Last modified: 20 May, 2025
Zhejiang Dahua
Technology Co., Ltd ("we" or "us" or "our" or "Dahua")
respects your privacy and is committed to protecting it through our compliance
with this Privacy Policy (the "Policy"). This Policy applies only to
[D-Volt] (the "Platform"). We may process your personal information
when you use the Platform and/or product or service in relation to the
Platform.
This Policy
applies only to personal information we collect when you use the Platform. This
Policy does not apply to products or services provided by third party companies
or individuals (hereinafter referred to as "Third Party Services").
Please be noted that your personal information may be processed by third
parties without our control. You shall consider carefully and decide whether to
use Third Party Services and we will not be liable for the Third Party Services
in any event.
Please read this
Policy carefully to understand our policies and practices regarding your
personal information and how we will treat it.
We may modify this
Policy from time to time (see "Changes to Policy" below). If you have
any issues regarding this Policy, please contact us at supportoverseas@dahuatech.com.
1.
Definitions
2.
How We Collect Your Personal Information and Purpose of Processing
3.
How We Share, Assign and Disclose Your Personal Information
4.
How We Protect and Store of Your Personal Information
5.
How We Protect Children's Personal Information
6.
International Transfers
7.
Your Rights
8.
SDK and Similar Technologies
9.
Changes to Policy
10.
How to Contact Us
1)
Account: the account you register and login to the Platform.
2)
Personal
Information: shall have the same meaning as "personal data" and
shall include any information relating to an identified or identifiable natural
person ("data subject"); an identifiable person is one who can be identified,
directly or indirectly, in particular by reference to an identification number
or to one or more factors specific to his/her physical, physiological, mental,
economic, cultural or social identity. Examples of personal
information include your name, telephone number, email address, ID number, and physical
address.
3)
Personal
Sensitive Information: it refers to
personal data revealing racial or ethnic origin, political opinions, religious
or philosophical beliefs, or trade union membership, and genetic data,
biometric data for the purpose of uniquely identifying a natural person, data
concerning health or data concerning a natural person’s sex life or sexual
orientation, etc., depending on the definition provided by applicable laws.
4)
Enterprise: it refers to any enterprise who purchase or use the
Product.
5)
Platform: it refers to the D-Volt website or D-Volt APP which
providing the function of real-time charge point monitoring, group and
individual invitation for sharing the use of Product, Product information management,
which enable you to manage the information stored on the Platform or the
Product.
6)
Product: it refers to the charging pile product which is used for home and commercial purposes. Such as home charge points, CPO charge
points, etc.
2.
How We Collect Your Personal Information and Purpose of Processing
We
collect several types of information from and about users of our Products
and/or Services. We may also automatically collect certain information as you
navigate through the platform, such as usage details, location information, equipment profiles,
charging orders, etc. We will also request Bluetooth permission when you use
the Platform, so that we can provide normal functionality for network
configuration, charging control, and other services for related devices.
We have set
out below, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate. We try to ensure that we only
collect and hold personal data that we need for the services and products we
are offering to you. Therefore, unless otherwise indicated in the below, the
provision of personal data is a requirement for us to enter into a contract
with you or fulfill our contractual obligations. In case that you choose not to
provide certain information, you might not be able to take advantage of our
services in full or partially.
1)
Registration
of the Platform
In
order to access and use certain functions of our services on the Platform, you
may be required to create an account ("Account") and you can use the Account information
to login the Platform and obtain our services. Certain services may only be
used after our evaluation of your qualification. The Account information on the
Platform may include your name, email address, country or region you choose,
telephone number and password (encrypted).
You
represent and warrant that: (i) all required Account information you submit is
truthful, accurate and complete. (ii) you will maintain the accuracy, security,
and confidentiality of Account information; and (iii) your use of the Account
does not violate any applicable law or regulation. You also acknowledge that
your account is personal to you and agree not to provide any other person with
access to these services or portions of them using your Account information.
You agree to notify us immediately of any unauthorized access to or use of your
Account information or any other breach of security by contacting us at supportoverseas@dahuatech.com. You also agree to ensure that you exit from your account at the end
of each session. You should use particular caution when accessing your account
from a public or shared computer so that others are not able to view or record
your Account information.
2)
Product
Connection Function
When
you use the product connection function, we may process the product serial
number (SN), product username, product password, and charging process data in
order to provide you with basic services for charging point device
monitoring and charging through the platform.
3)
Product
Accident Alert
For
purpose of using the product accident alert function to recognize the problems
of the products, we may collect your Personal Information to send you messages
about the accident details. The information may include your name, the name of
charge point and site, the name of group, telephone number and email address.
We will only process your Personal Information when it is necessary.
4)
Product
Management
For
purpose of managing the product to use relevant functions and our services,
such as Product maintenance service, Product information management service,
etc. we may process your request to add Product to your account and allow
configuration of your Product, hence we may collect the information of the
Product you purchased, including product name, product username, product
password, product serial number, product model. Such information may be
recognized as your Personal Information. We will only collect your Personal
Information when it is necessary. Refusing to provide such information may only result
in your being unable to use this function, but does not affect your normal use
of the Platform’s other functions.
5)
Mobile
device permission usage
When
you use the above-mentioned services, certain permissions may be required. We
will inform you through pop-up windows and obtain your consent. If you do not
agree to grant the necessary permissions or provide your personal information,
you will only be unable to use the corresponding services. However, it will not
affect your normal use of other services or functions. These services include:
(1)
Additional services based on the camera/camcorder/local album: After granting
camera/camcorder/local album permissions, you can use this feature to scan QR
codes for charging and other services.
(2)
Additional services based on location: After granting location permission, you
can use this feature to receive recommendations for nearby device-related
services and AP network setup for certain devices.
(3) Additional
services based on sensors: When scanning QR codes/barcodes, you can use this
feature to turn on the flashlight and enhance the lighting in low light
environments, for clearer scanning of device QR codes/barcodes.
You can check
the status of these permissions one by one in the settings of your mobile
device and decide to enable or disable these permissions at any time. Please
note that these permissions are not enabled by default. They will only be used
when you explicitly grant authorization to achieve specific functions or
services. You can also revoke the authorization. It is worth noting that even
with your authorization and access to these sensitive permissions, we will not
collect your information when the relevant functions or services do not require
it. Please be aware that by enabling these permissions, you are authorizing us
to collect and use this information to provide the aforementioned services. If
you revoke these authorizations, we will no longer collect and use this
information and will be unable to provide the corresponding functions
associated with these authorizations. However, your decision to disable
permissions will not affect the processing of personal information based on
your prior authorization.
To
ensure the security of the service and help us better understand the operation
of our application, we may record relevant information such as the frequency of
your use of our products and/or services, crash data, overall usage,
performance data, etc. We will not combine the information stored in the
analytics software with any personally identifiable information you provide in
the application.
If
we need to collect and use your personal information to improve service
quality, enhance user experience, or develop new products, we will obtain your
explicit consent in a clear manner (e.g., through a consent dialog). If you do
not agree to the collection, you can click "Refuse" or "Disagree,"
and we will not collect any information beyond the scope defined in this
policy. Your "Refuse" or "Disagree" will not affect your
use of the services under this policy or other relevant policies.
6)
Processing
Permitted by Laws
We
will obtain your explicit consent before processing your Personal Information unless
there is any applicable law permits the processing without your consent:
(1)
processing is necessary for the performance
of a contract or in order to take steps at your request prior to entering into
a contract;
(2)
processing is necessary for compliance with
a legal obligation;
(3)
processing is necessary in order to protect
the vital interests of data subject or of another natural person;
(4)
processing is necessary for the performance
of a task carried out in the public interest or in the exercise of official
authority vested;
(5)
processing is necessary for the purposes of
the legitimate interests pursued by we or by a third party, except where such
interests are overridden by the interests or fundamental rights and freedoms of
data subject which require protection of personal data, in particular where the
data subject is a child.
(6) Other
lawfulness of processing as specified in applicable laws.
3.
How We Share, Assign and Disclose Your Personal Information
1)
Personal
Information Sharing
We
may share your Personal Information with other companies, organizations and
individuals in the following situations:
(1)
Sharing upon explicit consent: we may share
your Personal Information with other third parties after obtaining the explicit
consent of you or other data subject corresponding to or associated with the Personal
Information you collect, provide and upload.
(2)
Sharing based on mandatory legal
requirements: we may share your Personal Information externally according to
laws and regulations or the mandatory requirements of government authorities.
(3)
Sharing with affiliated companies or other
group companies: we may share your Personal Information with our affiliated
companies. We should only share your necessary Personal Information and be
bound by the stated purpose of the Personal Information it collects. If our group
companies intend to change the purpose of processing Personal Information, they
shall obtain the explicit authorization and consent of you or other involved
data subject.
(4)
Sharing with our business partners, or
other trusted third-party vendors, such as providing, evaluating, improving, or
upgrading services; participating in market research activities related to our
services, developing new services, providing customer support, etc. To improve
the services, we may also analyze product usage, but these statistics will not
include any of your identifiable personal information
(5)
As regards the Personal Information
collected during your use of the Platform, we use the services of cloud service
providers, including: Amazon Web Services, Alibaba Cloud Computing Services.
Apart from that, we ensure you that we will not share such data unless you have
explicitly requested such sharing.
2)
Assignment
of Personal Information
We
may assign your personal Information to other companies, organizations and
individuals in the following circumstances:
(1) Assigning upon
your explicit consent;
(2) When there is a
merger, acquisition or bankruptcy liquidation, if assigning of your Personal Information
is necessary, we should require the successor who holds your Personal Information
to continue to perform the obligations herein. Otherwise, we shall require the successor
to obtain authorization and consent from you or other data subject separately.
3)
Disclosure
of Personal Information
Pursuant
to relevant laws and regulations, we may disclose your Personal Information
without obtaining prior consent in the following situations:
(1)
disclosure based on law: to comply with any
court order, law or legal process, including to respond to any government or
regulatory authority’s request or for investigations (e.g. disclosure to
prevent crime or fraud, or to comply with a court order or legislation);
(2)
to deal with public health emergencies, or,
in case of emergency, to protect the health of natural persons and the safety
of their property;
(3)
personal Information is publicly disclosed
by you or other personal data that is already legally and publicly disclosed
within a reasonable scope in accordance with the laws;
(4)
other situations in which data processing
is required by the applicable laws and regulations.
4.
How We Protect and Store of Your Personal Information
1)
Data
Security Measures
(1)
We shall take all appropriate physical,
electronic and management security measures to prevent your Personal
Information from accidental losses and from unauthorized access, use,
alteration and disclosure. For instance, we shall use encryption technology to
improve the security of Personal Information and trusted protection mechanisms
to prevent Personal Information from being maliciously attacked.
(2)
We highly recommends you to use
comprehensive and complex password in protecting the security of your account. We
shall ensure the security and confidentiality of Personal Information you
provide.
(3)
In the case of a personal information
leakage and other personal information security incidents, we shall without
undue delay and, where feasible, after having become aware of it, notify the
personal data breach to you and/or the supervisory authority competent in
accordance with the applicable laws and regulations via email, phone, push
notification, announcement or any other feasible methods in a reasonable and
effective way. We shall inform you including the basic situation and possible
impact, the disposal measures that we has taken or will take and
recommendations for risk mitigation, etc.
2)
The
Retention of Personal Information
(1)
Storage location
Your
Personal Information may be stored on the Platform.
(2)
Retention period
We
will retain your Personal Information for no longer than it is necessary for
the purposes stated in this Policy, unless otherwise extending the retention
period is required or permitted by law. To determine the appropriate retention
period for Personal Information, we may consider the amount, nature and
sensitivity of the Personal Information, the potential risk from unauthorized
use or disclosure of your Personal Information, the purposes for which we
process your Personal Information and whether we can achieve those purposes
through other means, and the applicable legal requirements.
In
the event where we cease our Products or part or all of our services, we will
notify you and delete your personal data in concern or anonymize such
information within a reasonable period of time.
5.
How We Protect Children's Personal Information
As for the Platform,
we will not collect, store, process the Personal Information of children under
16 years of age, or equivalent minimum age in the relevant jurisdiction (refer
to "Child" or "Children" below).
If we
acknowledge that the Platform has collected or received Personal Information
from a Child, without verification of Consent of Guardian, we will delete that
Personal Information.
6.
International Transfers
Since we
have established affiliates in different regions around the world and we may
offer our services through the use of servers located in different countries.
As such, your Personal Information might be transferred outside the region and
country you use our products or services, including to regions/countries
outside the European Economic Area ("EEA") which might have different legal
rules and might not offer an adequate level of protection as determined by the
European Commission. However, we have taken the necessary measures to ensure
that your Personal Information is processed in conformity with the applicable
laws and appropriate technical security measures are adopted to safeguard your
privacy. Your Personal Information may be stored or processed in multiple
countries, including Germany, Singapore and United States. For the purposes
described in this Policy, your information may be transferred to these
territories in accordance with applicable law.
7.
Your Rights
Your legal rights
to your Personal Information are set out below:
·
Request access to your Personal Information (commonly known as a
"data subject access request"). This enables you to receive a copy of
the Personal Information we hold about you and to check that we are lawfully
processing it.
·
Request correction of the Personal Information that we hold
about you. This enables you to have any incomplete or inaccurate data we hold
about you corrected, although we may need to verify the accuracy of the new
data you provide to us.
·
Request erasure of your Personal Information. This enables you to delete
or remove your Personal Information via the channel【Me- My Account- Delete Account】. Please be noted that if you have set password to
your account, you have to verify your account by entering the correct password
before Delete Confirmation. You also have the right to request us to delete or
remove your Personal Information where you have successfully exercised your
right to object to processing (see below), where we may have processed your
information unlawfully, or where we is required to erase your Personal
Information to comply with local law. Note, however, that we may not always be
able to comply with your request of erasure for specific legal reasons, which
will be notified to you, if applicable, at the time of your request.
·
Object to processing of your Personal Information where we are relying
on our legitimate interest (or that of a third party), and there is something
about your particular situation that makes you want to object to processing on
this ground as you believe it affects your fundamental rights and freedoms. You
also have the right to object where we are processing your Personal Information
for direct marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information that override your
rights and freedoms.
·
Request restriction of processing of your Personal Information. This enables you to ask us to
suspend the processing of your Personal Information in the following scenarios:
(a) if you want us to establish the data's accuracy; (b) where our use of the
data is unlawful, but you do not want us to erase it; (c) where you need us to
hold the data even if we no longer require it as you need it to establish,
exercise, or defend legal claims; or (d) you have objected to our use of your
data, but we need to verify whether we have overriding legitimate grounds to
use it.
·
Request the transfer of your Personal Information to you or to
a third party. We will provide to you, or a third party you have chosen, your Personal
Information in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information which you initially provided
consent for us to use or where we used the information to perform a contract
with you.
·
Withdraw consent at any time where we are relying on consent to process
your Personal Information. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your consent.
For security
reasons, we will take steps to authenticate your identity before providing
access to your Personal Information. You also have the right to lodge a
complaint with the relevant Data Protection Authority.
8.
SDK and Similar Technologies
To provide you
with a better, faster and safer user experience and ensure the stable
operation, the Product may be embedded in third party’s SDK. SDKs are a
collection of software development tools in one installable package, which
allow third party developers to integrate with the Product for specific
purposes (e.g., location). Third party SDKs may collect your Personal
Information for provision of specific service.
We will
evaluate the legality, legitimacy and necessity of the information collected by
such third party, and requires third party to take protective measures for your
Personal Information strictly abide by relevant laws and regulations. We will
timely explain to you the latest situation of the third-party SDK that collects
your personal information on this page:
|
1) Google Maps SDK |
|
|
Host: |
Google
Map SDK |
|
Purpose: |
The Google Maps SDK is used for integrating features
such as map display, location tracking, navigation, and place search. |
|
Permissions
involved: |
ACCESS_NETWORK_STATE, READ_EXTERNAL_STORAGE,
WRITE_EXTERNAL_STORAGE,READ_SETTINGS, ACCESS_FINE_LOCATION,
ACCESS_COARSE_LOCATION |
|
Personal
Information Collected |
(1) Information related to Mobile device: Android
ID, operating system version, brand and model number of mobile device,
configuration, APP information (APP name), network operator; (2) Information related to network: Wi-Fi connection
information (incl. Wi-Fi status, parameters and list), connection status
(e.g. mobile network, Wi-Fi network or no network); (3) Location related information: Wi-Fi address and
signal intensity, base station ID data information, sensor information,
signal intensity of mobile device and IP address. |
|
SDK
Privacy Policy |
https://policies.google.com/privacy?hl=en-US |
|
2) Push Notification SDK |
|
|
Host: |
Firebase
Cloud Messaging ("FCM") |
|
Purpose: |
The Push Notification SDK is used to enable the
functionality of sending push notifications to users' devices. This SDK
allows us to effectively communicate with users by sending timely updates,
alerts, and personalized messages directly to users’ devices. |
|
Permissions
involved: |
READ_SETTINGS ACCESS_NETWORK_STATE |
|
Personal
Information Collected |
(1) Information related to Mobile device: Android
ID, operating system version, brand and model number of mobile device,
configuration, APP information (APP name); (2) Information related to network: Wi-Fi connection
information (incl. Wi-Fi status, parameters and list), connection status
(e.g. mobile network, Wi-Fi network or no network); |
|
SDK
Privacy Policy |
https://policies.google.com/privacy?hl=en-US |
9.
Changes to Policy
We reserve the
right to modify this Policy from time to time at our sole discretion. If we made
material modifications to the Policy, we will notify you sending you an alert
the first time you use the Platform after making the changes. The date this
Policy was last modified is identified at the top of the page. All changes are
effective immediately when we post them and apply to all access to and use of
the Platform thereafter; provided, to the extent required by law, we will seek
your affirmative consent prior to applying material modifications to this
Policy on how we use or disclose Personal Information that we collected or
received prior to the date of the modification. You are expected to check this
Policy frequently, so you are aware of any modifications, as they are binding
on you once you providing affirmative consent.
10. How to Contact Us
To ask questions or
comment about this Policy and our privacy practices, contact us at supportoverseas@dahuatech.com, via email or by mail
at:
Zhejiang Dahua
Technology Co., Ltd
A10, Bin’An Road 1199,
Binjiang District
Hangzhou, Zhejiang
Province, P.R. China, 310053
C/O: Data Protection
Officer