Privacy Statement of DENZA APP

Issued on: July 8, 2024

Version：1.1

This Privacy Statement describes DENZA’s use of your data. The specific legal entity under the heading “Data controller” is hereinafter referred to as “DENZA”, “we”, “us” or “our”. The document comprehensively addresses information on the processing of personal data while using the DENZA application (hereinafter as "the APP") . DENZA will process your personal data within your residential country/district or other specific storage locations, you can contact us via auto.asia@byd.com or the following contact details:

Your residential country	Data controller	Mailing address	Storage location
Singapore, Brunei, Cambodia, Vietnam, Laos，Nepal	BYD (SINGAPORE) PTE. LTD.	Yokohama Dia Building 19F, 1-7, Kinko-cho,Kanagawa-ku,Yokohama-shi, Kanagawa-ken 221-0056,Japan	Singapore
Hong Kong, China	BYD (H.K.) Co., Ltd.	Unit 2902, 29/F., Enterprise Square 3, No.39 Wang Chiu Road, Kowloon Bay, Hong Kong	Singapore
Macau, China	BYD MACAU LIMITED	澳门新口岸宋玉生广场181-187号光辉集团商业中心21楼W-X	Singapore
Thailand	BYD AUTO (THAILAND) CO., LTD.	Interchange 21 building 22nd fl. room no.2211, 399 Sukhumvit Rd, Khlong Toei Nuea, Watthana,Bangkok 10110	Singapore
Malaysia	BYD Malaysia SDN.BHD	Unit 1.5a, Level 1, East Lobby, Menara Sunway Annexe Jalan Lagoon Timur, Bandar Sunway, 47500 Selangor	Singapore

We would like to emphasize that we take the protection of your privacy and your personal data very seriously and that we process your data in accordance with applicable data protection laws. We would like to explain to you below in more detail which personal data we collect in connection with DENZA and how we use this data. In this Privacy Statement, we will explain to you:

1. What data we collect

2. How we use your personal data

3. With whom we will share this personal data

4. To which third countries we will transfer your personal data

5. What rights you have in relation to your personal data

6. How long we will retain your personal data

7. How we protect your personal data

8. How you can raise questions about your personal data

9. How we will update this Privacy statement

This Privacy Statement applies since the date issued and it may be updated from time to time.

1. What data we collect

Customers who purchase DENZA passenger cars can register a DENZA Account, which is relating to the APP. The information contained in your account includes:

· your email address, login password and operation password;

· your vehicle identification number (VIN) and vehicle identifier;

· your vehicle's conditions: electricity, remaining charging time, charging status, endurance, total mileage, power position, door state, tyre pressure state, window status, seat ventilation and heating state.

You can access your DENZA Account to update the information from or about you in that account at any time.

We may collect the following data based on the requirements for providing services or analyzing and solving problems:

· Operating system information (name and version);

· Equipment brand and model;

· Equipment unique identification information (IMEI);

· Name and version of application (including database version);

· Network operator;

· Signal strength (UMTS and LTE);

· Wi-Fi signal strength；

· Vehicle geo-location information and mobile device location information;

· APP usage data include the number of times an app is opened, the duration of each session, specific features or screens accessed within the app, and user engagement metrics such as clicks, taps, or swipes.

We may collect the following data based on the requirements for carrying out surveys related to customer care and product and service improvement, including but not limited to pushing survey questionnaires, questionnaires re-collection and analysis, and communicating survey results:

· Vehicle Identification Number (VIN)

· Delivery date of the vehicle for first registration

· Maintenance service completion date

· Registration date of the App

· Feedback and ratings. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write

· Your email(if not anonymous)

Please note that some services (such as Rescue & Customer Service) may be provided by the third parties, and may require the collection of personal data, depending on the particular situation. It is optional for you to provide the following data and other data to have an additional way of communication and to provide you with better service:

· Plate information (optional)

· Car nickname (optional)

2. How we use your personal data

We use personal data to manage and meet service and information requests, to understand service vehicle and the APP use, and to make our products and services as effective as possible.

Data Processing Activities (Purposes)	Type of Data	Legal Basis for Processing
To provide APP account registration service for you	· Country · Vehicle Identification Number (VIN) · Login password and operation password · You email (if not anonymous)	· Where you have provided your consent
To provide car control and monitoring service through the APP	· Vehicle Identification Number (VIN) · Vehicle condition information: electricity, remaining charging time, amount of fuel, endurance mileage, total mileage, power position, door state, tyre pressure state, window state, roof hatch state, seat ventilation and heating state, air conditioner state, lamp state · Plate number (optional) · Vehicle nickname (optional)	· Where you have provided your consent
To detect and proactively fix issues related to the APP’s functionality	· Operating system information (name and version); · Equipment brand and model; · Equipment unique identification information (IMEI); · Name and version of application (including database version); · Network operator; · Signal strength (UMTS and LTE); · Wi-Fi signal strength.	· Where you have provided your consent
To provide Digital Key service for you through the APP	· Vehicle Identification Number (VIN) · Vehicle identifier · Account information · Operating system information (name and version) · Pairing password · Keylist	· Where you have provided your consent
To provide Vehicle Position service for you through the APP	· Vehicle geo-location information · Mobile device location information	· Where you have provided your consent
To find a dealer near you	· Location · equipment unique identification information (IMEI); · name and version of application (including database version); · Network operator; · signal strength (UMTS and LTE); · Wi-Fi signal strength.	· Where you have provide your consent
To conduct surveys related to customer care and product and service improvement	· Vehicle Identification Number (VIN) · Delivery date of the vehicle for first registration · Maitenace service completion date · Registration date of the App · Feedback and ratings · You email(if not anonymous)	· Where you have provided your consent
To contact you if there is an urgent safety or product recall notice and we need to tell you about it	· Vehicle Identification Number (VIN) · Contact information: email address	· Necessary to comply with a legal obligation
To demonstrate compliance with regulatory requirements	· Vehicle Identification Number (VIN) · Contact information: email address	· Necessary to comply with a legal obligation

Please note that it is unable to identify a specific natural person just with information of individual equipment and operating system,etc. To optimize products, we may analyze non-personal information. If we combine such non-personal information with other non-personal information or personal information to identify a specific natural person, then the non-personal information will be regarded as personal information. Unless authorized by you or required by the law and regulation, we will anonymize the personal information.

3. With whom we will share this personal data

We do not sell your personal data to anyone for any purpose, or any period. The table below illustrates who we may share your personal data with:

Categories of Recipients	Details	Reason for Sharing
Affiliates and subsidiaries	Companies that directly or indirectly, controls, is controlled by or is under common control with BYD, or where we have a substantial ownership interest	To assist, operate, enhance, and fulfil services on our behalf
Could service provider-Amazon Web Service , Inc	Companies we’ve hired to provide cloud data hosting service	To assist, operate, enhance, and fulfil services on our behalf
IT services providers	Companies we have hired to provide IT services	To assist, operate, enhance, and fulfil services on our behalf
Accountants, legal advisors and other professional service providers	Professionals we have hired for the provision of professional/legal services	To assist, operate, enhance, and fulfil services on our behalf
Law enforcement and government authorities where the services are provided	Disclosure of information as required by law, or when otherwise appropriate	To comply with applicable laws

When third parties are given access to your personal data, we will take the required contractual, technical and organizational measures to ensure that your personal data are only processed to the extent that such processing is necessary.

In other cases, your personal data will not be supplied to third parties, except where required or allowed by law.

4. To which third countries we will transfer your data

In principle, the personal data we collect is stored in your residential area or storage location mentioned in contact detail. We will take appropriate measures to ensure that safeguards are in place to ensure adequate data protection level.

By making a purchase or otherwise submitting your personal data to us, you give your consent to transfer information to DENZA in the countries other than your place of residence or in which the information was originally collected. DENZA complies with laws on the transfer of personal data between countries to help ensure your data is protected as described in this Statement, wherever it may be.

5. What rights you have in relation to your personal data

Unless exceptions provided by applicable law and regulations, you generally have the right to ask us:

· -for access to your personal data that we hold

· -withdraw consent given, or deemed to have been in respect of the collection, use or disclosure

· -to update or correct your personal data in order to make it accurate

If the processing of personal data is based on your consent, you may withdraw your consent at any time, but this does not affect the lawfulness of the previous processing.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

If you no longer want to use DENZA Account on the APP, you can go to“My Space---Account and security--deregister account”. After you deregister your account, we will stop providing you with services through your account and will anonymize your relevant Personal Data, provided that anonymization is not otherwise stipulated by special legal requirements.

If you no longer wish us to collect your location information, please disable them in “Individual center--Settings--Use vehicle position” in your app screen. Please note that if you disable this function, we cannot provide with you Vehicle Position service.

We hope that we can satisfy any queries you may have about the way we process your data. If you have any concerns about how we process your data you can contact us as described below in the section “If you have any questions about your data”.

In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular the data protection authority in the Member State of your habitual residence or place of work.

Finally, please note that where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

6. How long we will retain your personal data

For data about your visits to the APP, will keep this data for legal and tax preservation obligations. Where you are a customer, DENZA will keep your information for the duration of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this Statement. We retain the information we collect from or about you for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. When the information is no longer necessary for these purposes, or if you close your account, we will mark your account in our database as “Cancelled”, and we will delete or keep it in a form that does not identify you. When determining this retention period, we take into account various criteria, including the type of services requested by or provided to you, the nature of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, and retention periods required by law.

7. How we protect your personal data

We strive to maintain the proper standards of security and DENZA has put in place robust technical and organizational measures for the protection of your data in accordance with the current, general state of technology, especially to protect the data against loss, falsification or access by unauthorized third persons. However the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the 100% security of your data transmitted via the APP. Once we have received your personal data we will use strict procedures and security features to prevent unauthorized access. In the unfortunate event that a personal data security incident occurs, we will report it promptly and take remedial measures in accordance with the requirements of the law and regulatory authorities.

8. How you can raise questions about your personal data

If you have any questions about the processing of your personal data, please read this Privacy Statement first. For additional questions, please feel free to contact us via auto.asia@byd.com, or the contact details mentioned above.

Please note that we take your satisfaction very seriously. Should you have a complaint, please also direct it to the same email address and we will respond to you as soon as we can.

You can of course also lodge a complaint with the data protection authority of the country in which you live.

9. How we will update this Privacy Statement

We may update this Privacy Statement according to changes in our business functions and measures concerning the protection of personal information. If we make changes to this Privacy Statement, we will notify you through the APP. Where changes to this Privacy Statement will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you have.