Volvo Cars Privacy Notice - In-Car Application

Effective from: 2026-4-20
Published at: 2026-4-21

Thanks for using Volvo Cars in-vehicle application! Volvo Cars Asia Pacific Headquarters (with business address at 2088 Luyi Road, Jiading District, Shanghai, hereinafter referred to as “Volvo Cars” “we” or “us”) takes the protection of users’ personal information and privacy seriously. 

As we may collect and use your personal information when you are using Volvo Cars in-car application (“Volvo Application”), we have formulated the privacy notice (this “Notice”) that covers how we collect, store, use, entrusted process, share and protect personal information of users. We will explain to you in this Notice the purpose, manner and scope of our collection and use of your personal information, your rights to your personal information, and the measures we take to protect the information security, in order to provide full disclosure and obtain your consent or separate consent. 

Except as expressly provided in this Policy, this Policy does not apply to products and/or services independently provided to you by third parties through access via our products and/or services (including, without limitation, mapping services, Ximalaya, QQ Music, NetEase Music), such as third-party applications linked through our products and/or services. Such third parties, in order to provide you with their respective services, may collect your personal information and may also receive personal information shared by us. For details regarding the circumstances under which we share personal information with third parties, please refer to Section 4.2 of this Policy. Please note that if you provide your personal information to a third party when using its products and/or services, your information will then be subject to the third party’s privacy statement or similar policy, and we are not liable for any improper use or disclosure of the information provided by you by any third party. 

We understand that individuals or entities associated with you (including but not limited to your contacts, spouse, relatives, friends, drivers, etc.) may also access and experience our application during the use of your vehicle. Their information is provided to us in the process of enabling us to deliver relevant products and/or services to you (“You” and “Associated Persons,” collectively referred to as “You” below). You confirm that, prior to providing such information to us, you have explained to the associated persons the purpose, method, and scope of information use in accordance with this Policy and obtained their consent and authorization, allowing us to collect, store, use, entrust processing, share, transfer, and publicly disclose such information in accordance with this Policy. At the same time, you have informed the associated persons that they have the right to access, correct, and delete their personal information. If you need to resell or scrap the vehicle, or if vehicle maintenance involves replacing the in-car system, please make sure to click “Restore Factory Settings” in the vehicle settings interface; otherwise, personal information generated during your use of the vehicle may be accessible to others. 

Please use Volvo Application after you have fully understood this Notice and clicked “Agree”. If you/your guardian do/does not agree to this Notice, you may object to our collection and use of your personal information by clicking “Disagree”, and then we may not be able to provide you with the relevant services.

This Notice will help you understand the following:

1. How We Collect and Use Your Personal Information

2. How We Use Cookies or Similar Technologies

3. How We Store Your Personal Information

4. How We Process, Share, Transfer, and Disclose Your Personal Information

5. How We Protect Your Personal Information

6. Your Rights Regarding Your Personal Information

7. How We Process Personal Information of Minors

8. Third-Party Service Providers and Their Services

9. How Your Personal Information Is Transferred Globally

10. How This Policy Is Updated

11. How to Contact Us

Section 1: How We Collect and Use Your Personal Information

We collect personal information to operate more efficiently and to provide you with the best possible user experience. The channels through which we collect personal information include: (1) information you directly provide to us during your use of Volvo connected services; (2) information we obtain during your use of Volvo connected services; and/or (3) information obtained from third parties authorized by you.

The information we collect depends on the products and/or services you actually use, the context of your interactions with us, and the choices you make, including your privacy settings and the features you use. Our products and features include core business functions and value-added functions. When we collect information, you may choose to authorize us to collect and use your personal information. For core business functions, if you choose not to provide such information, we may be unable to provide the corresponding services or respond to or resolve issues you encounter. For value-added functions, if you choose not to provide such information, you may be unable to use the relevant value-added functions normally or achieve the intended functionality, but this will not affect your use of the corresponding core business functions.

Certain features and services require the processing of sensitive personal information to function properly. Sensitive personal information refers to personal data that, if disclosed or misused, may infringe upon an individual’s dignity or endanger personal or property safety. This includes, but is not limited to, biometric data, religious beliefs, specific identity information, medical and health data, financial account details, location and tracking information, as well as personal information of minors under the age of fourteen. Sensitive personal information is highlighted in bold in this Notice. Please be aware that the disclosure or unlawful use of such information may result in serious harm to your personal and property safety. You have the right to refuse to provide sensitive personal information; however, refusal to allow us to collect and use such information may affect your ability to use certain features or services.

1. How We Collect and Use Your Personal Information

1.1 Information collected during your use of the products and/or services, as well as information you provide directly to us

(1) In-Vehicle System Activation and Login
When you activate the in-vehicle system via your vehicle's center display, you must scan the QR code displayed on the system using the Volvo Cars App to authorize login. At this point, we will collect your Volvo Cars App account information—including your mobile phone number, user ID, user nickname, profile picture, linked vehicle details, and Vehicle Identification Number (VIN)—to establish a binding connection with the in-vehicle system. This enables further integration between the Volvo Cars App and your vehicle. Additionally, we will collect your vehicle settings information to synchronize your preferences when logging into this vehicle or other vehicles of the same model using this account. You may choose not to log in with your Volvo account and still access most Volvo Car features.

(2) To provide you with multimedia services, our online multimedia platforms (Bilibili, Tencent Video, iQIYI, etc.) are provided by our partners (as specified on the relevant pages), who may collect your information. Before using specific features, please carefully review the privacy policies of these partners. We also supervise our partners' legal compliance through methods such as reviewing qualifications and signing contracts. To maximize the security of your personal information, we strongly recommend reviewing the privacy terms of any third-party service before using it. To protect your legitimate rights and interests, if you discover risks associated with such apps or similar applications, we advise you to immediately cease related operations and contact us promptly.

Our online multimedia services (Ximalaya, QQ Music, NetEase Cloud Music) are jointly developed and provided by our partners and Volvo (as displayed on specific pages). When using Ximalaya, Volvo needs to collect your Vehicle Identification Number (VIN), vehicle model specifications, programs listened to, corresponding albums, authorization type (free, paid, VIP, etc.), and usage time. When using QQ Music and NetEase Cloud Music, Volvo collects your Vehicle Identification Number (VIN), vehicle model specifications, songs listened to, authorization type (free, paid, VIP, etc.), and usage time. Additionally, during operation of each online multimedia service, our partners may also collect your relevant information. The methods and scope of your personal information collected and processed by these partners will be disclosed to you via their respective privacy policies on the app homepages. Before using specific features, please carefully review the corresponding privacy policy. We also supervise partners' legal compliance through methods such as credential verification and contract signing. To maximize the security of your personal information, we strongly recommend reviewing relevant privacy terms before using any such services. To protect your legal rights and interests, if you discover risks associated with these apps or similar applications, we advise you to immediately cease related operations and contact us promptly.

(3) To provide you with map and navigation services
The map and navigation services for the in-vehicle infotainment system are jointly provided by Volvo and AutoNavi Software Co., Ltd. (AutoNavi). When you first choose to use the map and navigation services, you must agree to and comply with this policy, the AutoNavi Map Terms of Service, and/or the AutoNavi Map Privacy Policy. To deliver navigation services, Volvo collects and processes your vehicle location data, destination information, driving trajectory, and vehicle speed (instantaneous speed, average speed, maximum speed). Based on your settings, it may also record home addresses, work addresses, saved locations, and historical search addresses. You may view, modify, or delete this information at any time within the map navigation application. Additionally, AutoNavi will also collect relevant information about you. The methods and scope of AutoNavi's collection and processing of your personal information will be disclosed to you in the form of a privacy policy on the app's home page. If you refuse to provide vehicle location information or driving trajectory information, you will be unable to use the map and navigation services. However, this will not affect your use of other features and services that do not involve vehicle location information or driving trajectory information.

(4) To Provide You with Voice Assistant Services
When you use the human–machine interaction (voice assistant) feature, you are required to provide or allow us to collect your Volvo ID, model year, manufacturer, vehicle model, Vehicle Identification Number (VIN), voice data, text dialogue information, contact list, call records, location information, custom wake-up words, audio and video playback information, and speaker language type. Based on the information you input, we will generate corresponding outputs to provide you with interactive services.

During your use of this product, we will collect your question-and-answer history, including the text dialogue information you input and the conversation topics derived from such information (i.e., understanding your primary intent during the Q&A process), in order to provide you with a continuous and high-quality user experience. To fulfill our obligations under network information content security regulations, we will retain your Q&A history and conversation topics for the period required by law.

To ensure the security of your personal information and privacy, we will not process the content of your interactions with the voice assistant for any purposes other than those disclosed in this Policy, and we will apply necessary de-identification measures (such as removing personally identifiable information) before processing. Based on the characteristics of the product and technology, and to better protect your privacy and personal information, please refrain from entering any personal information while using the human–machine interaction feature to avoid potential information leakage, theft, or other incidents that may compromise your personal rights and interests.

(5) To Provide You with Driving Log Services
The Driving Log is provided by Volvo and automatically records all your trips to help you manage mileage expenses. When you first choose to use the Drive Log service, you must agree to and comply with this policy; otherwise, the Driving Log will not collect any data. You may withdraw your consent at any time, and we will immediately cease data collection. However, this does not affect information already collected.

To provide the driving log service, we will collect your identifiers such as name, phone number, email address, vehicle identification number (VIN), vehicle location information, and other trip-related details including your route, time, distance, fuel consumption and/or fuel usage, and mileage. Depending on your vehicle model, we may collect your starting and ending locations or the complete route for driving directions.

(6) To provide you with digital key services
Digital keys can completely replace traditional car keys, allowing you to conveniently lock, unlock, or start your vehicle using your smartphone or smartwatch. Additionally, keys can be shared with other users through various digital channels. When you first choose to use the digital key service, you must agree to and comply with this policy.

The digital key requires an internet connection only during the initial one-time setup process for sharing or revoking keys. Once configured, the key operates via Bluetooth, Near Field Communication (NFC), and Ultra-Wideband (UWB) technology. During setup, your key is added to the wallet application on your smart device, enabling you to share it through messaging apps, email, or Airdrop®.

To complete the digital key service, we need to collect and process your vehicle identification number (VIN), vehicle details, vehicle status, your Volvo ID, key identifier, and personal nickname.

(7) To provide you with air quality testing services
This feature displays air quality information such as pollution and pollen levels. The initial display shows air quality information inside the vehicle. If you choose to provide us with your vehicle's location, it will additionally display air quality information outside the vehicle. Relevant data is deleted immediately after being displayed inside the vehicle.

(8) To provide you with Event Data Recorder (EDR) services
To comply with applicable legal requirements, we may collect and store safety-related information associated with collision or near-collision events through the Event Data Recorder (EDR), also known as the vehicle's “black box.” Such safety-related information includes: the operational status of various vehicle systems; whether the driver and passengers were wearing seat belts; the degree to which the driver pressed the accelerator and/or brake pedals (if applicable); and the vehicle's speed.

Recording duration typically lasts up to 30 seconds. Please note that recording only occurs during non-minor collisions and does not capture any data under normal driving conditions. Furthermore, the recorded content does not include the geographic location of the vehicle driver or the collision (or its vicinity). Please understand that EDR services are provided in compliance with mandatory legal and regulatory requirements, and we need to collect the aforementioned data to deliver these services to you.

(9) To provide you with the eCall service
To ensure your safety, we have developed the Emergency Call (eCall) feature, which automatically initiates a call upon activation of one or more sensors within the vehicle during a severe accident. When an emergency call is triggered, we need to collect and process your vehicle identification number (VIN), vehicle propulsion or engine specifications, vehicle model specifications, the time of the incident, the location of the incident, the direction of vehicle travel, and the vehicle status.

Both Volvo and third-party call service partners have access to the aforementioned data. If necessary, this data will also be transmitted to emergency service providers (such as ambulance service providers). Please understand that the eCall system is a core business function we provide to you. If you refuse to allow us to collect the aforementioned data, you will be unable to use the relevant services within the Volvo app.

(10) To provide you with call center services
Through our call center service, you can contact our call center by pressing the “on call” (call)/emergency button inside your vehicle, placing a call via the in-app feature, or dialing the call center directly. As part of this call center service, the following assistance is provided:

1. Roadside Assistance (RSA)
Roadside assistance provides support when your vehicle experiences technical issues, including flat tires or engine/motor failures. In some cases, call center agents will guide you through troubleshooting over the phone. In other instances, repairs may be performed at the roadside (known as “on-site repairs”). If roadside repairs are not feasible, the vehicle will be towed to a repair facility for servicing. Service personnel will assess the appropriate response during the call. If roadside assistance (on-site repair or towing) is required, a third party (roadside vehicle towing and repair company) may provide the service vehicle, and the third party will handle the associated data processing.

2) Stolen Vehicle Tracking (SVT)
If a vehicle is stolen, SVT is a method for locating it. The following situations may result in the vehicle being reported as stolen:

• The vehicle itself. When the vehicle detects that the vehicle alarm has been triggered, it sends a “theft notification” to any driver of Volvo Cars app connected to the vehicle, as well as to the call center.

• Vehicle owners to call the call center.

• Local law enforcement (police) to call the call center directly.

To initiate the SVT program, a formal report must be filed with the police, and the case number must be submitted to the call center.

3) Remote Vehicle Immobilization/Movement (RVI/RVM)
RVI/RVM can be used to enable or disable the vehicle's anti-theft device. If the anti-theft device is enabled, the vehicle cannot be started until the device is deactivated. The vehicle can then be remotely mobilized. This service is initiated by a call center agent.

When providing call center services (including roadside assistance, stolen vehicle tracking, and remote vehicle immobilization or mobilization services), we may collect and process the following data: Vehicle Identification Number (VIN), license plate number, vehicle details, vehicle status, time and location of the request, location at the time of the call, and vehicle direction of travel. User access to call center services constitutes voluntary personal action, with location permissions granted on a one-time basis only.

Additionally, depending on the nature and scope of the request, we may also need to process other information required to provide the requested assistance: contact information (home address, email address, phone number), insurance details (policy and claim numbers), transaction-related data, cause of damage, and information about the repair location.

If you decline to allow us to collect the aforementioned information, we may be unable to provide you with call center services. However, this will not affect your use of other basic functions within the Volvo app.

(11) To provide you with intrusion detection services
The objective of the Intrusion Detection System (IDS) is to detect anomalies and violations that may pose a threat to the primary infotainment system. This entails monitoring the behavior of software and applications to ensure they do not breach permitted actions. The IDS will monitor the system in real time and report violations to Volvo Cars.

To provide you with IDS services, we need to collect and process your Vehicle Identification Number (VIN), timestamps (the exact time an event occurred), information related to the specific target associated with a source-initiated event, and technical data (software version, system and collision reports, permissions, and certificates).

(12) To provide you with battery safety monitoring services
We need to ensure that vehicles equipped with hybrid or all-electric powertrains are safe to protect our drivers, their families, and the public from hazards and unnecessary inconvenience. To ensure this, we will collect and use battery-related information to detect potential issues early and identify new types of potential failures. If we deem it necessary, we will also contact you to inform you of potential issues.

To provide you with battery safety monitoring services, we collect and use your vehicle information, including the Vehicle Identification Number (VIN), vehicle details, and hardware and software information. Additionally, we need to collect information related to the vehicle's propulsion system and battery, such as: hardware and software information, battery voltage, state of charge, charging information, configuration, calibration, temperature, alerts, warnings, faults, diagnostics, timestamps, health status, and overall status.

(13) Service Plan
The Service Plan helps you maintain your vehicle in good condition and monitor its status. When your vehicle is connected, Volvo Cars and service centers will collect diagnostic data, which will also be shared with our national sales company and retailers. This enables advance preparation for service when needed and facilitates the management of parts reservations and deliveries.

To provide you with service plans, we need to collect and process your vehicle information, including the Vehicle Identification Number (VIN), vehicle details, and hardware and software information. Additionally, we need to collect and process information generated by the vehicle and its sensors and systems, including odometer readings, service indicators, alerts, warnings, indicator lights, faults, diagnostics, temperatures, timestamps, health status, and the status and behavior of onboard systems and features.

(14) To provide you with diagnostic readout services at service stations
If your vehicle undergoes maintenance or repairs at a service center, repair shop, or partner facility, we will receive and use information for fault tracking to facilitate our troubleshooting efforts, manage product manufacturers, and conduct product development. This enables us to optimize and enhance the safety, quality, and other features of Volvo Cars.

To complete the diagnostic readout function at the service station, we need to collect and process vehicle-related information, including the Vehicle Identification Number (VIN), vehicle details, hardware and software information; Information generated by the vehicle and its sensors and systems, including odometer readings, service indicators, alerts, warnings, lights, faults, diagnostics, connectivity and network information, authentication and authorization data, calibrations, temperature, weather and road conditions, energy and fuel consumption, timestamps, health status, and the status and behavior of onboard systems and functions; Information related to vehicle usage and operation patterns, including configurations, settings, device connections, usage modes (charging, parking, driving), charging information, timestamps, vehicle speed, number of passengers, interactions, and use of the infotainment display (in-vehicle screen), use of remote services, use of vehicle functions (such as throttle, brakes, steering, seatbelts, and doors); and information related to vehicle usage and operation patterns, including configuration, settings, device connections, usage modes (charging, parking, driving), charging information, timestamps, vehicle speed, number of passengers, interactions, and use of the head-up display (in-vehicle screen), use of remote services, and use of vehicle functions (such as throttle, brakes, steering, seatbelts, and doors).

(15) To provide you with error reporting services
Error reporting is a tool that can be activated by the workshop, enabling us to collect information about software defects. This tool is used to identify and investigate the impact of issues, allowing us to resolve software-related problems and maintain the health of our software. Once error reporting is activated, we will collect and process the following data from your vehicle: Information generated by the head-up display, infotainment display, telematics and connectivity antenna modules, and their associated signals, including GPS, DID (Data Identifier), DTC (Diagnostic Trouble Codes), vehicle network diagnostics, Android Auto diagnostics, startup diagnostics, and reports and log files for developers; Interaction data between the driver and the vehicle, including vehicle speed, infotainment settings, navigation destinations, phone contacts, radio settings, third-party app settings, and roadside assistance logs; Driver-related information, including email accounts, phone numbers, and Volvo ID.

(16) To provide you with vehicle data extended analysis services
To conduct a comprehensive investigation into your vehicle's issue, we require the following vehicle data along with basic customer information, including name and contact details; data recorded by the Event Data Recorder and other vehicle safety systems, encompassing speed, GPS, steering angle, braking force, deployment and usage of safety systems, etc.; Data regarding the surrounding environment (temperature, road surface wetness, road characteristics, and exterior camera footage—10 seconds before and after the incident) collected by other vehicle sensors or obtained from such information providers; Data from the vehicle's electronic control units, telematics and connectivity antenna modules, infotainment host, and their associated signals; Vehicle status (mileage, fuel consumption, odometer readings, and other data displayed on the instrument panel); Driver-vehicle interactions, including changes to various settings, account names (Volvo ID and Google ID), and data related to the use of Bluetooth-connected devices; Vehicle identification number (VIN).

This data will be used to identify potential vehicle issues, manage potential warranty cases, and address potential product safety concerns. If this data cannot be collected, Volvo Cars will be unable to investigate the issues.

(17) To provide you with traffic accident investigation services
When our vehicles are involved in traffic accidents, we investigate the causes to improve vehicle safety and the traffic environment. If it benefits our research, we may send you a questionnaire to gather more information about the accident.

During the investigation, we need to collect and process the following data information from you: contact details; vehicle-related information, including the Vehicle Identification Number (VIN), vehicle specifications, license plate number, hardware and software information; Information generated by the vehicle, sensors, and systems, including shutdown objects, engine data, freeze frame data, odometer readings, weather and road conditions, temperature, service indicators, alerts, warnings, lights, faults, diagnostics, connectivity and network information, authentication and authorization data, calibration, energy and fuel consumption, timestamps, health status, and the status and behavior of onboard systems and functions; Information related to vehicle usage and operation patterns, including configurations, settings, device connections, usage modes (charging, parking, driving), charging information, timestamps, vehicle speed, number of passengers, interactions with and usage of the infotainment display (in-vehicle screen), use of remote services, and use of vehicle functions such as throttle, brakes, steering, seatbelts, doors, and airbag deployment; Location data.

(18) To provide you with vehicle data analysis services
To obtain statistical information about our vehicles and their usage for product development purposes, particularly to improve and monitor vehicle quality and safety performance, to provide Volvo Car warranty services, and to comply with our legal obligations regarding emissions monitoring, we may need to collect and use the following data. When you first choose to use the vehicle data analytics service, you must agree to and comply with this policy; otherwise, vehicle data analytics will not collect any data. You may withdraw your consent at any time, and we will immediately cease collecting data. However, this withdrawal does not affect data already collected.

To provide you with vehicle data analysis, we need to collect and process your Vehicle Identification Number (VIN), identifiers for your vehicle's hardware and software versions, and Diagnostic Trouble Codes (DTCs). Additionally, we collect the following information about your vehicle's high-voltage battery (if applicable): high-voltage battery ID, capacity and health status, vehicle market information, charging station details (availability status, power source type, pole ID, etc.), and diagnostic data during charging (duration, state of charge, current fluctuations, etc.).

(19) To provide you with vehicle analysis and improvement services
For the purposes of fault tracing, product research, and development—such as monitoring and improving the sustainability, quality, safety performance, and other features of our vehicles—we may need to collect and use the following data to obtain information about your vehicle and its usage.

To provide you with vehicle analysis and improvement services, we need to collect and process your: Information generated by the vehicle, sensors, and systems, including odometer readings, service indicators, alerts, warnings, lights, faults, diagnostics, connectivity and network information, authentication and authorization data, security logs, calibrations, temperature, weather and road conditions, energy and fuel consumption, timestamps, health status, status of onboard systems and features, behavior of onboard systems and features, and outputs of onboard systems and features; Information related to vehicle usage and operation patterns, including configuration, settings, device connections, trailer connections, usage modes (charging, parking, driving), charging information, timestamps, vehicle speed, number of passengers, interactions with and usage of the infotainment system (in-vehicle screens), usage of remote services, and usage of vehicle functions such as throttle, brakes, steering, seat belts, and doors; Vehicle location data, including location data collected under the following circumstances: (1) Occurrence of incidents (hazards) and accidents, (2) Activation of the emergency call (eCall) function, (3) Connection issues, and (4) Continuous collection by safety features and combined driver assistance systems; Camera data, including images captured by exterior cameras related to incidents and accidents, as well as images continuously collected by safety features and combined driver assistance systems. We have anonymized such images in accordance with legal and regulatory requirements.

The information collected above will be retained for five years. Upon expiration of this five-year period, we will either delete the relevant information or ensure it is fully anonymized. However, information concerning the vehicle's high-voltage battery will be retained for the duration of the battery's service life.

(20) To provide you with over-the-air (OTA) software updates.
To enable maintenance of in-vehicle software and perform necessary updates directly, we may collect and use the following data:

• Vehicle Identification Number (VIN);

• Vehicle Software Version;

• Diagnose fault codes;

• Vehicle Specifications;

• Installation Status and Reports;

• Vehicle manufacturing date.

If you decline remote software updates, this will prevent you from accessing our update services or fully utilizing the functionality. Similar to all other smart devices, failure to perform regular software updates may also increase the risk of cybersecurity incidents. Please note, however, that you may also choose to visit our workshop for installation updates. Should you decline our collection of the aforementioned information, we may be unable to provide you with remote software update services; however, this will not affect your use of the basic functions of the Volvo app.

If you have enabled the Over-the-Air Software Update service, you may still disable this service by navigating to [Settings > System > Software Update > Turn Off Automatic Software Download] to stop us from collecting your relevant personal information.

(21) To provide you with Connected Safety features
To alert you to road changes or potential hazards in a conspicuous manner while you are driving, enabling you to adjust your driving behavior promptly to avoid and reduce road traffic dangers, thereby enhancing road safety.

We may collect and use the following data from you:

• Vehicle Identification Number (VIN);

• Alarm activation signals (including slippery road warning activation signals, hazard warning light activation signals, etc.);

• Alarm Signal Timestamp;

• Location information (Location information is used to alert you to current or potential road hazards).

The collected information will be retained for one week, after which we will anonymize the data.

(22) To provide you with the Fleet Insight proactive safety data recording feature
The primary purpose of the active safety data recording function is to capture data related to traffic accidents or similar collision events. This information will be processed by our R&D department to help us better understand the circumstances under which traffic accidents, injuries, and damage occur.

With your authorization and consent, we will collect and process the following data for future development purposes and to address complaints related to active safety:

• Vehicle Identification Number (VIN)

• Types of security incidents triggered and their occurrence frequency

• Vehicle location at the time of the accident

The legal basis for our processing of the aforementioned data is your consent. The information collected as described above will be retained for a period of ten years. Upon expiration of this ten-year period, we will delete such information or, if deemed necessary to retain the relevant information, ensure its complete anonymization.

(23) To provide you with the Driver Monitoring System (DMS)
To ensure driving safety, when you enable the “Driver Monitoring System” feature, we will monitor your driving status to assess your fitness to drive and issue alerts when necessary. To do this, we collect your facial image data and analyze characteristics such as head position, eye position, and whether your eyes are closed. This information is converted into assessment values to determine your level of fatigue or distraction, enabling us to provide corresponding alerts.

The Driver Monitoring System processes all video images exclusively within your vehicle's cabin. After converting them into evaluation values, collected facial images are deleted. No facial images are stored inside the vehicle or uploaded to cloud servers. You may enable or disable this feature via the consent switch, so as to allow or reject our collection of your facial image data. In accordance with relevant laws and regulations, certain combined driver assistance features require the “Driver Monitoring System” to be enabled in order to function. Therefore, if you disable the “Driver Monitoring System,” you will not be able to use certain combined driver assistance features.

(24) To provide you with map data distribution system services
The map data distribution system identifies vehicle location information, navigation route data, and other relevant data to promptly download surrounding map data, thereby providing “over-the-horizon digital sensor” services for the combined driving assistance system.

To ensure you can smoothly activate the desired functions when your vehicle is operating under the design conditions of the combined driver assistance system, we may collect and use the following data:

• Vehicle Identification Number (VIN)

• Vehicle Specifications

• Vehicle location information

• Destination Information

• Travel path

If you decline to provide the above information, you will be unable to use certain combined driver assistance features. However, this will not affect other combined driver assistance features that do not involve the aforementioned information.

(25) To provide you with Bluetooth services
When you pair your vehicle with your phone using Bluetooth functionality, your vehicle may request access to the following data via Bluetooth:

• Contacts;
• Personal Collection Phone;
• Call Log.

(26) To meet law enforcement requirements
To fulfill legal obligations or to protect the legitimate interests of those who provide us with data, personal data may need to be shared with law enforcement agencies (such as police or courts) when serious crimes are suspected, or when it is necessary to establish, exercise, or defend legal claims.

We do provide technical data, but this data itself does not reveal any connection to individuals (such as automotive part serial numbers associated with the Vehicle Identification Number (VIN), or service history linked to the Vehicle Identification Number (VIN)).

1.2 Information Collected in Compliance with Legal and Regulatory Requirements
To comply with legal and regulatory requirements, we need to monitor the following vehicle data and upload it to national/local new energy monitoring platforms as well as Volvo and its affiliated companies' data platforms. This includes vehicle static information, vehicle data, drive motor data, fuel cell data, engine data, vehicle location data, extreme value data, alarm data, and other information required to be monitored and uploaded under applicable laws, regulations, or government mandates. We are required to upload electronic repair data to the Vehicle Electronic Maintenance Records System, including: basic repair information, license plate number, vehicle identification number (VIN), date of repair submission, mileage at repair submission, settlement date, fault description, settlement invoice number, fuel type, list of replacement parts, part name, part quantity, part code, list of repair items, repair items, and repair labor hours.

1.3 Obtaining Your Information from Third Parties
When you choose to log in to third-party services (including third-party applications) via linked accounts, we may need to collect your third-party account avatar, nickname, and OpenID from the third party. This information is used to identify you, assist with account binding and login, and display your identity information.

We will strictly adhere to the purposes stated in this policy when using your personal information. Your personal information will only be used for the purposes that were identified, explained, and authorized by you at the time of collection. Should we intend to use the information for any other purposes not specified in this policy, we will seek your consent beforehand. Should we intend to use information collected for specific purposes for other purposes, we will seek your consent beforehand. Without user consent, we will not provide user personal information or other vehicle data to third parties for their use.

1.4 Other Usage Instructions
In addition to the explicitly stated purposes, the personal information collected under this policy may also be used for the following purposes. We commit to complying with relevant laws and regulations in its use, including obtaining your authorization and consent when necessary:

(1) Product and Service Enhancement
We may use personal information collected under this policy through research, analysis, and forecasting to improve service quality, enhance user experience, develop new products, and strengthen product security.

(2) Security Prevention and Anti-Fraud
We may use information collected under this policy for security safeguarding, fraud prevention, and illegal activity monitoring purposes to prevent violations of our or other third parties' legitimate rights and interests, breaches of laws or agreements, thereby protecting the legitimate rights and interests of you, us, other third parties, and the public interest.

(3) User Profiles
We may aggregate and analyze personal information collected under this policy, such as conducting analyses or making predictions based on personal preferences and operational behaviors. Please note, however, that we currently do not create personalized feature models based on your individual operational information or browsing habits on the in-vehicle system. Instead, we only generate group-related profiles, which may be used for relevant ecosystem services based on these feature models. For services related to your personal information that you have not separately consented to, we will only use your indirect profile. For example, when conducting commercial advertising promotions, we will only utilize your indirect profile.

(4) De-identification/Anonymization of Personal Information
After collecting your personal information, we will promptly de-identify and/or anonymize the data using technical means. Without disclosing your personal information, we reserve the right to mine, analyze, and utilize (including for commercial purposes) the anonymized user database. When we intend to use information for purposes not specified in this policy, we will seek your prior consent or rely on other lawful bases for processing your information. When we intend to use information collected for specific purposes for other purposes, we will seek your prior consent or rely on other lawful bases for processing your information.

(5) Human-Computer Interaction
We will not share any personally identifiable information that is directly associated with you (including personal account information and identity verification details you voluntarily provide) with any third parties. However, please note that to enhance the smooth operation and service experience of this product, we may provide text dialog content you input during human-machine interaction features to our AI technology service providers. Therefore, to avoid risks associated with sharing personal information with third parties, please refrain from entering any personal information in text dialog content. Specifically, take care not to type any content in the dialog box that may compromise your personal privacy security.

2. Exceptions to Obtaining Authorization and Consent for the Collection and Use of Personal Information
You fully understand that, in accordance with applicable laws, we may collect and use your personal information without obtaining your authorization or consent in the following circumstances:

(1) Necessary for the conclusion and performance of a contract in which the individual is a party;

(2) Necessary for the performance of statutory duties or legal obligations;

(3) To respond to public health emergencies, or when necessary to protect the life, health, and property safety of natural persons in urgent situations;

(4) Processing personal information within reasonable limits for activities such as news reporting and public oversight conducted in the public interest;

(5) Processing personal information voluntarily disclosed by individuals or otherwise lawfully made public within reasonable limits, as stipulated by the Personal Information Protection Law of the People's Republic of China;

(6) Other circumstances as prescribed by laws and administrative regulations. 

Section 2: How We Use Cookies or Similar Technologies

1. Cookies and Similar Technologies
In the vehicle infotainment system, we utilize the [GrowingIO SDK] analytics tool—a universal data tracking platform. This tool records relevant data based on your interactions within the system. This data includes your usage of applications such as Maps, Himalaya, QQ Music, NetEase Cloud Music, Voice Assistant, Scene Assistant, App Center, and Smart Driving News (if applicable), along with your transaction activities. This information helps us understand how you use our products and/or services to further develop and improve them, enhance your user experience, research and develop new products, and recommend content that may interest you.

To provide you with improved user experience services, we need to collect your application usage data and behavioral data for processing and analysis. You may stop data collection by withdrawing your consent to this policy. However, please note that withdrawing consent to this policy may prevent you from continuing to use our products or services and receiving enhanced and personalized experiences.

Section 3: How We Store Your Personal Information

1. Except as required by laws and regulations or as otherwise required by relevant authorities, we will only store your personal information for the period necessary to achieve the purposes outlined in this policy. Beyond this period, we will delete your personal information within a reasonable timeframe or anonymize it.

2. Upon expiration of the consent period, we will obtain renewed consent from the individual. Should the purpose of processing personal information, the method of processing, or the types of personal information processed undergo changes, we will obtain renewed consent from the individual.

3. If we terminate our services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information after the termination of services or operations.

Section 4: How We Process, Share, Transfer, and Disclose Your Personal Information

1. How We Entrust Suppliers to Process Your Personal Information
Certain specific modules or features within our products or services are provided by external suppliers. Examples include our roadside assistance services, maintenance and repair services, insurance services, charging station installation services, and charging station operation and maintenance services. For companies, organizations, and individuals entrusted by us to process personal information, we enter into strict confidentiality agreements or other data protection-related agreements with them. We require them to process personal information in accordance with our instructions, applicable laws and regulations, and to implement other measures necessary to ensure the confidentiality and security of personal information.

2. How We Share and Transfer Your Personal Information
We may occasionally share certain personal information with affiliated companies and strategic partners who collaborate with us to provide products and services, or share and transfer your personal information in other circumstances to deliver the products or services you request. Volvo may share your personal information within the following scope:

(1) Sharing among Volvo entities: To ensure compliance with laws, protect the interests, property, or safety of us, our affiliates or business partners, you, other users, or the public, your personal information may be shared with our affiliates within the scope permitted by laws and regulations. We will only share the personal information necessary to achieve the aforementioned purposes. Without your consent, our affiliates will not use the shared personal information for any purposes beyond those stated above.

(2) Sharing with Business Partners: To fulfill the purposes stated in this policy, certain services may be provided with the assistance of authorized business partners. We may share some of your personal information with these partners to deliver better customer service and user experience. Our business partners include the following types:
a) After-sales service providers. We may share your personal information with after-sales service providers as necessary for them to provide services to you. For example, we may provide your Vehicle Identification Number (VIN), device information, network access credentials, and connected feature-related log information to after-sales service providers to identify and diagnose vehicle connectivity issues, assist you in resolving connectivity problems, and/or provide product upgrade services. We may also provide your vehicle diagnostic codes and mileage to after-sales service providers to provide you with vehicle repair, maintenance, and other related services.
b) Suppliers or Service Providers. To continuously optimize our products and provide you with higher-quality and more diverse services, we may share your personal information with suppliers or service providers to ensure the smooth delivery of services to you. The current scenarios for sharing information with suppliers or service providers are detailed in Appendix I: “Third-Party Information Sharing List.”
c) Third-Party SDKs. In certain specific business scenarios, to ensure the stable operation and functional implementation of our products or services, and to enable you to use and enjoy more services and features, we may embed third-party software development kits or other similar applications (collectively referred to as SDKs) into our products or services to provide you with services. The current status of third-party SDKs integrated into our products or services under this policy that involve the collection of your personal information is detailed in Appendix II: “Third-Party SDK List.”

(3) Transfer of Personal Information: We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
a) Transfer with explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent;
b) Transfer in Cases of Merger, Spin-off, Dissolution, Acquisition, or Bankruptcy: In the event of a merger, spin-off, dissolution, acquisition, or bankruptcy where personal information transfer is involved, we will notify you of the name and contact information of the recipient of such personal information. We will inform the recipient that they must continue to fulfill the obligations outlined in this Privacy Statement and obtain your separate consent.

(4) Information sharing should be conducted when explicitly required by law or regulatory mandates, such as in scenarios related to government investigations, legal proceedings, disputes, or other legal requirements.

(5) When we believe disclosure is necessary to protect our rights in good faith, such as to investigate potential violations of our terms and conditions or to detect, prevent, or disclose fraud and other security issues.

(6) We will only share your personal information for lawful, legitimate, necessary, specific, and clearly defined purposes, and will only share the personal information necessary to provide products and/or services. We will only permit Volvo employees and affiliates who require access to your personal information to do so on behalf of Volvo, and we will only share the necessary personal information, with such sharing being subject to the purposes stated in this policy. Should our affiliates wish to change the purpose of processing personal information, they will seek your authorization and consent again.

(7) We enter into strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information. These agreements emphasize stringent data protection compliance requirements and mandate that they process personal information in accordance with our instructions and any other relevant confidentiality and security measures. For sensitive personal information, we require third parties to employ data anonymization and encryption technologies to better protect user data. However, please note that Volvo and its authorized dealers and service providers are separate legal entities. We generally do not assume liability for unlawful acts committed by Volvo authorized dealers or service providers. If you have any questions regarding how your dealer or service provider collects and uses your personal information, please contact that dealer or service provider directly.

3.How We Publicly Disclose Your Personal Information
We will only publicly disclose your personal information under the following circumstances:

(1) After obtaining your separate consent;

(2) Legal Disclosures: We may disclose your personal information when legally required to comply with subpoenas or other legal processes, lawsuits, or mandatory requests from government authorities. We may also disclose such information if we believe in good faith that disclosure is necessary to protect our rights, safeguard your safety or the safety of others, investigate fraud, or respond to government requests.

4.Exceptions to Obtaining Authorized Consent for Sharing, Transferring, or Publicly Disclosing Personal Information
You fully understand that, in accordance with applicable laws, we may share, transfer, or publicly disclose your personal information without prior authorization or consent in the following circumstances:

(1) Necessary for the conclusion and performance of a contract in which the individual is a party;

(2) Necessary for the performance of statutory duties or legal obligations;

(3) To respond to public health emergencies, or when necessary to protect the life, health, and property safety of natural persons in urgent situations;

(4) Processing personal information within reasonable limits for activities such as news reporting and public oversight conducted in the public interest;

(5) Processing personal information voluntarily disclosed by individuals or otherwise lawfully made public within reasonable limits as prescribed by laws and regulations;

(6) Other circumstances as prescribed by laws and administrative regulations.

Section 5: How We Protect Your Personal Information

We place great importance on personal information security and take all reasonable and feasible measures to protect your personal information:

1. Data Security Technical Measures
We will implement industry-standard security measures, including establishing reasonable systems and protocols, as well as employing security technologies to prevent unauthorized access, use, or modification of your personal information, and to avoid data corruption or loss.

Volvo employs encryption technology to securely store user personal information and isolates it through isolation techniques. Strict data access permissions and multi-factor authentication technologies are implemented to protect personal information and prevent unauthorized use of data.

2. We only permit Volvo and Volvo affiliate employees who have a legitimate need to know such information to access personal data, and have established strict access control and monitoring mechanisms for this purpose. We also require all personnel who may come into contact with your personal information to fulfill corresponding confidentiality obligations. Failure to comply with these obligations will result in legal liability or termination of the cooperative relationship.

3. We recommend using complex passwords when communicating with other users via email, instant messaging, social media, and similar platforms, and taking care to protect your personal information.

4. Please be advised that the internet environment is not 100% secure. We will implement security safeguards in accordance with legal requirements and technological advancements to ensure the security of any information you send to us. However, if our physical, technical, or administrative security measures are compromised due to unforeseeable and unpreventable circumstances, resulting in unauthorized access, public disclosure, alteration, or destruction of information, we shall not be liable for any losses not attributable to Volvo.

5. Security Incident Response
Please safeguard your personal information and only share it with others when necessary. To address potential risks such as personal information leaks, damage, or loss, Volvo has established multiple systems that clearly define classification and grading standards for security incidents and vulnerabilities, along with corresponding handling procedures. Volvo has also established a dedicated emergency response team for security incidents. Following standardized security incident handling protocols, the team activates contingency plans tailored to different incidents to mitigate damage, analyze the situation, pinpoint the source, develop remedial measures, and collaborate with relevant departments to trace the origin and take countermeasures.

In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with legal and regulatory requirements. This notification will include: - The basic details of the security incident and its potential impact; - The measures we have taken or will take to address the incident; - Recommendations for you to independently prevent and mitigate risks; - Remedial measures available to you. We will promptly notify you of the incident via email, letter, phone call, push notifications, or other means. When it is impractical to notify each data subject individually, we will publish an announcement through reasonable and effective channels. Additionally, we will proactively report the handling of the personal information security incident to regulatory authorities as required by law.

We have established dedicated teams for network operations and data security to oversee personal information protection. Should you have any questions regarding our personal information protection practices, please contact us via the contact information provided at the bottom of this policy. If you discover any leakage of your personal information, particularly if your account credentials or passwords have been compromised, please immediately contact us using the contact details in this policy and assist us in taking appropriate measures.

Section 6: Your Rights Regarding Your Personal Information

We respect your rights regarding your personal information. Below are the rights you are entitled to under the law, along with how we protect these rights.

1. Right to Know
We inform you of how we handle your personal information by publishing this policy. We are committed to ensuring transparency in the use of your information.

2. Right to Access and Supplement
You may directly access and update your personal information within our product or service interfaces. This includes logging into your account at any time via the product page to access and make necessary updates to the personal information associated with your account.

You may access your personal information and vehicle usage data through the vehicle's “System Settings” > “User Center.” If you are unable to query or supplement your personal information independently, or encounter any issues while exercising your data access rights, you may contact us via the methods disclosed in this policy to request access to or supplementation of your personal information.

3. Right of Rectification
When you discover that the personal information we process about you is incorrect or incomplete, you have the right to request that we correct or supplement it. You can access the “My Profile” section within the Volvo Cars App, navigate to ‘Settings’ > “Profile,” and review, modify, or update your nickname, profile picture, and related personal information. You may also modify your personal information by accessing the in-vehicle user center. You may also submit correction requests through Volvo entities, authorized dealers, or the customer service hotline (10108666).

4. Right to Erasure
You may choose to delete certain personal information you have provided to us. For some of your personal information, you may contact us by calling our customer service hotline at 10108666 to request deletion. We will assist you in completing the deletion process within the timeframe stipulated by applicable laws and regulations.

5. Account Termination Right
We provide you with the right to deactivate your account. You may deactivate your account via the “My” section in the Volvo Cars App. Alternatively, you may deactivate your account by visiting the Volvo Cars official website, navigating to “Account,” and selecting “Delete Volvo ID.” You may also contact us directly using the methods disclosed in this policy to request account deactivation. After submitting your account cancellation request, we may conduct a manual review to verify your eligibility for account cancellation. We will assist you in completing the account cancellation process within 15 business days of your request submission. Upon account cancellation, we will delete or anonymize all relevant personal information associated with your account, except where otherwise required by applicable laws and regulations. After cancellation, we will no longer be able to provide you with products or services requiring account login.

6. Right of Transfer
When the conditions specified by the national cyberspace administration are met, you have the right to request the transfer of your personal information to a designated personal information processor. We will provide the transfer method in accordance with the requirements of relevant regulations. You may contact us via the contact information provided in this policy to submit a request for the right to transfer personal information.

7. Obtain a copy of your personal information
You have the right to obtain a copy of your personal information. You may contact us via the contact details provided in this policy, and we will provide it to you in text format.

8. Modify the scope of your authorization or withdraw consent
You have the right to modify the scope of your consent or withdraw your authorization. You may contact us via the contact information provided in this policy to submit a request to withdraw consent, including withdrawing consent for the collection and use of your personal information that we hold or control. Performing a factory reset constitutes withdrawal of consent for personal information collection, thereby ceasing all personal information collection.

Please note that withdrawing your consent may result in certain legal consequences. Depending on the scope of your authorization for us to process your information, this may prevent you from continuing to use our products or services. However, your decision to withdraw consent or authorization will not affect the processing of your personal information that occurred prior to your withdrawal based on your authorization.

9. Restrict or Refuse Processing of Personal Information
If you wish to restrict or object to our processing of your personal information, you may contact us via the contact details provided in this policy and submit a rights request. Please note that when you restrict or object to our processing of your relevant personal information, you may be unable to use some or all of the services we provide normally.

10. Right to File a Complaint
You have the right to contact us and file a complaint through the methods disclosed in this policy. We will respond within 15 business days of receiving your complaint. If you are dissatisfied with our response, particularly if our personal information processing practices have infringed upon your lawful rights and interests, you may also file a complaint or report with regulatory authorities such as the Cyberspace Administration, Public Security Bureau, or Administration for Market Regulation, or initiate legal proceedings in a court with jurisdiction.

Please note that for security reasons, we may verify your identity before processing your request. We generally do not charge fees for reasonable requests. However, for repeated requests that exceed reasonable limits, we may charge a fee commensurate with the costs incurred. We may refuse requests that are groundless and repetitive, require disproportionate technical means (e.g., necessitating new system development or fundamental changes to existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical. In such cases, we will provide specific reasons in our response. Additionally, if your request directly involves matters of national security, defense security, public health, criminal investigations, or other issues directly related to public interest, or if it may result in serious harm to the legitimate rights and interests of you, other individuals, or organizations, we may be unable to respond to your request.

Subject to compliance with relevant legal requirements, your close relatives may exercise the aforementioned rights to access, copy, correct, or delete your relevant personal information, unless you have made alternative arrangements.

Section 7: How We Process Personal Information of Minors

1. Our products and services are primarily intended for adults. If you are a minor under the age of 18, you must obtain your guardian's consent before using our products and/or services. When collecting personal information from children with parental consent, we will only use or publicly disclose such information when permitted by law, with explicit guardian consent, or when necessary to protect the child. For personal information potentially involving children under the age of 14, in addition to complying with the provisions of this policy regarding user personal information, we will adhere to the principles of legitimacy and necessity, informed consent, clear purpose, security safeguards, and lawful utilization. We will strictly follow the requirements of laws and regulations such as the Personal Information Protection Law and the Regulations on the Protection of Children's Personal Information Online for the storage, use, and disclosure of children's personal information, and ensure the lawful rights of children and their guardians regarding such information.

2. If we discover that we have collected personal information from minors without first obtaining verifiable parental consent, we will promptly delete the relevant data.

3. If you are the guardian of a minor, and you have questions regarding the processing of the minor's information under your guardianship, or if you have evidence that the minor used our connected vehicle services without obtaining guardian consent, please contact us using the information provided below.

Section 8: Third-Party Service Providers and Their Services

While using our products and/or services, you may access applications and other services linked to Volvo vehicles, websites, and other products but provided by third parties. For example, third-party applications may require vehicle data such as your location to provide services. Consequently, such third-party applications and services may involve your provision of specific categories of personal information to third parties. Volvo assumes no responsibility for the collection or use of personal information by third-party applications or services. We recommend that you carefully review the applicable terms and conditions (and any related privacy statements) before using such applications or services. Make your own decision to use them only after ensuring you fully understand their rules for collecting and using your personal information. If you have any questions about a specific third party's use of your personal information, please contact that third party directly.

Section 9: How Your Personal Information Is Transferred Globally

In principle, personal information collected and generated within the People's Republic of China will be stored within the People's Republic of China. As Volvo Car Group conducts daily operations through affiliated companies and information systems worldwide, your personal information may be transferred to affiliated companies outside Volvo Car Group and third-party service providers (“Overseas Recipients”), or accessed by Overseas Recipients, after obtaining your separate consent:

Our data is currently physically stored in Beijing, Shanghai, and Hangzhou.

The aforementioned Overseas Recipient is:

Section 10: How This Policy Is Updated

1. To provide you with better service and in line with Volvo's business development, this policy may be updated. However, we will not reduce your rights under this policy without your explicit consent. We will notify you of any updates by posting the revised version on Volvo websites and apps, and by providing advance notice via website announcements or other appropriate means before the changes take effect. Please visit Volvo websites to stay informed about the latest privacy notices. In practice, for product upgrades, we will also inform you separately on the feature activation interface about the personal information collected by that feature. If you use or continue to use our products and/or services after we update this policy (we will promptly notify you of the updates), it means you agree to the content of this policy (including updated versions) and consent to our collection, use, storage, and sharing of your relevant information in accordance with this policy.

2. For significant changes, we will also provide more prominent notices (including but not limited to email, SMS, or special prompts on browsing pages, as well as obtaining your consent separately through the feature's display interface to explain the specific changes to the privacy notice).

Significant changes referred to in this policy include but are not limited to:

(1) Our service model has undergone significant changes. For example, the purpose of processing personal information, the types of personal information processed, and how personal information is used;

(2) We have undergone significant changes in ownership structure, organizational framework, and other aspects. These include changes in ownership resulting from business restructuring, bankruptcy, mergers, and acquisitions;

(3) Changes in the primary recipients of personal information sharing, transfer, or public disclosure;

(4) Significant changes to your rights regarding the processing of your personal information and how to exercise them;

(5) When changes occur to the department responsible for personal information security, contact information, or complaint channels;

(6) When the personal information security impact assessment report indicates a high risk.

3. We will also archive previous versions of this policy for your reference.

Section 11: How to Contact Us

If you have any questions, comments, or suggestions regarding this Policy or matters related to your personal information, please send your inquiries to: Volvo Car (Asia Pacific) Investment Holding Co., Ltd., at 2088 Luyi Road, Jiading District, Shanghai. You may also contact us by calling our customer service hotline (10108666) or by reaching out to our User Rights Affairs Contact, Ms. Xu Hewei, at +86 16621032398.

In general, we will respond within fifteen (15) business days, unless otherwise required by applicable laws and regulations. For example, if you request the deletion of your sensitive personal information, we will respond within ten (10) business days. If you are not satisfied with our response, particularly if you believe that our handling of your personal information has infringed upon your lawful rights and interests, you may file a complaint or report to regulatory authorities such as the Cyberspace Administration, the Ministry of Industry and Information Technology, the Public Security Bureau, or the Administration for Market Regulation, or you may initiate legal proceedings before a competent court.

Appendix 1
Third-Party Information Sharing List

Appendix 2
Third-Party SDK List