Updated: March 20, 2023
This privacy policy is applicable to the eBike iProtector App service (hereinafter referred to as the "Service") provided by Cloud Drive Intelligent Technology Co., Ltd. (hereinafter referred to as "Cloud Drive", "We"), which specifies what data we collect, why we collect this data, how to use this data for what purpose, and how to protect this data. Your trust is crucial to us, and we fully understand the importance of personal information to you. We will collect personal information from you to the extent reasonable and necessary in accordance with laws and regulations. We make every effort to adopt appropriate security measures through reasonable and effective information security technology and management processes to prevent your information from being leaked, damaged, or lost.
1. Personal information: Various information recorded electronically or otherwise related to identified or identifiable natural persons, excluding information after anonymization. The processing of personal information includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
2. Personal sensitive information: including personal biometric information, property information, action trajectory, and transaction information. When we provide you with specific products or services that involve the collection of personal sensitive information, we will obtain your consent through a significant notice before collecting personal sensitive information about you. Sensitive information will be highlighted in bold and underlined in this policy.
3. Personal information deletion: refers to the act of removing personal information from systems involved in the implementation of daily business functions, leaving it in a state that is not retrievable or accessible.
4. Intelligent devices: refer to non-standard computing devices that are produced or manufactured by our hardware manufacturers, have human-computer interfaces, and can transmit information through wireless networks, including intelligent travel devices, intelligent positioning and anti-theft devices, etc.
Before using the service, please be sure to carefully read and thoroughly understand this policy, especially the terms marked with bold and underline. When you access or use this service, you agree to this privacy policy and trust the way we handle your information. If you have any questions about this policy, you can contact us through the methods listed in Article 9 of this policy. If you are a minor under the age of 14, please read this policy with your legal guardian and pay special attention to the terms of use for minors.
We collect your information based on the principles of legality, reasonableness, and necessity. When providing you with a specific service, we will clearly inform you of the information that will be collected and its purpose in response to your specific service request.". Depending on the service you choose, we may collect one or more of the following information in the following scenarios:
1.1 When registering and logging in, you need to provide us with your email or mobile phone number, and by entering a verification code, we can verify your identity. During your interaction with our products, we will further collect language preferences in your account.
1.2 When you download or use the APP, we may read information related to your mobile device, including hardware model, IMEI number, or other unique device identifier, MAC address, IP address, operating system version, and settings for the device used to access the service. We may also read information about your device usage through the app, including device model, device operation status, and device usage frequency. At the same time, the unique device identifier of the mobile phone, such as Android ID, will also be collected for the purpose of identifying the mobile phone.
1.3 Smart Device Connection
When you use a smart device, we collect information inherent in the smart device itself and information generated during your use of the smart device.
1.3.1 Basic information about smart devices: When you use smart devices connected to our products or services, we collect basic information about smart devices, including the name, device ID, online status, activation time, firmware version, and upgrade information of the smart device.
1.3.2 Information collected during connecting smart devices: Based on the type of smart device you need to connect to, the basic information collected includes:
1.3.2.1 Smart devices connected through 4G: device Mac address, module IEMI number, and ICCID number;
1.3.2.2 Smart device connected via Bluetooth: Device Mac address.
1.4 When you bind and control a device, we will collect your device model, IP address, location information, device status information, device SN, device MAC address, device SIM card information, device and personal GPS precise location information, longitude and latitude, as well as transaction and consumption record information within the APP.
1.5 When you use a product or service, we will automatically receive and record information about your APP client, including your IP address, language of use, access date and time, software and hardware feature information data; When you apply for after-sales service, we may also collect the phone number and GPS information location provided by you.
1.6 To help us understand the operation of APP. We may record relevant information, including your usage frequency, crash data, overall usage, and performance data.
1.7 User feedback: When you use our service and submit feedback and suggestions related to the service to us, we will collect the feedback content (text and pictures) you fill in. This information will be used to promptly handle your application issues and smart device related failures for us.
1.8 To provide you with a push service and send notifications about software updates or new product launches (including but not limited to marketing information about our and related third-party products or services), you agree that we collect information about your device (such as IMEI or OAID, Serial Number, IMSI, User ID, Android ID, Google Advertising ID, phone region settings, device model, phone power, phone operating system version, and language) The application information using the push service (such as the APP package name and version number, running status), network related information (such as IP or domain name connection results, current network type), message sending results, notification bar status (such as notification bar permissions, user click behavior), and lock screen status (such as whether to lock the screen, and whether to allow lock screen notifications).
1.9 Device Permission Call: During the process of providing services, we may require you to activate some device permissions, including storage, notification, GPS positioning, and camera access rights. You can also choose to turn off some or all permissions at any time in the device's settings function, thereby denying us the right to collect corresponding personal information. The display and closing methods of permissions may vary among different devices. Please refer to the instructions or guidelines of the device and system developer for details
1.9.1 Read and write external storage space (Android version): Used to read and write photos and files on the device during scanning, user feedback, and other functions.
1.9.2 Location permissions (Android, iOS versions): used to determine the region, discover nearby smart devices, and discover the attached WLAN list.
1.9.3 Camera permissions (Android, iOS versions): Used for scanning QR codes for device binding and other functions.
1.9.4 Enable Bluetooth permissions (Android, iOS versions): Used to quickly connect devices, connect Bluetooth signals sent by devices, and communicate with devices.
1.10 It is important to note that separate device information and service log information are information that cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or use it in combination with personal information, during the combined use period, this type of non-personal information will be considered personal information. Unless otherwise authorized by you or required by laws and regulations, we will anonymize and de identify this type of information.
1.11 If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing us with such personal information. If any personal information involving children is involved, you need to obtain the consent of the corresponding child guardian before releasing it. In the aforementioned cases, the guardian has the right to contact us through the channels provided in Article 9 of this policy to request correction or deletion of the content involving children's personal information.
If we use the information for other purposes not specified in this policy, or use the information collected for a specific purpose to
For other purposes, or if we proactively obtain your personal information from a third party, we will obtain your consent in advance.
1.12 Exceptions to obtaining authorized consent: You fully understand and agree that we do not require your authorized consent to collect and use your personal information under the following circumstances, and we may not respond to your request for correction/modification, deletion, cancellation, withdrawal of consent, or request for information:
1.12.1 Related to national security and national defense security;
1.12.2 Those related to public safety, public health, or significant public interests;
1.12.3 Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;
1.12.4 It is difficult to obtain my consent for the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property;
1.12.5 Personal information that you disclose to the public on your own;
1.12.6 Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure, and other channels.
1.12.7 Necessary according to the policy or other written documents agreed by you;
1.12.8 Necessary for maintaining the safe and stable operation of the provided products and/or services, such as detecting and handling failures of the products and/or services;
1.12.9 Necessary for legitimate news reporting;
1.12.10 It is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and to deidentify the personal information contained in the results when providing academic research or descriptive results to the public;
1.12.11 Other circumstances specified by laws and regulations.
2.1 We will keep your personal data up-to-date; Safely store or destroy it; Minimize the collection and retention of data we need to provide you with services; Protect personal information from disclosure, abuse, unauthorized access, and disclosure; Take appropriate technical measures to protect the security of your personal information.
2.2 We use your information for the following purposes:
2.2.1 Provide you with services, including device access, device management, message subscription, OTA upgrade, and message subscription services.
2.2.2 Provide other services requested by you in accordance with the requirements stated when we collected information.
2.2.3 Share your information with our authorized partners so that they can assist us in providing you with our services and products.
2.2.4 Process transactions and communicate with you about these transactions.
2.2.5 Help track and correct errors and faults in the program.
2.2.6 For internal management and backstage support, share your contact information with branches of companies around the world.
2.2.7 Maintain the integrity and security of our data technology systems for storing and processing your personal information.
2.2.8 Conduct internal audit, data analysis, and research to analyze the efficiency of business operations and improve our services.
2.2.9 Comply with applicable laws and regulations, and cooperate with legal proceedings, lawsuits, or government authorities to provide relevant information.
2.2.10 Push the information related to you in the application service (such as following device information, etc.) to your device terminal in a timely manner.
2.2.11 Analyze and develop statistical information related to the use of our products or services to better improve our products or services.
2.2.12 Detect and investigate information leaks, illegal activities, and fraudulent practices.
2.2.13 Store and maintain information related to you for our business operations or legal obligations.
2.3 It should be noted that the above usage methods cover the main ways we use your information. From time to time, we may provide users with more diverse services by updating website pages or device firmware. When we want to use information for other purposes not specified in this policy, or when we want to use information collected for specific purposes for other purposes, we will seek your consent again by signing the policy, pop-up prompts, updating this policy, and other forms.
Your personal information will be strictly confidential, and we will not share your personal information with any other company, organization, or individual, except for the following circumstances:
3.1 With your explicit consent, we will share your personal information with other parties.
3.2 When necessary to achieve service functions, sharing with our employees and our company's branches worldwide is generally used for the following purposes: providing you with further services, internal management needs, detecting and handling data leaks, illegal activities, and fraud incidents, and maintaining the integrity of the company's information technology system. We will only share necessary personal information with employees to the minimum extent and are bound by this privacy policy. We will sign a confidentiality agreement with authorized employees.
3.3 Share your personal information with our third-party service providers (or partners) to assist us in providing or improving our services, including but not limited to cloud services, information system technical support, and providing customer services. We will only share your personal information for legitimate, legitimate, necessary, specific, and clear purposes, and only share the personal information necessary to provide services. Our third-party service providers (or partners) do not have the right to use the shared personal information for any other purpose. We will sign strict data processing agreements with all third-party service providers (or partners) involved, requiring them to take certain security measures to process your personal information in accordance with relevant laws, regulations, and our requirements, to ensure the security of your personal information.
3.4 We will not transfer your personal information to any company, organization, or individual, except for the following:
3.4.1 With your explicit consent, we will transfer your personal information to other parties.
3.4.2 In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to obtain authorization from you again.
3.5 We will only publicly disclose your personal information under the following circumstances
3.5.1 With your explicit consent or based on your active choice, we may publicly disclose your personal information.
3.5.2 Provide your personal information to government authorities in accordance with laws and regulations, or as required by government authorities. If we receive any judicial or other documents such as government subpoenas, search warrants, or orders, we will immediately report them to our Data Protection Office and respond to the relevant departments after their review. "If, after review, it is believed that the relevant authorities have jurisdiction and there are no other laws prohibiting us from doing so, we will disclose the relevant information required to the judiciary or government, while limiting disclosure to the extent explicitly required by the order or warranty."
3.6 According to relevant laws and regulations, in the following circumstances, we can share, transfer, and publicly disclose your information without your consent
3.6.1 Related to national security and national defense security.
3.6.2 Those related to public safety, public health, and significant public interests.
3.6.3 Related to criminal investigation, prosecution, trial, and execution of judgments.
3.6.4 For the purpose of safeguarding the significant legal rights and interests of your or other individuals' lives and property, but it is difficult to obtain my consent.
3.6.5 Personal information that you disclose to the public on your own.
3.6.6 Collecting personal information from legally disclosed information, such as legitimate news reports and government information disclosure channels.
3.7 Third-party information sharing and SDK services
When you use the services provided by a third party, we will share the corresponding information after ensuring that the third party obtains your authorization and consent, as well as other situations that comply with laws and regulations. You can learn how third parties will handle your personal information through the relevant information listed in this list. We will also strictly restrict third-party access to personal information to protect the security of your personal information.
In addition, in order to ensure the stable operation of the application or achieve relevant independent functions, we will embed third-party SDKs in the application. Please note that third-party SDKs may have changes in their personal information processing types due to version upgrades, policy adjustments, and other reasons. Please follow the official instructions posted on them.
The situation of third-party information sharing is as follows:
Access to third-party SDKs is as follows:
Google Maps
Third party entity: Google Corporation
Purpose: Used to display the device location
Function type: positioning function
Information collection details: device information, location information, network type
Privacy Policy: https://policies.google.com/privacy
Gaud Map
Third party entity: Gaode Software Co., Ltd
Purpose: Used to display the device location
Function type: positioning function
Information collection details: device information, location information, network type
Privacy Policy: https://cache.amap.com/h5/h5/publish/238/index.html
In order to comply with your agreed privacy policy, we will access and process your personal information through our server. Our server is located in Frankfurt, Germany. The personal information obtained from the service is stored on the server in Frankfurt, Germany.
We retain personal information for the purpose of information collection or in compliance with applicable legal requirements. After completing the purpose of collecting personal information, we will stop retaining data or undergo desensitization and deidentification processing. If for public interest, scientific, historical research, or statistical purposes, we will continue to retain relevant data based on applicable laws, even if further data processing is unrelated to the original collection purpose.
We adhere to recognized key data protection principles (fairness, purpose restrictions, data quality, data retention, compliance with personal rights, security), and take reasonable measures to ensure the security of personal information. We have applied a series of technical measures to protect the security of your personal information, minimizing the risks of misuse, unauthorized access, unauthorized disclosure, and inability to access. The security measures we use include, but are not limited to, data desensitization, data encryption, firewalls, and data access authorization controls.
5.1 At the same time, we will regularly review and update the security mechanisms used to protect data to provide effective protection measures against data abuse. If you believe that the security of your data has been compromised, or if you want to learn more about our measures to protect data, you can contact us by email.
You have the right to manage your information, including:
6.1 Access to your personal information:
6.1.1 Account information: If you want to access or edit personal information in your account, change your password, etc., you can log in to your account and access your information through settings.
6.1.2 If you need personal information generated during your use of our products or services, you can contact us through the contact information in Article 9.
6.2 Correcting Your Personal Information
When you discover that we have made errors in processing your personal information, you have the right to request us to make corrections or additions.". You can make corrections or additional instructions by visiting the personal information settings page or contact us directly.
6.3 Deleting Your Personal Information
Under the following circumstances, you can contact customer service to request the deletion of personal information:
6.3.1 If we handle personal information in violation of laws and regulations.
6.3.2 If we collect and use your personal information without your explicit consent.
6.3.3 If our handling of personal information seriously violates our agreement with you.
6.3.4 If you do not need to use our products and services, or if you voluntarily apply to cancel your account.
6.3.5 If we are not permanently required to provide products or services.
If we decide to respond to your deletion request, we will stop providing you with products or services and delete your personal information in accordance with applicable laws.
6.4 Right to carry: We are required to provide you with your data and, where possible, directly transmit the data to the data controller.
7.1 If you need, you can contact us through the contact information in Article 9 to cancel the account of the personal information subject.
7.2 After you cancel your account, we will stop providing you with products or services, and delete your personal information according to your request.
Our services are primarily aimed at adults, but for children using the service, we have taken additional procedures and measures to help ensure the safety of children's personal data. We treat minors under the age of 14 (or the age prescribed by local law) as children. In the case of collecting personal data from children with the consent of their parents, we will only use or disclose this data if permitted by law, explicitly agreed by parents or guardians, or necessary to protect the child. If we find ourselves collecting personal information about a child without obtaining the prior consent of a verifiable guardian, we will try to delete the relevant content as soon as possible.
9.1 If you have any questions, comments, or suggestions regarding this privacy policy, or if you want to exercise any rights, or if you have any requirements to discuss with us, please contact us through the following methods:
Mailing address: Via Senzaname 1040123, Bologna, Italy
E-mail: support@ebikes.tech
9.2 To ensure security, you may need to provide a written request or otherwise prove your identity. Generally, we will reply within 15 days. Given the complexity and quantity of requirements, this deadline may be extended for another 45 days if necessary. In the event of a delay in providing information, we will notify the personal information subject of the relevant situation and the reason for the delay. If the time limit set in this paragraph conflicts with the laws of your location, the laws of your location shall prevail.
9.3 This privacy policy may be modified, and the above modifications will not harm the privacy of users or the confidentiality of information that users may collect or upload through the APP.
Thank you for taking the time to understand our privacy policy!