Privacy Policy
Privacy Policy
Last
Revised: June 19th, 2024
Version: V1.1
Energies
Solutions LLC and its affiliates, including but not
limited to subsidiaries, branches, and holding companies (hereinafter referred
to as “Energies Solutions” or “We”) respect your personal data and are
committed to protecting it through our compliance with this Privacy Policy (the
“Privacy Policy”).
The Privacy Policy aims to introduce you to the purpose, method, and scope of
processing your personal data by Energies Solutions products, mainly including
management platforms, hardware, and software products, and how you can exercise
your rights based on personal data protection.
Before using Energies Solutions products
and related services, please carefully read and understand this policy, and
confirm that you fully understand and agree before starting to use it. By
choosing to use Energies Solutions products and related services, you consent
to the collection or use of your relevant data in accordance with this Privacy
Policy. The following Privacy Policy details our process of collecting, using,
disclosing, and protecting your data. If you have any questions or suggestions
about our Privacy Policy, you may choose to contact us or contact the relevant
responsible person of your business/organization through the method disclosed
in this policy. If you have any questions or concerns about our Privacy Policy,
please contact us.
THIS
PRIVACY POLICY WILL HELP YOU UNDERSTAND THE FOLLOWING:
I. DEFINITIONS AND DECLARATIONS
II. HOW WE COLLECT AND USE YOUR PERSONAL DATA
III. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES
IV. HOW WE SHARE, TRANSFER AND PUBLICLY DISCLOSE YOUR PERSONAL DATA
V. HOW WE RETAIN YOUR PERSONAL DATA
VI. HOW WE PROTECT YOUR PERSONAL DATA
VII. HOW YOU CAN EXERCISE YOUR RIGHTS TO YOUR PERSONAL DATA
VIII. HOW WE PROTECT THE PERSONAL DATA OF MINORS
IX. HOW THIS PRIVACY POLICY IS UPDATED
X. HOW DO YOU CONTACT US?
I. Definitions and
Declarations
1.1
Definitions
Energies Solutions Product Enterprise/Organization User: refers to the enterprise/organization through the enterprise or other
organization authorized administrator or directly through the legal
representative to register as the Energies Solutions product user, and as an
administrator through the Energies Solutions product management platform to
upload the enterprise/organization employee information to establish the
enterprise/organizational structure, on behalf of the enterprise/organization
to open, manage and use Energies Solutions product services. Energies Solutions
product enterprise/organization users include but are not limited to legal
persons, government agencies, organizations, partnerships, or individual,
industrial, and commercial households.
Energies Solutions Product
Enterprise/Organization Administrator: refers to the representative,
authorized or designated by the Energies Solutions product
enterprise/organization user, has operation authority of the Energies Solutions
product enterprise/organization/user management platform system, on behalf of
the enterprise/organization to open, manage and use Energies Solutions product
services Energies Solutions product individual users.
Energies Solutions Product Individual
Users: refers to the individual users of the Energies Solutions product
account, including individual users with the administrator authority of the
Energies Solutions product enterprise/organization user, and all individuals
within the Structure of the Energies Solutions product enterprise/organization
users, as well as the freight drivers who configure the Energies Solutions
products.
End-user Personal Data: refers to
the personal data of individual users collected and processed by Energies
Solutions products, including but not limited to audio and video information
and location information of drivers collected through the equipment in the car,
registration information, usage information, equipment information of the end
users collected, and audio and video recording information outside the car
collected through the driving recorder.
Personal Data: All kinds of
information related to identified or identifiable natural persons recorded
electronically or otherwise, excluding information after anonymization.
Sensitive Personal Data: refers to
personal data that, once leaked or illegally used, may lead to the infringement
of the personal dignity of natural persons or the endangerment of personal and
property safety. Sensitive personal data processed by Energies Solutions products
and services include ID card numbers, whereabouts, personal biometric
information (face, fingerprint), etc. (we will prominently identify specific
sensitive personal data in bold and underline in this Privacy Policy). The
sensitive personal data we process is necessary to provide the relevant
services and cannot be provided without collecting such information.
Anonymization of Personal Data: A
process in which the subject of personal data cannot be identified through the
technical processing of personal data, and the processed information cannot be
restored.
Personal Data Controller:
Organizations or individuals who have the right to decide on the purpose,
method, etc., of personal data processing.
1.2
Declarations
1.2.1 Energies Solutions products do not provide
products or services to minors under the age of 18. Therefore, please confirm
that when you agree to accept this policy and apply to open relevant functions,
we have reason to believe that you are already a natural person with full
capacity for civil rights and full capacity for civil conduct and can
independently assume civil liability. If you do not meet the above conditions,
you should immediately stop applying for the use of the Service.
1.2.2 Please be aware that the
information collected by Energies Solutions products will be stored in the
local server or cloud server independently managed by the Energies Solutions
product enterprise/organization user, and the Energies Solutions product enterprise/organization
user as the personal data controller independently decides the purpose and
method of processing the collected end-user data. Energies Solutions is only in
the purpose of providing services, and is entrusted by the Energies Solutions
product enterprise/organization user to process such data in accordance with
its requirements. In this regard, Energies Solutions does not have the right to
directly access and process the personal data of end users.
1.2.3 Please note that in the
process of using Energies Solutions products, you provide us with personal data
of anyone other than yourself out of business needs, and you should ensure that
you have obtained the consent of the relevant personal data subject before we
process such personal data.
1.2.4 When you use the personal data
provided by the Service to us, when registering, setting up, and managing the
account as a user of the Energies Solutions product enterprise/organization,
the enterprise/organization user administrator account, and the individual
users and services of the Energies Solutions product ("Administrative
Information"), Energies Solutions and the Energies Solutions product
enterprise/organization user jointly decide how to collect and use the
management information.
1.2.5 We comply with the General
Data Protection Regulation (EU Regulation 2016/679) (“EU GDPR”). Please note
that this Privacy Policy covers only those instances when the purposes and
means of processing your personal data are determined by us (in other words, when
we are a “controller” as defined by the GDPR). It therefore does not apply to
any of your personal data which we may process on behalf of
Enterprise/Organization Users (in other words, when we are a “processor” as
defined by the GDPR). Please therefore directly contact the relevant controller
(e.g., your employer, if you are an employee of Enterprise/Organization Users)
for more information about their privacy practices.
1.2.6 If you are a California (USA)
resident, we have not sold personal data, as “sell” and “personal data” are
defined under the California Consumer Privacy Act of 2018, in the preceding 12
months.
II. How We Collect and
Use Your Personal Data
2.1
To Become A Registered User of Energies Solutions Products
2.1.1 Register as An Energies Solutions Product Enterprise/Organization User
In order to register as an Energies Solutions product
enterprise/organization user, so that we can provide Energies Solutions product
services based on the employment and management behavior of your
enterprise/organization, such as creating and managing your account and
associated orders, you need to provide the name of the organization, the
registered number of the organization, the scale of personnel information, and
optionally provide tax code, business scope, business type, registered capital,
legal person, and other information to create an Energies Solutions product
enterprise/organization account. Otherwise, you will not be able to register
the enterprise/organization of Energies Solutions products and use Energies
Solutions product services.
2.1.2 Register as An Individual User of
Energies Solutions Products
Energies Solutions products are not open to individual users for
registration. You need to create a personal user account for you through the
enterprise/organization user administrator. Your enterprise/organization user
administrator needs to fill in your name, photo, email, telephone, work number,
and vehicle registration and license plates to use the basic services provided
by Energies Solutions products. Otherwise, you will not be able to use Energies
Solutions products and services. After registering as an individual user of
Energies Solutions products, you can further provide your avatar, position, and
other personal basic information. If you do not provide such personal basic
information, it will not affect your use of the basic services of Energies
Solutions products.
2.1.3 Provide You with Energies
Solutions Products and Services, Such as Snipe, FT Vision, FT Manager, and
Other Energies Solutions Services
When you use our services through the Energies Solutions platforms, your
business/organization entrusts Energies Solutions to collect your information
to achieve specific functions, specifically:
Energies Solutions products need to collect some information from you,
including driver name, driver working ID, vehicle registration and license
plates, vehicle location, real-time audio and video captured by the products,
vehicle trajectory information, vehicle speed, email, telephone, vehicle
product number, driving mileage, driving time, and face, in order to achieve
functions such as vehicle and driver safety escort, real-time recording of
vehicle and driver status, equipment audio and video playback and editing,
trajectory recording and playback, early warning and alarm, and other
functions.
2.1.4 Provide You with Operation and
Maintenance (“O&M”) Services
Your enterprise/organization user entrusts Energies Solutions to perform
O&M management of devices loaded on the vehicle to which you belong: such
as firmware upgrades, edge configuration deployments, and application updates,
etc., to perform unified O&M operations on massive devices; or log query:
through the type, source, and complex filtering conditions, the device and
cloud logs are checked in detail, so as to grasp the business operation and
solve the problem in the first time.
Based on the above O&M services and upon your consent, we need to collect
your name, working ID, vehicle registration and license plates, vehicle
location, real-time vehicle audio and video, vehicle trajectory information,
vehicle speed, email, telephone, on-board product number, mileage, driving
time, face, and other information to achieve specific functions.
2.1.5 Provide You with AI Algorithm
Model Optimization Services
Your enterprise/organization user entrusts Energies Solutions to optimize
the service performance of the products, and your enterprise/organization user
entrusts Energies Solutions to collect your information for achieving specific
functions. The technology of Energies Solutions' products after the performance
improvement may continue to be used in other products, so as to gradually
improve product services to better serve you. Specifically, with your consent,
Energies Solutions products need to collect certain information from you,
including driver name, driver working ID, vehicle registration and license
plates, vehicle location, real-time audio and video captured by the products,
vehicle trajectory information, vehicle speed, email, telephone, vehicle
product number, driving mileage, driving time, and face and other information
to achieve security protection accuracy, classification and identification of
environmental information outside the vehicle, screening of sensitive
information, encryption, coding or other performance-enhancing services.
2.1.6 Personal Data We Collect from
Other Sources
We may supplement other personal data we collect with information from
third parties or other publicly available sources. If the services you use are
provided by one of our partners and you register with that partner, we may also
receive your personal data from them.
2.1.7 Exceptions to the Acquisition of
Authorized Consents
In accordance with relevant laws and regulations, in the following
circumstances, Energies Solutions products may collect and use your personal
data in accordance with the law without your consent:
(a) Necessary for the conclusion and performance of a contract in which an
individual is a party, in accordance with the law and the collective contract
signed in accordance with the law;
(b) Necessary for the performance of statutory duties or statutory obligations;
(c) Necessary in response to public health emergencies or, in emergency
situations, to protect the life, health, and property safety of natural
persons;
(d) Carry out news reporting, public opinion supervision, and other such
conduct for the public interest, and process personal data within a reasonable
range;
(e) Process personal data disclosed by individuals themselves or otherwise
lawfully disclosed within a reasonable range in accordance with the provisions
of the Data Protection Law;
(f) Other circumstances stipulated by laws and regulations.
III. How We Use Cookies
and Similar Technologies
3.1
Cookies
When you use Energies Solutions products, we store a
small data file called a cookie on your computer or mobile device. Cookies
typically contain identifiers, site names, and some numbers and characters. We
collect and store data about your access to and use of Energies Solutions
products through cookies to provide you with more specific service options,
including helping you avoid the need to repeatedly enter your account
information or helping to determine the security of your account.
Please understand that some of our Energies Solutions product features or
services can only be achieved through the use of cookies. If your browser or
browser add-ons allow it, you may manage or delete cookies based on your
preferences, but this may in some cases affect your secure access to the
Energies Solutions products and the use of some features or services of the
Energies Solutions products.
3.2 Web Beacons and Pixel Tags
In addition to cookies, we also use other similar technologies such as web
beacons and pixel tags on our websites. For example, an email we send you may
contain a click-through URL that links to the content of our website. If you
click on the link, we'll track that click to understand your product or service
needs. A web beacon is usually a transparent image embedded in a website or
email. Thanks to the pixel label in the email, we can know if the email has
been opened. If you don't want your activity to be tracked in this way, you can
unsubscribe from our mailing list at any time.
3.3 SDK
We also use Firebase messaging push service ("FCM") on websites
and apps for message push functionality. FCM's push service provides you with
relevant and useful information, updates, and notifications to provide a better
user experience. These notifications may include but are not limited to
application updates, new feature launches, important announcements, and
promotional activities. You can choose to receive or reject push notifications
we send, and you can change the authorization status of push notifications at
any time in the app settings. The FCM push service is provided and managed by
Google. You can refer to Google's privacy policy to learn more about data
security and protection.
If you have any questions or concerns
about this Privacy Policy or the data processing practices of Energies
Solutions, please contact us through the method disclosed in this policy.
IV.
How We Share, Transfer and Publicly Disclose Your Personal Data
4.1
Sharing
From time to time, we may share some Personal Data
with affiliates and strategic partners with whom we work to provide products
and services in order to fulfill the products or services you have requested.
4.1.1
Share with Energies Solutions LLC's Affiliates
To facilitate our global operations and in accordance
with applicable law, we may transfer your personal data to and access your
personal data from our offices, subsidiaries, and affiliates in the various
countries in which we operate, such as our affiliates in P.R.China: Chongqing
Energies Solutions Technology Co., Ltd and Sichuan Energies Solutions Zhitong
Technology Co., Ltd. This could involve sharing to a country other than the
country that provided or collected it. When we transfer your personal data, we
comply with applicable local data protection laws. We take steps to protect
personal data in any country to which personal data is stored or transmitted.
You can request more information about the transfer mechanism by exercising the
rights described below. For example, to comply with applicable data protection
laws regarding international data transfer mechanisms from the European Union
or the United Kingdom to the United States, we have entered into Standard
Contractual Clauses ("SCCs") approved by the European Commission and
provide additional safeguards to provide adequate protection.
4.1.2
Share with Energies Solutions LLC's Authorized Partners
In some cases, some of our products and services may
be offered or sold jointly with partners or through Energies Solutions LLC
Products Enterprises/Organizations Users. If you register through our partners
or Energies Solutions LLC Products Enterprise/Organization Users, we may also
receive your Personal Data from them, and we may share your Personal Data with
our partners for the distribution of these joint products or with Energies
Solutions LLC Products Enterprises/Organizations Users. Therefore, if applicable,
you should also carefully review the privacy policies of our partners or
Energies Solutions LLC Products Enterprises/Organizations Users, which may have
different terms. For the sole purposes stated in this Privacy Policy, some of
our services will be provided with the assistance of authorized partners. We
may share some of your Personal Data with partners to provide better services.
Our authorized partners, such as cloud service providers: Amazon Web Services,
Inc. and Tencent Holdings Limited; Some of our services may rely on third-party
cloud service platforms, with whom we share your Personal Data to operate our
services, or related business data will be stored on such cloud service
platforms, and third-party cloud service providers may need to collect your
device information and network-related information. We will sign strict
confidentiality agreements with companies, organizations, and individuals that
share Personal Data, requiring them to use Personal Data strictly for the
purposes of this Privacy Policy and to take relevant confidentiality and
security measures to process Personal Data. We will comply with relevant laws
and regulations and keep your Personal Data confidential. We will not publicly
disclose your Personal Data except with your prior explicit consent or
authorization, or as required by law.
4.2
Transfer
We may transfer and disclose the personal data we
collect from you: (1) to contractors, service providers, and other third
parties used to support our business; (2) Complete the reasons or purposes
specified by Energies Solutions LLC Products Enterprise/Organization User or
provided by you; (3) comply with any court order, law, or legal process,
including responding to any governmental or regulatory request; (4) the
performance of our obligations and our rights arising out of any contract entered
into between Energies Solutions LLC Products Enterprise/Organization User or
you and us; (5) if we believe disclosure is necessary or appropriate to protect
the rights, property, or safety of us or others; (7) Obtain your consent. We do
not sell or otherwise share personal data with third parties for direct
marketing purposes. If we enter into a merger, acquisition, bankruptcy, or
other transaction in which a third party takes over (in whole or in part) our
business, all of your personal data we collect may be transferred to a third
party. If one of these events occurs, we will use reasonable efforts to notify
you before your information is subject to different privacy and data protection
practices and require companies and organizations that receive your Personal
Data to continue to be bound by this Privacy Policy and fulfill their relevant
Personal Data protection obligations.
4.3
Public Disclosure
We will comply with relevant laws and regulations and
keep your Personal Data confidential. We will not publicly disclose your
Personal Data except with your prior individual consent or as required by law,
except in the following circumstances:
●
with your explicit, separate
consent;
●
(i) Disclosure based on Law: We
may publicly disclose your Personal Data in cases where required by law, legal
process, litigation, or mandatory requirements of government authorities; or
●
(ii) When filing a lawsuit or
arbitration with you in order to safeguard your legitimate rights and
interests.
4.4
Exceptions to Obtaining Consents
In addition, in accordance with relevant laws,
regulations, and national standards, in the following circumstances, we may
share, transfer, or publicly disclose Personal Data without the prior
authorization and consent of the personal data subject:
●
(a) Necessary for the conclusion
and performance of a contract in which an individual is a party, or in
accordance with law and the collective contract signed in accordance with law;
●
(b) Necessary for the performance
of statutory duties or statutory obligations;
●
(c) Necessary in response to a
public health emergency or, in an emergency, to protect the health and safety
of life and property of natural persons;
●
(d) Carry out news reporting,
public opinion supervision, and other such conduct for the public interest, and
process Personal Data within a reasonable range;
●
(e) Process Personal Data
disclosed by individuals themselves or otherwise lawfully disclosed within a
reasonable range in accordance with the provisions of the Data Protection Laws;
●
(f) Other circumstances stipulated
by laws and regulations.
V.
How We Retain Your Information
In principle, the retention period for the Personal
Data we collect is as long as is necessary to achieve the processing purpose
for which the data was collected and any other permitted related purposes.
Unless laws and regulations require a longer retention period. After the above
retention period, we will delete or anonymize your Personal Data. When we stop
operating some or all of our products or services due to special reasons, we
will promptly inform you and stop the collection and processing of Personal
Data for the relevant products or services, and at the same time transfer the
information we hold with the said products or services. Relevant Personal Data
will be deleted or anonymized, unless otherwise provided by laws and
regulations. Please be aware that Energies Solutions LLC Products
Enterprises/Organizations Users, as Personal Data Controller of Personal Data,
will independently determine the processing methods and purposes of the use of
Personal Data, and the storage location and storage period of Personal Data
will be determined by Energies Solutions LLC Products Enterprises/Organizations
Users. If you have any specific questions, please contact the person in charge
of your business/organization for details. The locations where we store your
personal data mainly include China and Hong Kong in Asia Pacific, the United
States in the Americas, and the Netherlands in Europe. Administrative
information stored by us about you is deleted within 180 days by default from the
date of account deletion.
VI.
How We Safeguard Your Information
6.1 Technical Security Protection
To ensure the security of your information, we have
taken reasonable and feasible security protection measures in line with
industry standards to protect your information and prevent Personal Data from
unauthorized access, public disclosure, use, modification, damage, or loss. For
example, we will use trusted protection mechanisms to prevent Personal Data
from being maliciously attacked; we will deploy access control mechanisms to
ensure that only authorized personnel can access Personal Data; and we will
conduct security and privacy protection training courses to strengthen
employees’ awareness of the importance of protecting Personal Data.
6.2
Certifications of Safety System
Energies Solutions LLC products have an
industry-leading data security management system, which improves the security
of the entire system from multiple dimensions, such as organizational
construction, system design, personnel management, and product technology.
6.3
Personnel Management
We also take strict management of employees or
outsourced personnel who may have access to your information, including but not
limited to adopting different authority controls according to different
positions, signing non-disclosure agreements with them, and monitoring their
operations. We will provide corresponding security measures to protect your
information and provide reasonable security according to the existing
technology, and we will try our best to prevent your information from being
leaked, damaged, or lost. We will hold security and privacy protection training
courses to enhance employees’ awareness of the importance of protecting
Personal Data.
6.4
Password Protection Reminder
Please note that the Internet is not an absolutely
safe environment. Please use a complex password when using Energies Solutions
LLC products to help us ensure the security of your account. We will make
reasonable commercial efforts to safeguard the security of any information you
send us. If our physical, technical, or management protection facilities are
damaged, resulting in unauthorized access, public disclosure, tampering, or
destruction of information, resulting in damage to your legitimate rights and
interests, we will assume corresponding legal responsibilities.
6.5
Personal Data Breach
After a Personal Data security incident occurs, we
will promptly inform you in accordance with the requirements of laws and
regulations: (1) the types, causes, and possible hazards of Personal Data
leakage, tampering, or loss of Personal Data that has occurred or may occur;
(2) security incidents' situation and possible impact, disposal measures we
have taken or will take, suggestions for you to prevent and reduce risks on
your own, remedial measures for you; and (3) our contact information. We will
notify you of the incident-related situation by email, letter, telephone,
website notification, etc. When it is difficult to inform the subject of
Personal Data one by one, we will publish an announcement in a reasonable and
effective way. At the same time, we will also report the handling of Personal
Data security incidents in accordance with the requirements of regulatory
authorities.
VII.
How You Manage Your Personal Data
7.1
Inquiring, Correcting, Supplementing, and Copying Your Personal Data
7.1.1. Energies Solutions LLC Product Enterprise/Organization User
As the administrator of the Energies Solutions LLC
Products Enterprise/Organization, you have the right to inquire, correct or
supplement the information of your enterprise/organization, except in the
exceptions stipulated by laws and regulations.
7.1.2.
Energies Solutions LLC Products Individual User
As an individual user of Energies Solutions LLC
products, you have the right to inquire, correct, supplement, or copy your
Personal Data. You may contact us or contact the relevant responsible person of
your business/organization to request the exercise of the above rights by means
disclosed in this Policy.
7.2
Reproduction and Transfer
You have the right to copy your Personal Data we hold
or, subject to legal regulations, request that we transfer your Personal Data
to the place you designate. You may contact us or the relevant responsible
person of your business/organization to request the exercise of the above
rights by means disclosed in this Policy.
7.3
Change the Scope of the Authorization
You have the right to change or withdraw the scope of
your authorization for us to collect and process your Personal Data. You may
contact us or the relevant responsible person of your business/organization to
request the exercise of the above rights by means disclosed in this Policy.
After you withdraw your consent, Energies Solutions LLC Products can no longer
provide you with the services corresponding to the withdrawal of consent, and
will no longer process the corresponding Personal Data. However, your decision
to withdraw your consent will not affect the processing of Personal Data
previously carried out based on your consent.
7.4
Restricted Processing
In any of the following situations, you have the right
to contact us through the methods disclosed in this policy or to contact the
relevant responsible personnel of your enterprise/organization to request
Energies Solutions LLC or the enterprise/organization to restrict its
processing of your personal data:
●
(a) When you doubt the accuracy of
your personal data, allow Energies Solutions LLC or Energies Solutions LLC
enterprise/organization users to verify the accuracy of your personal data
within a reasonable period of time; or
●
(b) When it is verified that the
data processing is illegal, you request not to delete the personal data
directly but to request Energies Solutions LLC product
enterprises/organizations users to restrict the use of the personal data; or
●
(c) Energies Solutions LLC or
Energies Solutions LLC product enterprise/organization users no longer need
personal data for processing purposes, but restrict their deletion of data
because you need the personal data for the establishment, exercise, or defense
of legal rights; or
●
(d) Other circumstances that
restrict processing as stipulated by data protection law.
7.5
Rejection
You have the right to refuse Energies Solutions LLC or
Energies Solutions LLC product enterprise/organization users to process
personal data at any time for direct marketing, commercial purposes, or other
situations stipulated by data protection laws as personal data processors. You
can contact us or the relevant responsible person of your business/organization
to request the exercise of the above rights.
7.6
Deletion
You may request that we delete your Personal Data by
contacting us by the means disclosed in this Privacy Policy or by contacting
the relevant responsible person of your business/organization, when:
●
(i) The purpose of the processing
has been achieved, cannot be achieved, or is no longer necessary to achieve the
purpose of the processing;
●
(ii) The Personal Data Controller
has stopped providing products or services, or the retention period has
expired;
●
(iii) Withdrawal of consent by
individuals;
●
(iv) Personal Data Controller
processes Personal Data in violation of laws, regulations, or agreements;
●
(v) Other circumstances provided
for by laws and regulations. Please note that the exercise of the right to
erasure is not absolute, and only in the above statutory circumstances, you
have the right to request us to delete your Personal Data. In addition, due to
statutory requirements for retention or technical limitations, it may be
difficult for us to delete your Personal Data, but we will stop processing
activities other than storing and take necessary security measures.
7.7
Cancel Your Account
When your enterprise/organization user cancels the
Energies Solutions LLC product enterprise/organization account, Energies
Solutions LLC products will also cancel your personal user account and will
delete your Personal Data or anonymize it in accordance with the requirements
of applicable law.
- If your enterprise/organization user account is a fee-based
account, if the purchased Energies Solutions LLC products and services
have not been renewed due to expiration or do not renew the subscription
after the deadline, we have the right to cancel the
enterprise/organization account.
- You can apply to the administrator of your enterprise/organization
to cancel your personal account or your personal account will be canceled
at the same time as the account of your enterprise/organization will be
canceled. After you voluntarily cancel your account, we will stop
providing you with products or services, delete your Personal Data as
required by applicable law, or anonymize it.
7.8
Pre-existing Arrangements for Account Information
In accordance with relevant legal requirements, you
can make pre-existing arrangements for your Personal Data in advance, and you
can contact us by means of the disclosure of this policy or contact the
relevant responsible person of your business/organization to inform you of your
arrangement in writing; Unless otherwise arranged, your close relatives may,
based on their legitimate interests, exercise the right to access, copy,
correct, delete, etc. on your Personal Data after your death in accordance with
relevant laws and regulations and the provisions of this Privacy Policy.
7.9
Respond to Your Above Request
For security purposes, you may be required to provide
a written request or otherwise prove your identity. We may ask you to verify
your identity before processing your request. We will respond within 15 days.
If you are not satisfied, you can also make a complaint through the customer
service of Energies Solutions LLC products or the contact information disclosed
in this policy. We do not charge a fee in principle for your reasonable
request, but we will charge a fee at our discretion for multiple requests that
repeat and exceed reasonable limits. We may reject requests for information
that is not directly related to your identity, that is unwarrantedly
repetitive, or that requires excessive technical means (e.g., the need to
develop a new system or fundamentally change existing practices), that poses a
risk to the legitimate interests of others, or that is impractical (e.g.,
involving information stored on backup tapes). Please be aware that in the
following cases, we will not be able to respond to your request in accordance
with the requirements of laws and regulations:
●
Related to national security and
national defense security;
●
Related to public safety, public
health, or major public interests;
●
Related to criminal investigation,
prosecution, trial, and enforcement of judgments;
●
There is sufficient evidence that
the Subject of Personal Data has subjective malice or abuse of rights;
●
Responding to your request will
cause serious damage to the legitimate rights and interests of you or other
individuals and organizations;
●
Involving Energies Solutions LLC
product company and/or Energies Solutions LLC product enterprise/organization
user trade secrets.
VIII.
How We Process Information about Minors
We value the protection of minors' information. Please
be aware that under normal circumstances, Energies Solutions LLC products do
not provide products and services to minors under the age of 18. Unless you
submit real-person authentication information or combine other information
(such as browsing, search records, etc.) to identify you as a minor, we will
presume that you have the corresponding capacity for civil conduct in
accordance with business practices, and your age is in line with the legal
working age stipulated in the Labor Law. If you are a minor, please read this
Policy carefully with your parents or other guardians and use our services or
provide us with information with the consent of your parent or other guardian.
If you are not of legal working age, you may not use Energies Solutions LLC
Products, even with the consent of your parent or other guardian. If you are
the guardian of a minor, when you have questions about the processing of the
information of the minor under your guardianship, or if you have evidence that
the minor has registered to use our products and/or services without the
consent of the guardian, please contact us through the contact information
disclosed in the "How to Contact Us" section of this Policy. We will
verify it as soon as possible and take all reasonable measures in a timely
manner to assist you in deleting or anonymizing the relevant information.
IX.
How to Update this Privacy Policy
Our Privacy Policy is subject to change. We do not
limit your rights under this Privacy Policy without your explicit consent. We
will post any changes to this Privacy Policy on the Energies Solutions LLC
Product Platform, Energies Solutions LLC APP, or the Energies Solutions LLC
Products Website. For material changes, we will solicit comments,
announcements, and provide you with pop-up alerts through the primary.
X. How to Contact Us
If you have any questions, comments or suggestions
about this Privacy Policy or our Personal Data processing activities, you can
contact us in the following ways. Please contact us via: Email
[info@muddasar.dev]
To communicate with our Data Protection Officer,
please send an email to [info@muddasar.dev]
If you are not satisfied with the responses you have
received, you can refer your complaint to the relevant supervisory authority in
your jurisdiction. If you consult us, we will provide information on the
relevant complaint avenues that may be applicable based on your location.
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