Supplemental Statement on Smart Vehicle Data Transfer

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1. Purpose of Collection and Use: In order to provide and continuously improve connected vehicle services, intelligent driving assistance functions, vehicle operation monitoring, and routine operation and maintenance services, the Company will collect, use and process vehicle-related data in relation to you in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “PDPO”), and solely for the above purposes or purposes directly related thereto.

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2. Categories of Data Involved: Such data includes, but is not limited to, the Vehicle Identification Number (VIN), desensitized location data, de-identified or masked exterior vehicle images and video data, exterior perception data, and overall vehicle operating status (collectively, the “Relevant Data”). The Company will ensure that the data collected is relevant to the above purposes and not excessive.

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3. Provision of Data: The provision of the Relevant Data is necessary for the Company to provide connected vehicle and related smart services to you. If you fail to provide such data, the Company may not be able to provide some or all of the services or functionalities to you.

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4. Data Transfer and Disclosure: For the purposes set out above, the Company may transfer or disclose the Relevant Data to its affiliates, appointed service providers (including IT, data processing and cloud service providers), maintenance, technical support or operational service providers, or to such parties as required by applicable laws or regulatory authorities. Such recipients shall only process the Relevant Data within the scope of the purposes and in accordance with the Company’s instructions, and shall be bound by legally enforceable contractual obligations.

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5. Cross-border Data Transfer: You acknowledge and agree that, for the purposes set out above, the Relevant Data may be transferred, transmitted or stored outside Hong Kong (including, without limitation, Mainland China). The Company will take all reasonably practicable steps to ensure that such transfers comply with the PDPO, including: (i) entering into legally binding agreements with overseas data recipients; (ii) requiring them to adopt a level of protection not less than that required under the PDPO; and (iii) permitting them to process the Relevant Data only in accordance with the Company’s instructions.

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6. Data Security Safeguards: The Company will implement all reasonably practicable technical and organizational measures to safeguard the Relevant Data, including but not limited to encryption, de-identification, strict access controls, and staff confidentiality obligations. The Company has also entered into written agreements with data recipients requiring them to implement appropriate security measures to prevent unauthorized or accidental access, processing, loss or disclosure.

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7. Retention Period: The Relevant Data will be retained only for as long as necessary to fulfill the above purposes and will be deleted or anonymized when no longer required. Unless otherwise required by applicable law, such data will not be retained for longer than is reasonably necessary following termination of the relevant services.

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8. Data Subject Rights: You have the right under the PDPO to request access to and correction of your personal data held by the Company. The Company will handle such requests in accordance with applicable legal requirements.

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Your Rights

You have the right to request access to and correction of the Information collected from your AVATR vehicle and/or your personal data held by us at any time, by sending an email to our Data Protection Officer at marketing@avatr.hk .

 

Data Protection Officer of our Company

The person to whom requests for access to data or correction of data or for information regarding our Company's privacy policies and practices and kinds of data held and for any other communications herein above described are to be addressed is as follows:

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The Data Protection Officer

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Evolve New Energy Motors Company Limited

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8/F, DCH Building, 20 Kai Cheung Road, Kowloon Bay, Kowloon

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Tel: 2262 1380

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Email: marketing@avatr.hk

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Language

If there is any discrepancy between the Chinese and English versions, the English version shall prevail.