Customer privacy statement
Your privacy is important to us. Our Privacy Statement is designed to promote transparency and help you understand our privacy practices in a form that is easy to read and navigate. Please read the following sections to understand how we collect, use, share and protect your information to provide you with a smooth vehicle product experience. This statement applies to the products and services provided to you by Jiangsu Kaiwo Automobile (Jiangsu) Co., Ltd. and its affiliated companies ("we").
Privacy protection starts from day one
Your Skywell generates vehicle, diagnostic, and infotainment system data. Privacy protection is on from the moment you accept delivery of your vehicle. Generally, we will not associate
vehicle data generated by driving behavior with your identity or account. Therefore, your driving behavior cannot be known to anyone but you. Your other activities in the cabin are also protected. The infotainment data we collect (such as voice commands, web browsing through touch screens, etc.) will not be associated with your identity information or account, fully ensuring the privacy and security of your information.
We may collect the following two types of information, which may be related to you or your use of our products and services:
•Information from or about you
•Information from or about your Skywell
Depending on the Skywell products and services you apply for, own or use, not all the above categories of information may apply to you.
When you interact with us before purchasing
When you visit our website, mini programs, visit experience stores and showrooms, participate in online and offline activities, conduct vehicle test drives, and contact us with any questions or product information (including on-site, online chat, by phone and electronic We may collect a variety of information from or about you, your vehicle and equipment, or from third parties. For example, the data we collect may include:
Information from or about you
| Data category |
Explanation |
Use |
| Contact Information |
Your name, address, region, phone number, email address, preferred contact method. |
To communicate with you, process your requests, and provide products or services based on your consent or our contract with you. |
| Communication Or Interaction Records |
Your information requests, phone calls, emails or face-to-face communication, visits, text messages, Skywell events and test drives. |
Communicate with you, confirm relevant qualifications, and provide products or services based on your consent or our contract with you. |
| Network Activity And Device Information |
Your device information (including device unique identification number, such as Android ID), device model, browser type, operating system, region, IP address, pixel tags, cookies, SD card status, network data, WIFI status, etc. |
Based on your consent or the contract we enter into with you, and/or our legitimate interests in improving user experience and security, optimize website and application performance to protect the performance and operational security of your account and mobile applications. |
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We may also receive the above information about you from other lawful sources, such as public databases, joint marketing partners, qualified installers, affiliates and business partners, and social media platforms.
Cookies and other similar technologies: Cookies are pieces of information that are stored directly on the computer you are using. When you visit our website, we may use some important cookies in order to provide you with the services you request or to ensure the normal functioning of our website.
When you are a Skywell customer
If you are an owner of Skywell products or services, we may also collect information from or about you, your Skywell vehicle information, or from third parties. We may collect this information via remote access or in person (such as during maintenance services). Depending on the Skywell products and services you apply for or use, not all of the above categories of information may apply to you.
Skywell Account: Customers who purchase certain Skywell products may create a Skywell account hosted on our website. You may access your Skywell account at any time to update information from or about you in that account. The information contained in your account includes:
•Your order status
•Your customer registration information
•Warranty and other documentation for your Skywell product
•Charging station history
•Payment method information
•Other general information about your Skywell product (for example, vehicle identification number or other product serial number, warranty plan or in-car entertainment service package), driver's license and other information.
Information from or about you
| Data category |
Explanation |
Use |
| Order Information |
Your mall purchase details, after-sales details, and other documents required for vehicle binding, such as driving license and ID card. |
To fulfill your product and service requests in accordance with our contract with you. |
| Customer Service Records |
Your feedback content, date, and customer service reply content. |
To provide customer service and technical support in accordance with our contract with you and our legitimate interests in maintaining customer satisfaction. |
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Information from or about your Skywell vehicle
| Data category |
Explanation |
Use |
| Vehicle Type |
Vehicle year, make, model, vehicle identification number, configuration |
To fulfill your product and service requests in accordance with our contract with you |
| Vehicle Data |
Telemetry data about your vehicle’s performance, usage, operation and vehicle health |
To provide you with care, maintenance (including remote vehicle diagnostics and support) and continuous improvement of your vehicle based on your consent or our contract with you, or our legitimate interests in ensuring product safety and product improvement |
| Charging Information |
Charging stations used, utilization, charging rates, battery analysis and performance data |
Fulfill your service requests in accordance with our contract with you and improve the charging network based on our legitimate interests |
| Diagnostic Data |
Logs for identifying and resolving problematic software or connectivity issues, and other debug log reports |
Classify and fix software or product issues (including remote vehicle diagnostics and support) pursuant to our contract with you, or our legitimate interests in ensuring product safety and product improvement |
| Infotainment system data |
Analysis of infotainment system usage, e.g. normal functionality or loading failure |
Provide you with care, maintenance (including remote vehicle diagnostics and support) and continuous improvement of your vehicle based on your consent or in accordance with our contract with you, or our legitimate interests in ensuring product safety and product improvement |
| Skywell Mobile App Information |
Analysis of mobile application usage, such as functionality or failure to load |
Ensure the reliability and maintenance of the Application based on our legitimate interests in improving user experience and ensuring the security and stability of the Service |
| Skywell Service and Repair History |
Service facilities, dates, mileage, repairs performed, estimated fees and costs, parts details and other similar information |
Provide services and repairs to you, report to you in accordance with our contract with you, and improve quality and reduce costs in accordance with our legitimate interests in optimizing internal business processes |
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Your Skywell generates three categories of data: vehicle data, diagnostic data, and infotainment system data.
To ensure continued vehicle operation, predictive maintenance, and improved functionality and experience, your Skywell collects and processes vehicle data related to vehicle use, operation, and condition. This information is used to identify and resolve potential problems and to continuously improve your vehicle and the service provided to you. To protect your privacy, this vehicle data will generally be stored in a manner that is not associated with your account or vehicle number, is stored in an encrypted format that we cannot decrypt, or is inaccessible except in certain events Triggered:
•If your vehicle requires service or repair, or you proactively request service or repair
•In the event of a safety incident (e.g. vehicle collision, airbag deployment or emergency braking event)
•If your vehicle requires road safety services such as emergency response or roadside assistance
•If your vehicle is experiencing hardware or software issues that may be checked and resolved through future software updates or other solutions
•If you consent, or other legal basis applies
We clearly define what vehicle data we do and do not collect. Subject to local laws, for example, vehicle data collected includes: vehicle speed information, odometer readings, vehicle component signals, Internet connection status, battery usage management information, battery charging history, electrical system functions, software version information, information Entertainment system data, safety-related data, information on summon and other functions, and other data used to help identify problems and analyze vehicle performance.
1.Location Services: Your Skywell uses location data to support functions such as in-car maps, navigation or mobile application location services. Location services may use a combination of GPS, Bluetooth, IP address, Wi-Fi, and mobile towers to determine your location. To protect your privacy, location data will be processed directly locally in the vehicle, or in a form that does not identify you personally, or to which we have no direct access (unless required by local law). When you encounter a safety incident (such as a collision, air bag deployment, or automatic emergency braking event), we may use your vehicle's location information to provide timely assistance. Please note that some advanced features, such as real-time traffic conditions and intelligent route planning, rely on this data.
2.Safety Analysis Data: To help improve our products and services, we may collect and store other vehicle data, some of which may contain information that identifies you or your vehicle chassis number, including: Regarding accidents involving your Skywell Or data about minor accident-like situations (such as collision, airbag deployment or automatic emergency braking events); remote service-related data (such as remote locking/unlocking, turning on/off air conditioning, start/stop charging and siren commands); confirmation Data reporting of your vehicle online, current software version information and certain telematics; data about any issues that could significantly affect the operation of your vehicle; data about any critical safety issues; and data about each software and firmware update.
3.Charging Information: We may collect information about charging rates and the charging stations you use to analyze which charging stations are being used, how long and efficiently the battery is charged.
4.Service History: In order to facilitate the service and repair of your vehicle, we may collect and process data about past services from Skywell service centers or third-party authorized body spraying centers. This data includes names, frame numbers, repair history, parts details, expense estimates and costs, outstanding recalls, due bills, customer complaints and any other information related to the vehicle's service history.
5.Turn Off Vehicle Data Collection: Network connectivity and vehicle performance are core building blocks of all Skywells, necessary to achieve advanced features and a comfortable driving experience, and are also the reasons why some customers choose Skywell. By default, we will collect the necessary data to provide you with a smooth experience while protecting your privacy. However, if you no longer wish us to collect vehicle data or any other data from your Skywell, please contact us to disable the network connection. Please note that some advanced features (such as OTA over-the-air updates, remote services, interaction with mobile applications, etc.) as well as in-car functions (such as location search, Internet radio, voice commands, and web browser functions) rely on network connection services. If you choose to turn off vehicle data collection, we will not be able to know or promptly notify you about problems or applicable updates that occur with your vehicle. This may result in reduced functionality, severe damage, or inoperability of the vehicle.
We use diagnostic logs to keep our products and services updated, to troubleshoot or debug, and to make continuous improvements. We strive to collect the minimum necessary diagnostic data to help ensure your vehicle or energy product is reliable, safe and functioning properly. Diagnostic data may include details about vehicle configuration, firmware, energy usage, electronic system status, as well as data transmitted between different systems to identify errors and perform technical evaluations. For specific events, we use the diagnostic logs as basic error information to help determine whether the problem encountered can be solved by updating the software version to the latest version or the next version.
3.Infotainment System Data
When using a vehicle's touchscreen, Skywell may collect certain information, which may be stored locally in the vehicle or shared with us in a manner that is not associated with your account or chassis number. To protect your privacy, your in-car browser history and login credentials are not shared with Skywell. The infotainment system data we collect may include: aggregate counts of features or applications you use, playback and browsing metadata (such as station listening times and channels), and the approximate location of local station options. For some third-party infotainment applications that require login, if you do not have your own account, you can choose to use the system account provided by Skywell to log in and use the application. If you choose to use a system account provided by Skywell, your infotainment system data for that specific application may be associated with your Skywell account or vehicle chassis number. In addition, if you experience performance issues with your infotainment system and require support, we may retrieve certain infotainment system data in order to fulfill your request, efficiently troubleshoot or debug problems, and improve our products and services.
1.Voice Commands: Every Skywell has the ability for you to issue commands to the vehicle using your voice. To support continuous quality improvement, Skywell captures and transcribes commands (e.g., "Set the temperature to..."). To protect your privacy, Skywell does not capture voice audio recordings, and the text conversion of voice commands will not be associated with your account or vehicle chassis number. Additionally, Skywell does not collect any information when using the speech-to-text feature, so the text of your message will not be sent to us.
2.Skywell Mobile App: The Skywell app enables direct communication between car owners and their vehicles. With the Skywell app, you can do the following: check the vehicle's charging progress and start/stop charging in real time, heat/cool the cabin before driving, lock/unlock the vehicle from a distance, adjust seat heating/ventilation, or locate you The current location of your mobile device or vehicle to facilitate providing or recommending services to you. In order to detect and proactively resolve issues related to the functionality of the Skywell App, handle any customer complaints and prevent unauthorized access or misuse, certain general usage information associated with your account or VIN may be shared with us . For example, if you use the Skywell App to change the cabin temperature of your vehicle, we may collect data on the success or otherwise of that command. If you choose to use the mobile key function or other content sharing functions, the Skywell mobile application may read the clipboard information of your mobile device, and the Skywell application may read the sensor information of your mobile device to ensure that the mobile key function works properly. The Skywell application will also provide you with message push services during running (the application is opened on the home screen), or while running in the background (through the self-launch function when the application is not active on the home screen). You can choose to turn off the push message service at any time through the settings options of your mobile device.
We may use the information we collect to:
1.Communicate with you
2.Implement our products and services
3.Improve and enhance the development of our products and services
This includes contacting you with important safety-related information, notifying emergency responders in the event of an accident involving your vehicle, providing products and offers tailored to you, or responding to your inquiries and fulfilling your requests for product information, Requests for Skywell updates or other activity.
When you contact us for information or to make a purchase, we may use the data we collect for a variety of purposes. The following are examples of how we use your personal data to provide you with a smooth experience using our vehicle products and energy products.
Reasons for processing data
•Respond to your inquiries and fulfill your requests
•Provide you with information about events and promotions, and manage these events
•Share administrative information with you, such as changes to our terms, conditions and policies
•Help you understand and learn about topics that may interest you
•To tell you important safety-related information about your vehicle or to notify emergency responders in the event of an accident involving your vehicle
•Conduct research, surveys and get your feedback
Realize our products and services
•Complete your purchase, apply for a product lease or loan, and install or deliver the products you ordered
•Process payments for your products or services
•Process, assist and provide relevant customer support
•Monitor the performance of Skywell products and provide related services, including OTA over-the-air updates
•Understand, classify and resolve questions or concerns about products and services
Improve and enhance the development of our products and services
•Research, develop and promote new products and services, and improve or modify our existing services
•Analyze and improve the security of our products and services
•For operational needs, such as: data analysis, auditing, monitoring and preventing fraud, business planning, determining the effectiveness of promotional activities, reporting and forecasting
•Fulfill contractual obligations with third parties, agents and affiliates
•Analyze, recreate, investigate or otherwise determine the cause of a vehicle-related incident or accident
•To comply with legal obligations, law enforcement requests and other government requests (in which case your authorization is not required)
•Establish, exercise or defend legal claims
•Subject to your other permission or instructions
We only retain personal data for as long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Notice, our service-specific notices, or as required by law. Criteria for determining data retention may include considering the purpose of the data, our relationship with you, whether there is an existing service contract, whether you have given consent or whether there is a legal requirement to retain certain data. We carefully review whether it is necessary to retain the personal data collected and strive to ensure that the data is retained for the shortest possible time.
When we process personal data about you, we will obtain your consent and/or as required to provide the products or services you use, operate our business, fulfill our contractual and legal obligations, protect our systems, products and customer's security, or to achieve Skywell's other legitimate interests as described in this section. We will not share information that identifies you with unaffiliated third parties for their marketing purposes unless you choose to participate in such sharing.
We may also use and disclose your information if we believe in good faith that the law requires it for security, compliance with our legal obligations (such as a subpoena or court order), law enforcement, or other matters of public importance. Disclosure of information about you. We may also share information about you if we have a legal basis to do so if we determine that disclosure is reasonably necessary to enforce our Terms of Use or protect our operations or customers. This may include providing relevant information to public or government authorities. In addition, in the event of a reorganization, merger, change of control, or sale, we may transfer any personal data we collect to the relevant third party.
Collect and use non-personal data
Except as described here, Skywell may also collect, use and share information that does not independently identify you. Such information may be used for any purpose, including, for example, for operational or research purposes, industry analysis, improving or modifying our products and services, better customizing products and services to your needs, and as required by law.
We may share information with:
•Our service providers, business partners and affiliates
•Third parties authorized by you
•Other third parties required by law
We limit how and with whom we share your personal data. Examples of when we may share your information include: processing payments, order fulfillment, product installation, customer service, marketing, financial services, after-sales service or repair, and other similar services.
We will not sell your personal data to anyone for any purpose at any time. The table below explains who Skywell may share your personal data with, depending on your interactions with us or purchases you make.
Our service providers, business partners and affiliates
| Recipient Category |
Explanation |
Share Reason |
| Related parties and subsidiaries |
Companies owned or controlled by Skywell, or companies in which we have a substantial ownership interest |
To assist, operate, enhance and perform services on our behalf based on our legitimate interests in outsourcing certain operations |
| Service providers and business partners |
Companies we engage to provide services, such as customer support, product financing, repair assessment providers, infrastructure and other professional service providers |
To assist, operate and perform services on our behalf based on our legitimate interests in outsourcing certain operations |
| Payment service provider |
Companies we contract with to securely process your payment details |
To process payments under our contract with you, to prevent fraud and to safeguard our legitimate interests |
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Third parties authorized by you
|
Explanation |
Share Reason |
| Financial Institutions |
Companies that process lease and loan applications |
Confirm your eligibility and process your service requests based on your consent or our contract with you |
| Certified Installer |
Partners available for financing, licensing, inspections and installation |
To perform, assist and perform services on our or your behalf based on your consent or our contract with you |
| Third-party Service And Repair Centers |
Third-party service outlets we work with to provide you with quality repair services |
To provide services and repairs and to improve costs and services in accordance with our contract with you and our legitimate interests in improving costs and services |
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Other third parties or other situations required by law
| Recipient Category |
Explanation |
Share Reason |
| law enforcement and government |
Companies owned or controlled by Skyworth Automotive, or companies in which we have a substantial ownership interest |
Comply with applicable law based on our legal obligations or legitimate interests |
| Incentive or credit programs provided by the government |
Disclosure of information required by the plan such as vehicle frame number |
Based on our legitimate interests to comply with the terms of participation in the programs offered |
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When performing necessary services on our behalf or on your behalf, the personal data we collect may be shared between Skywell and our subsidiaries, affiliates (companies owned or controlled by Skywell, or companies in which we have a material ownership interest), third parties Shared among service providers, channel partners, suppliers and other parties. For example, we employ businesses to provide customer support or assist in protecting our systems and services, and these businesses may need access to personal data to complete the services described above. In such cases, the above-mentioned businesses must strictly comply with our privacy and data protection requirements and must not use the personal data received from us for any other purpose.
In addition, we may share information with the following parties:
•Third-party service providers and channel partners to provide services such as: website hosting, data analysis and storage, payment processing, order fulfillment and product installation, Skywell product wireless networking, information technology and related infrastructure, customer service, products Design, product diagnostics, maintenance or related services, email delivery, credit card processing, auditing, marketing, voice command processing and other similar services.
•Subsidiaries and affiliates in order to develop new products and improve existing products and services, perform data analysis and reporting. For example, if you request vehicle service/repair from a service center or body painting center operated by Skywell or a third party, we may share information about your vehicle, repair status and related personal data to optimize your vehicle experience, Accurately price repairs, and improve our business practices.
•Repair estimate providers and any insurance companies that enable Skywell or third-party service providers to perform services such as repairs or maintenance on your vehicle. When you ask Skywell to perform certain services, we share limited information about you and your vehicle with these parties to help provide you with accurate repair estimates and facilitate payment. Repair estimate providers can use this boiled down information to create and publish industry analysis data.
•Other third-party business partners, but only those involved in the purchase, rental or repair of your Skywell product. To allow you to take full advantage of the services you choose to use, we share limited information from or about you or your Skywell Products with partners, such as financial institutions, leasing, registration, title companies, power companies, licensing authorities and insurance companies.
Third parties authorized by you, such as:
•Share with third-party service centers or providers (if you choose such service providers). Please note that some information about you stored on certain Skywell products may be directly accessed by third-party service centers or providers you choose to diagnose, service, or repair your Skywell products.
•Third-party sponsors of similar promotions (if you choose to participate); shared with your social media account provider (if you link your Skywell account to your social media account). If you do so, you authorize us to share the relevant information with your social media account provider and you acknowledge that use of this information will be governed by the social media account provider's privacy policy.
To other third parties when required by law or under other circumstances, such as:
•To comply with legal obligations (such as subpoenas or other court orders); to respond to lawful requests from government agencies conducting investigations, including to comply with law enforcement requests and regulatory inquiries; to confirm or enforce our policies and procedures; to respond to emergencies; to prevent or prevent We may, in our sole discretion, consider to be or pose a risk of being illegal, unethical or legally actionable; or to protect the rights, property, safety or security of us and our products and services, third parties, visitors or the public.
•To your employer, other fleet operators, or the owner of a Skywell product if you do not directly own the product, as authorized by local law.
•In some jurisdictions, Skywell participates in government programs, either voluntarily or as required by law, such as incentive or credit programs related to environmental objectives, energy conservation or the introduction of new technologies. Skywell’s involvement helps us and local governments scale investment and supports the introduction of our technologies, including electric vehicles, electricity storage and charging. Participation in certain programs may require Skywell to share certain limited vehicle information and energy generation, charging or storage information, such as vehicle identification number or home address, with government or regulatory authorities as specified in the terms of those programs.
•When you accept a purchase incentive from a government or otherwise participate in a government incentive program, Skywell may be required to provide certain information about your purchase, participation and eligibility to the government or its designated regulatory agency in order to process the purchase incentive.
You can access and control the data we collect, use and share at any time, including through device permission management, mobile app settings options, contact preferences, your Skywell account and in-car data sharing controls. You have control over your data.
Skywell Updates: When you proactively request information, purchase products, or obtain Skywell event information, we may contact you by phone, text message, or Skywell application to inform you of information about events, products, and services that interest you. We will reply to you with relevant content and provide support for corresponding products and services. If you no longer wish to receive promotional emails or messages, you can follow the unsubscribe instructions in the messages you receive, modify your communication preferences, or contact us through any of the methods described in the Privacy Issues section. If you receive a call from us and do not wish to receive similar calls in the future, or if you do not wish to receive automated calls, simply let us know to put you on our "Do Not Call" list. Please note that even if you choose not to receive promotional messages, we may still need to send you administrative or other important messages, such as billing notices or policy changes.
Data Sharing: You have control over the data you share. If you choose to enable data sharing, your Skywell may collect data and provide it to us for analysis. This analysis helps us improve products and features faster, and diagnose problems. The information collected is generally not associated with your account or vehicle chassis number and does not identify you personally. Depending on your selections, analysis may include detailed information about your vehicle, configuration, performance, software version and short video clips or images. To protect your privacy, your personal data is either not recorded at all, is subject to privacy protection technology, or is removed from the report in which it is located before being sent to us.
Privacy Data Rights And Applications: According to local laws, you may have the right to know and decide how to process your personal data, request to inspect, copy and access the personal data we process about you, correct and supplement inaccuracies in the information, Restrict or delete that information, object to certain uses of the data or withdraw your consent (to stop the collection of your information), you may also have data portability rights in relation to the data you provide to us, and lodge a complaint with your local data protection authority . You may also have a right not to be subject to automated decision-making, including profiling, where this may have legal effects or similarly significant effects on you. We want you to have control over how we use your personal data. We provide you with a variety of ways to exercise these data rights, including:
•
Contact us by email, mailing address:
Wende Building, No. 1, Jinlong Lake Cultural and Creative Town, Longhu East Road, Jiawang District, Xuzhou City Jiangsu Kaiwo New Energy Vehicle Co., Ltd., Skywell (receiver)
•
Update personal information by accessing your Skywell account at any time
•
Call the Skywell customer service hotline:
400-696-8080
When you contact us, or when necessary to deal with your issue, we may ask you to provide more information, for example to verify your identity, or to tell you that we need more time to respond. If you are not satisfied with our response, you can always forward your complaint to the relevant supervisory authority in your jurisdiction. If you ask, we will endeavor to provide you with information about relevant complaints channels that may be applicable to your circumstances.
Protection of personal data
Taking into account the nature of the data and the threats posed, we use administrative, technical and physical safeguards to protect your personal data. We have implemented a variety of security features to continually protect your information. For example, your Skywell account contains owner resources, guides, and important documents, so we provide authentication to protect your account.
We will also implement other appropriate technical and organizational measures to help protect and secure your personal data. However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer safe or has been compromised, please notify us as soon as possible using the contact details below.
This Statement does not address, and we are not responsible for, the privacy, information or other practices of any third party, including any third party operating any website or service to which we may link in this Statement. The inclusion of such a link does not imply endorsement by us or our affiliates of the linked website or service, nor does it imply an affiliation with the third party. Additionally, we are not responsible for the collection, use or disclosure policies and practices (including data security practices) of other organizations. These organizations include any other application developers, application providers, social media platform providers, operating system providers or wireless service providers, including those to which you provide information, directly or indirectly through our software applications or social media pages. Any information disclosed by the organization. In addition, our products and services are not intended for people under the age of sixteen, and we ask such individuals not to provide any information to us.
Updates to this Statement
This statement sets out basic details about your relationship with Skywell for your personal data. From time to time, we may develop new functionality, features or offer other services, which may require us to make material changes to this Statement. When we do this, we will notify you by changing the date this statement was last updated on our website. From time to time, we may provide you with additional notifications (such as text messages) with more information about the revisions. Unless otherwise stated when we introduce these new or additional services, they will be subject to this Statement and will be effective when we post it on our website.
If you have questions or comments about privacy, or want to unsubscribe from certain services, or submit a privacy data request, please contact us.
Contact us by email, mailing address: Wende Building, No. 1, Jinlong Lake Cultural and Creative Town, Longhu East Road, Jiawang District, Xuzhou City Jiangsu Kaiwo New Energy Vehicle Co., Ltd.