Star Charge Privacy Policy

Effective 2023-08-17: Please take a moment to familiarize yourself with our new privacy Policy and let us know if you have any questions.

OUR COMMITMENT TO YOU

This Privacy Policy sets out how Wanbang Star Charge Technology Co., Ltd. (hereinafter referred to as "we") collect, use, disclose, process and protect any data that you give us when you use Star Energy product and services. This Privacy Policy also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data, and to restrict or object to the processing of your personal data under certain circumstances. Should we ask you to provide certain data by which you can be identified when using Star Energy product and services, it will only be used in accordance with this Privacy Policy.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal data collection and usage practices, as well as full confidence that ultimately, you have control of any personal data provided to we.

In this Privacy Policy, "personal data" means data that can be used to identify an individual, either from that data alone or from that data combined with other data we has access about that individual. Such personal data may include but not limit to the data you provide to us or upload, device,etc.

By using Star Energy product and services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e.g. General Data Protection Regulation in Europe Union), we will specifically seek prior explicit consent to the particular processing (e.g. automated individual decision-making) of special categories of personal data. We are committed to protecting the privacy, confidentiality and security of your personal data by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact our Data Protection Officer at privacy guoyu.zhao@wbstar.com to address your specific concerns. We will be happy to address them directly.

Please read and understand this Privacy Policy carefully before using our products (or services). Our Privacy Policy explains the following issues:

1. WHAT DATA IS COLLECTED AND HOW WE CAN USE IT
2. HOW THE PERSONAL DATA IS USED
3. COOKIES AND OTHER TECHNOLOGIES
4. WITH WHOM WE SHARE YOUR DATA
5. DATA NOT REQUIRING CONSENT
6. DATA SECURITY
7. RETENTION POLICY
8. WHAT YOU CAN DO
9. YOU HAVE CONTROL OVER YOUR DATA!
10. TRANSFER OF PERSONAL DATA OUTSIDE OF YOUR JURISDICTION
11. WITHDRAWAL OF CONSENT
12. UPDATES TO THE PRIVACY POLICY
13. DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?
14. OUR APPROACH TO MANAGE YOUR PERSONAL DATA UNDER GDPR
15. CONTACT US

WHAT DATA IS COLLECTED AND HOW WE CAN USE IT

TYPES OF DATA COLLECTED

In order to provide our services to you, we will ask you to provide personal data that is necessary to provide those services to you. If you do not provide your personal data, we may not be able to provide you with our products or services.

We will only collect the data that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of data (which may or may not be personal data):

We may also collect other types of data which are not directly or indirectly linked to an individual and which is aggregated, anonymized or de-identified. For example, Browser version，may be collected when using a particular service. Such data is collected in order to improve the services we provide to you.

HOW THE PERSONAL DATA IS USED

Personal data is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal data to our affiliated companies, Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal data for the following purposes:

· Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.

· Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, data about our events, notices.

· Analyzing and developing statistical data on use of our products and services to better improve our products and services.

· Optimizing the performance of your device.

· Storing and maintaining data about you for our business operations or legal obligations.

Here are more details on how we use your data (which may include personal data):

1.Open up your account. Apply for your account by email application, and the personal data such as mobile phone number, email address, account name and so on collected during this process will be used to create your account.

2.Log history. When you use the products / services we provide, we collect your IP address, access dates and time, and the page records you request as web logs for query questions.

3.Monitor the equipment operation. We will collect telemetry data through the device, which includes the operation data of the subdevice, fault log, device ID, to provide viewing service and history access service to users, for device security inspection, to maintain system stability, and to improve user experience.

You will not be subject to decisions based on automated data processing without your prior consent.

COOKIES AND OTHER TECHNOLOGIES

What data is collected and how we can use them: Technologies such as cookies, tags, and scripts are used by we and our Third Party Service Providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Log Files: As true of most websites, we gather certain information and store it in log files. This data may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other data we gather about you.

WITH WHOM WE SHARE YOUR DATA

We do not sell any personal data to third parties.

We may disclose your personal data on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that we will only share your personal data in accordance with your consent. Your consent to WE will engage sub-processors for the processing of your personal data. You should know that when we shares your personal data with a Third Party Service Provider under any circumstance described in this section, we will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. we will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

SHARING WITH OUR GROUP AND THIRD PARTY SERVICE PROVIDERS

In order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal data from time to time to other affiliated companies, or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, and our representatives. Such Third Party Service Providers would be processing your personal data on our behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this data, please contact us at privacy kefu@wbstar.com.

SHARING WITH OTHERS

We may disclose your personal data without further consent when required under applicable law.

DATA NOT REQUIRING CONSENT

We may share anonymized data and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

For the avoidance of doubt, we may collect, use or disclose your personal data without your consent if it is and only to the extent it is allowed explicitly under local data protection laws. Such disclosure may be brought about by the necessity to protect our rights, ensure the safety of you and other people, and comply with the requirements of the local government to facilitate the investigations of illegal activities.

DATA SECURITY

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

The data security lifecycle includes the following stages: data collection, data storage, data usage, data transmission, data backup, and data destruction. Here is an introduction to each stage:

Data Collection: In the data collection stage, compliance with privacy protection regulations is followed, and only the necessary fields for business purposes are collected. Measures such as TLS encryption for transmission and frontend input encryption (e.g., for credential information) ensure the security of the information collection and input process.

Data Storage: The storage stage primarily ensures security through mechanisms such as data encryption, backup, and access control. For more details, refer to the sections on "Data Storage Mechanisms," "Data Encryption Mechanisms," and "Data Backup Mechanisms."

Data Usage: The main security mechanisms during the data usage process include permission control, page watermarking, and data anonymization. Permission control involves functional and data-level permissions, both following the principle of least privilege. For more information, refer to the "Identity Management and Permission Control" section in this document. Page watermarking and data anonymization are discussed in the "Privacy Protection" section under the "Privacy Protection Features of the Product" subsection. The scope of data usage is strictly limited to within the scope of business functions and is not used for any purposes outside of the business. During data transmission, TLS encryption is employed to ensure the security of data during the usage process.

Data Sharing: Data is not shared with any third party without the authorization of the tenant.

Data Backup: A mechanism combining full backups and incremental backups is used, and data is regularly synchronized with the disaster recovery center, following the principle of having data backed up in two locations.

Data Destruction: When a tenant contract terminates, if there are no additional data retention requirements, the data deletion mechanism is triggered upon the termination of the business process, and the data is deleted within the time frame specified by legal or regulatory requirements.

RETENTION POLICY

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal data in our data retention policy. For more detailed data regarding personal data retaintion period, please refer to the Deletion period of Wanbang Deletion Policy, You can access this document at the following e-mail address: kefu@wbstar.com.

Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer an employee of the company, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.

WHAT YOU CAN DO

You can play your part in safeguarding your personal data by not disclosing your login password or account data to anybody unless such person is duly authorized by you. Whenever you log in on http://eueaas-energy.starcharge.com/ websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.

We cannot be held responsible for lapses in security caused by third party accesses to your personal data as a result of your failure to keep your personal data private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.

Your assistance will help us protect the privacy of your personal data.

YOU HAVE CONTROL OVER YOUR DATA!

ACCESS, UPDATING, CORRECTING OR ERASURE YOUR PERSONAL DATA

You have the right to request access to and/or correction of any other personal data that we hold about you. When you update your personal data, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient data to accommodate your request for access to or correction of your personal data, we will respond to your requests without undue delay and at the least within one month and to give reasons where we do not intend to comply with any such requests. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same data, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

If you would like to request access to your personal data held by us or if you believe any data we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the email address below. Email: kefu@wbstar.com.

If you are Europe Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal data. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.

If you are Europe Union user under GDPR, you have the right to obtain from us the restriction of processing your personal data. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal data under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.

If you are Europe Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you are Europe Union user under GDPR, you have the right to receive your personal data in a structured, commonly used format and transmit the data to another data controller.

TRANSFER OF PERSONAL DATA OUTSIDE OF YOUR JURISDICTION

To the extent that we may need to transfer personal data outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by us for this transfer of your personal data.

Currently, We have local data centers in China and Germany and run them by ourselves to process or back up your personal information. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. We may transfer to and store your personal data at our overseas facilities. However, this does not change any of our commitments to safeguard your personal data in accordance with this Privacy Policy. If you are located in the EU, we will implemente DATA TRANSFER MECHANISM FROM ARTICLES 46, 47, OR 49 OF THE GDPR to secure the transfer of your personal data to other jurisdictions.

WITHDRAWAL OF CONSENT

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or control by submitting a request. This may be done by sending e-mail to kefu@wbstar.com. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal data as per your request.

Please recognize that your withdrawal of consent could result in certain legal consequences, without affecting the lawfulness of processing based on your consent before its withdraw.. Depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that you will not be able to enjoy our products and services.

UPDATES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our data practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the http://eueaas-energy.starcharge.com/policyEn.html websites, so that you may be aware of the data we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest data on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal data from you or when we wish to use or disclose your personal data for new purposes.

If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products and services offered by a third party. Our products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your data too. For this reason, we strongly suggest that you read the third party’s Privacy Policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal data which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

Here are third party terms and privacy policies that apply when you use these specific products:

In order to enable you to use and enjoy the corresponding services and functions, we will call a third-party SDK on the platform, and we will carefully evaluate the purpose of using the SDK.

SDK name	Processing intent	Personal information collected by the SDK	Privacy policy links	Company
Amap	position	OAID, IDFV, system properties, operating system, and version	https://lbs.amap.com/pages/privacy	Autonavi Software Co., Ltd
The wind weather	Get the weather	OAID, IDFV, system properties, operating system, and version	https://www.qweather.com/terms/privacy	Hefeng Internet Technology (Beijing) Co., Ltd.

OUR APPROACH TO MANAGE YOUR PERSONAL DATA UNDER GDPR

If you are Europe Union user under GDPR, we will provide systematic approach to manage personal data deeply engages our people, management processes and data systems by applying a risk management methodology.

According to the GDPR, for instance,

(1) We have appointed a Data Protection Officer to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal data, or would like to request access to your personal data, please contact the Data Protection Officer at: [guoyu.zhao@wbstar.com]. If you are unsatisfied with our response to any issues that you raise with the Data Protection Officer, you may have the right to make a complaint with the data protection authority in your jurisdiction by contacting the data protection authority.

(2) We have appointed Coco as our EU representative to help ensure our compliance with applicable law. Please direct any questions relating to our processing of your personal data to our EU representative at: [c.hong@starcharge.com].

(3) Procedure like data protection impact assessment (DPIA).

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating that we collect, use or disclosure of your personal data, please contact us at the address below referencing "Privacy Policy":

Wanbang Star Charge Technology Co., Ltd.

No. 39 Longhui Road, National High tech Industrial Development Zone, Wujin District, Changzhou City, Jiangsu Province Postal Code of Wujin District, Changzhou: 213161

Email: kefu@wbstar.com

If you are unsatisfied with our response to any issues that you raise, you have the right to make a complaint with the data protection authority in your jurisdiction.

Thank you for taking the time to understand our Privacy Policy!