People's Republic of China*;
10) Where responding to your request would severely harm the legitimate rights and interests of you or other individuals or organizations;
11) Where trade secrets may be involved;
12) Other circumstances stipulated by laws and regulations.
V. How We Protect Your Personal Information
(1) Data Protection Measures
We highly value the security of your personal information. We have adopted security protection measures that meet industry standards and are reasonably feasible to protect your information and prevent unauthorized access, public disclosure, use, modification, damage, or loss of personal information. For example, we enhance the security of personal information during data exchange between browser and server by using encryption technology (TLS protocol). We provide the HTTPS protocol as a secure browsing method to ensure that data is encrypted and protected during transmission, making it difficult to steal or tamper with, providing users with a higher level of security and privacy protection.
We use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to strive to ensure that only authorized personnel can access personal information. We hold information security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
(2) Security Incident Response*
In the unfortunate event of a personal information security incident, we will immediately form a special emergency response team, activate our emergency plan to prevent the incident from expanding, and promptly inform you in accordance with legal and regulatory requirements of: the basic situation and potential impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and mitigate risks on your own, and remedial measures for you, etc. We will promptly inform you of the incident-related situation by letter, phone call, SMS, push notification, etc. If it is difficult to notify individuals one by one, we will issue an announcement in a reasonable and effective manner. Simultaneously, we will proactively report the handling of the personal information security incident to the regulatory authorities as required.
(3) Special Reminder
The Internet is not an absolutely secure environment. We strongly recommend that you use secure methods and complex passwords to assist us in ensuring the security of your account. If you discover that your personal information has been leaked, especially if your account or password has been compromised, please contact us immediately using the contact information provided in this Privacy Policy so that we can take appropriate measures.
Please also understand that due to technical limitations and the potential existence of various malicious means, it is impossible to guarantee 100% information security in the Internet environment, even with best efforts to strengthen security measures. We will endeavor to ensure the security of the personal information you provide to us.
VI. Protection of Minors' Personal Information
We highly value the protection of minors' personal information. Our products, websites, and services are primarily intended for adults. We do not actively or directly collect personal information from minors. If we discover that we have collected a minor's personal information without obtaining verifiable prior consent from their guardian, we will endeavor to promptly delete the relevant information. If you discover that we have inadvertently collected a minor's personal information, please notify us via the contact details below, and we will endeavor to delete the relevant data promptly.
VII. Updates to the Privacy Policy
To provide you with better services, this Privacy Policy will be updated promptly as our business develops. Without your explicit consent, we will not diminish your rights under this Privacy Policy. We will issue an updated version and remind you of the updated content through announcements or other appropriate means before it takes effect. Please also log in to the ZERON official website and App in a timely manner to review the latest Privacy Policy. If there are significant changes to this Privacy Policy, we will issue a formal notice in the form of email, etc., explaining the changes made to the Privacy Policy and other information.
VIII. Contact Us
You can contact us through various means such as mail, phone, email, etc. Specific information is as follows:
Company Name: Jiangsu ZERON Automotive Technology Co., Ltd.
Registered Address / Common Office Address: Building 17#, Pingqian (Taicang) Modern Industrial Park, No. 525 Yuewang Lingang South Road, Shaxi Town, Taicang City, Suzhou City, Jiangsu Province
Tel for User Rights Affairs: 400 168 0101
Email: legal@zeron.ai
Working Hours: Monday to Friday, 9:00 AM - 5:00 PM
If you have any questions, comments, or suggestions regarding this policy, you can also contact us through the above contact methods. We will respond within the time stipulated by law. Under normal circumstances, we will complete the verification, processing, or provide a reasonable explanation within fifteen working days. If you are dissatisfied with our response, especially if our personal information processing behavior has damaged your legitimate rights and interests, you may also seek solutions through external channels.