Dear User,
Shenzhen SmartSafe Tech Co., Ltd. (Address: Room 3310, Building 11, Tian'an Cloud Park, Bantian Subdistrict, Longgang District, Shenzhen City, hereinafter referred to as "SmartSafe" or "we”), highly values the protection of your privacy.This Privacy Policy aims to inform you about how we collect, use, store, share, and protect your personal information when you use SmartSafe APP service (hereinafter referred to as "this APP" or "the Service"), including binding detection devices and new energy maintenance devices, viewing and managing data, and other related services. Please read this Policy carefully before using this APP. If you have any questions, comments, or suggestions regarding this Policy, you may contact us through the contact information provided in this APP.By checking the "Agree" box, registering an account or actually using this APP, you acknowledge that you have fully understood and agreed to all terms of this Policy.
1.1 What information do we collect?
To provide you with our service, we require certain necessary information for service usage. We only collect information essential for specific, explicit, and legitimate purposes and ensure that such information will not be further processed in a manner incompatible with those purposes. You have the right to choose whether to provide the requested information. However, in most cases, if you refuse, we may not be able to provide the corresponding services or address any issues you encounter.
Depending on your use of this APP, we may collect one or more of the following types of information:
1.1.1 Personal information you voluntarily provide
Based on the services you select, we collect the personal information required for those services. For example, when creating an account, you may provide account security-related information; if you participate in promotional activities, you may provide your nickname, email address, photos, videos, or other required information; if you participate in our campaigns or win prizes, you may provide your name, phone number, and address.
1.1.2 Information we collect during your use of the Service
• Information related to your device or SIM card: Including but not limited to IMEI/OAID, GAID, IMSI numbers, MAC address, serial number, system version and type, ROM version, Android version, Android ID, Space ID, SIM card carrier and location, screen display information, device input information, device activation time, manufacturer details and model name, network operator, connection type, hardware configuration, sales channel, and usage-related data (e.g., CPU, memory, battery consumption, screen resolution, device temperature, camera lens model, screen activations, and unlock attempts).
• Information related to your application usage:Including unique application identifiers (e.g., VAID, OAID, AAID, Instance ID), basic APP details such as installed APP lists, APP ID, SDK version, system update settings, APP preferences (region, language, time zone, font), foreground/background transition timestamps, and APP status records (e.g., downloads, installations, updates, deletions).
• Information generated during your use of this APP service:Such as your SmartSafe account profile picture, nickname, user level, browsing history; feedback submitted via SmartSafe (visible only to sender and recipient); system language, country/region, network status, and installed APP lists during service usage.
• Information regarding device binding and usage:When binding SmartSafe detection devices or new energy maintenance devices via this APP, we collect the device serial number, device model, device location (obtained through positioning functionality), as well as any remarks you input during the binding process to establish and accurately manage the association between the device and your account.This includes login timestamps, feature usage, data access records, device connection/disconnection times—all of which are used to optimize service experience and conduct security analyses. The inspection data, maintenance records, operational status data (including but not limited to new energy vehicle battery health status, fault codes, and diagnostic parameters) generated through device binding are utilized for device management and to provide you with data analysis services.
• Log information: This refers to information related to your use of certain features, applications, and websites. Examples include cookies and other tracking technologies, Internet Protocol (IP) addresses, network request information, temporary message histories, standard system logs, error/crash reports, as well as log data generated during service usage (such as registration time, access timestamps, and activity duration).
Other information:Environmental characteristic values (ECV), derived from SmartSafe account details, device identifiers, information generated during Wi-Fi connections, and geolocation data.
1.1.3 Information obtained from third parties
Where permitted by law, we may obtain your personal information from third parties. For example:
• We may use designated unique identifiers (such as IMEI/OAID/GAID obtained from advertisers) and, under specific circumstances, receive partial conversion data corresponding to your use of advertising services (e.g., click-through rates) to optimize advertising models and provide you with relevant ad services.
• We may also acquire certain information from third-party social network services, including account details, nicknames, profile pictures, and email addresses (for instance, when you log in to SmartSafe service using social media credentials).
1.1.4 Non-personal information
We may also collect other information that neither directly nor indirectly identifies a specific individual and does not constitute personal information under applicable local laws. Such information is referred to as non-personal information. We may collect, use, transfer, and disclose non-personal information. Below are examples of how we collect and use non-personal information in aggregated form:
• May include statistical data generated from your use of specific services (e.g., anonymous device-related information, daily active events, page view events, page duration events, session events).
• Network monitoring data (e.g., request duration, request counts, error request counts).
• Application crash events (e.g., automatically generated logs after APP crashes).
The purpose of collecting such information is to improve the services we provide to you. The categories and volume of information collected will depend on how you use our products and/or services.
We aggregate such information to deliver more useful insights and understand which sections of our website, products, or services interest you most. For instance, we may only require the number of active users within a day without needing their identities; thus, aggregated data suffices for statistical analysis. We will isolate your personal information from non-personal information wherever possible and ensure their separate usage. Should we combine non-personal information with personal information, the combined data will be treated as personal information during such usage.
1.2 Legal basis for data collection and processing
Our collection and processing of your personal information will be based on at least one of the following legal grounds:
1.2.1 Necessity for contractual performance;
1.2.2 Your explicit consent;
1.2.3 Necessity for compliance with legal obligations;
1.2.4 Protection of your or others’ vital interests;
1.2.5 Performance of tasks carried out in the public interest;
1.2.6 Other legitimate interests pursued by us or third parties, provided such interests do not override your interests, fundamental rights, or freedoms.
We collect personal information to provide you with products or services and to ensure compliance with applicable laws, regulations, and other normative documents. This includes:
• Providing, processing, maintaining, improving, and developing our products or services offered to you, such as login authentication, customer support, and promotional activities.
• Security purposes, including loss prevention, fraud detection, user identification, and identity verification. We will only use your information for anti-fraud purposes if both of the following conditions are met: it is strictly necessary, and such use aligns with SmartSafe’s legitimate interests in protecting users and services.
• Handling your inquiries or requests regarding devices and services, such as responding to customer queries, sending system and application notifications, and managing activities like lucky draws that you participate in.
• Conducting promotional activities, such as providing promotional materials and updates. Unless otherwise stipulated by applicable law, if you no longer wish to receive certain types of promotional communications, you may opt out using the unsubscribe method provided in such communications. Please refer to "Your Rights" below.
• Internal purposes,such as data analysis, research, and development of statistical information related to the use of our products or services, in order to improve them effectively.
• Storing and maintaining information related to you for business operations (e.g., business statistics) or compliance with legal obligations.
• Processing data based on SmartSafe’s legitimate interests (in applicable jurisdictions, such as under GDPR). Legitimate interests include enabling us to manage and operate our business more efficiently; delivering our products and/or services; protecting the security of our business, products, services, and customers (including loss prevention and fraud detection); internal administration; compliance with internal policies and procedures; and other legitimate interests described in this Privacy Policy.
For example, to ensure the security of our services and help us better understand the APP's performance status, we may record relevant information such as your usage frequency, crash logs, overall usage patterns, performance data, and application sources.
• User identity verification:SmartSafe uses ECVs to assist in verifying user identities and preventing unauthorized access.
• Providing core services: Enabling essential functions such as device binding and management, data viewing and analysis, and ensuring normal service operation.
• Service optimization and improvement:Analyzing your usage behavior and device data to understand your needs and habits, optimizing APP functionality and interface design, and enhancing service quality.
• Collecting user feedback: The feedback you voluntarily provide is crucial in helping SmartSafe improve its services. To address your feedback promptly, SmartSafe may use your personal information to contact you and retain records for troubleshooting and service enhancement.
• Sending notifications: We may use your personal information to deliver important notices, such as device alerts or software update notifications. Since such information is critical to you, we recommend against opting out of these communications.
• Conducting promotional activities:If you participate in lucky draws, competitions, or similar promotions via SmartSafe’s social media platforms, we may use the personal information you provide to deliver such rewards.
• Security safeguards: Monitoring and analyzing abnormal behaviors during account and device usage to prevent security risks and ensure account and device safety.
We do not sell any personal information to third parties.
We may occasionally share your personal information with third parties (as defined below) in order to provide or improve our products or services, including fulfilling your requests for products or services. Specific information regarding data sharing is provided below.
1. Necessary cooperation for service provision:When we engage third parties to process personal information for service provision (e.g., server hosting, data storage service providers), we enter into strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions and subjecting their processing activities to our supervision.
2. Sharing information within our group ecosystem
As a globally operating company, we may share your personal information with other SmartSafe affiliates from time to time to facilitate business operations and provide you with the full functionality of our products or services. Your personal information may also be transferred to countries outside your country of residence (including China). We will ensure that such transfers are subject to adequate legal safeguards and that your rights remain protected.
3. You fully acknowledge that in the following circumstances, we may collect and use personal information without your prior consent:
3.1 Where it relates to national security or defense security;
3.2 Where it relates to public security, public health, or significant public interests;
3.3 Where it relates to criminal investigation, prosecution, trial, or enforcement of judgments;
3.4 Where it is necessary to protect the life, property, or other major legitimate interests of the personal information subject or another individual, but obtaining consent is difficult;
3.5 Where the personal information collected has been voluntarily disclosed to the public by the personal information subject;
3.6 Where the personal information is collected from legally publicly disclosed sources, such as lawful news reports or government information disclosures;
3.7 Where it is necessary for entering into or performing a contract at your request;
3.8 Where it is necessary to ensure the secure and stable operation of the provided products and/or services, such as detecting and addressing faults of products and/or services;
3.9 Where it is necessary for lawful news reporting;
3.10 Where academic research institutions require such information for statistical or academic research conducted in the public interest, provided that any disclosed research results undergo de-identification of personal information;
3.11 Where it is necessary to establish, exercise, or defend legal claims;
3.12 Where required by applicable laws, legal proceedings, litigation, or governmental authorities.
4. Additionally, we may share your personal information with the following parties:
4.1. Our accountants, auditors, lawyers, or similar advisors when we require their professional advice.
4.2. Investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction involving an entity within the SmartSafe Group.
4.3. Other third parties as detailed in this Privacy Policy or otherwise notified to you, such as disclosures made with your authorization regarding specific information.
1. Retention period: We will retain your personal information only for the minimum period necessary to provide you with services. Upon expiration of this period, we will either delete or anonymize the information. Typically, we will delete or anonymize your personal information within [30 days] after account deletion, unless otherwise required by laws and regulations.
2. Security measures
2.1 We employ encryption technologies to protect your personal information, such as SSL encrypted transmission and encrypted data storage, to prevent theft or tampering during transmission and storage.
2.2 We have established stringent access control mechanisms that restrict access to personal information to authorized personnel only, while recording and auditing all access activities.
2.3 We conduct security and privacy protection training sessions and tests to enhance employees' awareness of the importance of safeguarding personal information. We will take all feasible and legally required measures to protect your personal information. However, you should be aware that internet usage is not entirely secure, and therefore we cannot guarantee the security or integrity of any personal information transmitted bidirectionally over the internet.
2.4 We perform due diligence on third-party service providers and business partners to ensure their capability to protect your personal information. We also verify whether third parties adhere to appropriate security standards by implementing suitable contractual restrictions and conducting audits and evaluations when necessary. Furthermore, employees, third-party service providers, and business partners who access your personal information are bound by strict contractual confidentiality obligations.
3. Security incident handling: In the event of a security incident such as a personal information breach, we will immediately activate emergency response measures, take remedial actions, and notify you and relevant regulatory authorities in accordance with legal requirements (typically within [72 hours] or other statutory timeframes stipulated by your country/region).
1. Access, inquiry and correction:You have the right to access, inquire about, and correct your personal information through this APP or by contacting us.
2. Logging in or out of your SmartSafe account.
3. Deletion:Subject to applicable laws and regulations and the terms of this Privacy Policy, you have the right to request deletion of your personal information. Please note that deletion of certain information may affect your normal use of this APP service.
4. Account deletion: You may delete your account through the methods provided in this APP. Upon deletion, we will cease collecting and using your personal information, and will erase or anonymize the collected information in compliance with legal requirements.
5. Withdrawal of consent: You may withdraw your previously given consent for the processing of personal information by adjusting APP settings or contacting us. However, such withdrawal shall not affect the validity of any personal information processing activities conducted prior to the withdrawal based on your authorization.
6. Where expressly stipulated by the laws and regulations of your country/region, you additionally enjoy the following rights:
6.1. Right to data portability: To request that we provide your data in a structured, commonly used and machine-readable format, or transmit it to another controller;
6.2. Right to restriction of processing: To request restriction of processing of your personal information under specific circumstances;
6.3. Right to object: To object to our processing based on legitimate interests under specific circumstances, including processing for direct marketing purposes;
6.4. Right not to be subject to automated decision-making: Not to be subject to decisions based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you.
7. Exercise of rights: To exercise any of these rights, please contact us through the methods specified in this Privacy Policy. For security purposes, we may require you to submit a written request or otherwise verify your identity. We will respond to your request within a reasonable timeframe after receipt.
We believe it is the responsibility of parents or guardians to supervise minors' use of our products or services. We do not provide services directly to minors nor use minors' personal information for marketing purposes.
If you are a parent or guardian and believe that a minor has submitted personal information to SmartSafe, please contact us to ensure such personal information is promptly deleted.
We will periodically review this Privacy Policy in accordance with business and technological changes, applicable laws, and industry best practices, and may update it accordingly. The updated version will be published on this APP, and your continued use constitutes acceptance of the modified terms. Where we collect additional personal information or use/disclose your personal information for new purposes, we will seek your consent again as required by applicable laws. Should you disagree with the modified terms, you must cease using this APP and delete your account.
If you have any questions, comments, or suggestions regarding this Privacy Policy or personal information protection, you may contact us through the feedback channels within this APP or via the following contact details.We will process and respond to your feedback promptly upon receipt.
Shenzhen SmartSafe Tech Co., Ltd.
Address: Room 3310, Building 11, Tian'an Cloud Park, Bantian Subdistrict, Longgang District, Shenzhen City
Tel.: 400-930-1883
[October 10, 2025]