Privacy policy

INTRODUCTION

At ARVALA Scooters, your privacy is important to us. SHANGHAI YIXING INTELLIGENT TECHNOLOGY CO.,LTD(“ARVALA”) is committed to providing visitors with websites that respect their privacy. This statement (the “Privacy Policy”) sets out our privacy practices with respect to the collection, use and disclosure of personal data on this website (the “Website”).

This Website may contain links that take you to websites of third parties. This Privacy Policy does not extend to the data collection practices of third parties and ARVALA does not assume any responsibility for the privacy practices, policies or actions of third parties. You should read the individual privacy policies and/or legal notices of such sites and make an informed decision as to whether or not you wish to use these sites based on their privacy practices.

Personal Data

Personal data means data or information about an identifiable person, recorded in any form. When you interact with us on our Website or place orders for products or services, you may be asked to provide and disclose, on a voluntary basis (therefore with your consent), your name, e-mail address, mailing address, telephone number, credit card information and other similar contact, personal and payment information, as the case may be. Visitors of this Website may provide and disclose personal data to us in using certain features of our Website, including our ordering and contact forms. The personal data ARVALA processes for providing such features is limited to information required to process customers’ and potential customers’ and visitors’ orders and other requests.

Processing and Purpose of Use

ARVALA processes your personal data in order to provide you with the requested products and services or enable you to use certain features of the Website. The services requested by you may contain marketing information. ARVALA will not sell or make commercially available any personal data that you provide through this Website without your permission. 

Disclosure of Personal Data

If you submit an inquiry or order through this Website, any personal data you might submit at that time will only be used by employees, representatives or agents of ARVALA, its affiliates or third parties who need to have access to it in order to respond to your inquiry or order, to provide the requested products and services, for proper administration (including any storage in the cloud) or for marketing purposes.

ARVALA will only share your personal data with third parties or affiliates, if those third parties or affiliates are established in a country which is recognized as providing an adequate data protection level or if such entity has signed a contract with ARVALA for processing personal data in compliance with applicable data protection laws.

ARVALA may disclose personal data to respond to legal requirements, enforce its corporate policies, respond to claims or protect anyone's vital interests. Disclosure will be in accordance with the applicable data protection laws.

Protection of Personal Data

ARVALA is committed to ensuring that your personal data is stored securely and only accessible by authorized persons. Your personal data will only be transferred to other parties in accordance with this Privacy Policy, following the implementation of appropriate technical and organizational measures in compliance with applicable data protection laws. Nonetheless there are third parties that may unlawfully try to access systems or intercept transmissions or communications containing personal data. ARVALA will deploy reasonable efforts to protect your personal data but cannot absolutely guarantee that such unlawful actions will not occur. Consequently, ARVALA bears no liability for the use that may be made of the information by any third party. ARVALA has in place an adequate data breach response plan.

Storage Duration

ARVALA seeks to only store your personal data for the duration necessary for providing you with the requested products and services or features of the Website and in a manner permitted by applicable laws.

Rights of Data Subjects 

You - as the individual whose personal data ARVALA processes - have the right to withdraw your consent to ARVALA’s processing of your personal data at any time, which results in the immediate termination of the processing without affecting the lawfulness of processing based on consent before your withdrawal and, if necessary, the deletion of all personal data. You have the right to request access to your personal data held by ARVALA, request (e.g. for transfer to another IT environment) for a copy of such personal data, and to request to update or correct it. You also have the right to object to the processing of your personal data by ARVALA, to request ARVALA to restrict its processing or to request to erase it. 

If you would like to exercise any of the above rights, please advise ARVALA by sending us an email at: shaoyiqun@arvalascooter.com  We will take reasonable steps to respond to your request in a timely fashion and in accordance with applicable data protection laws.

If you believe that the processing of your personal data by ARVALA is not compliant with applicable data protection laws or if ARVALA does not respond to your requests in a timely or adequate manner, you have the right to lodge a complaint with the competent authority for the protection of personal data, in accordance with applicable data protection laws.

Contact and Further Information

Contact details of ARVALA Head Office:

SHANGHAI YIXING INTELLIGENT TECHNOLOGY

If you have any comments, questions or complaints regarding ARVALA's Privacy Policy or practices, please contact us by sending an email to: shaoyiqun@arvalascooter.com

General Information

ARVALA reserves the right to change this Privacy Policy as it sees fit and without prior notice. However, we will ensure that any change to this Privacy Policy is in compliance with applicable data protection laws and posted on this Website. We encourage you to refer back to this Privacy Policy regularly.

Please note that, if applicable, both the English and French versions of ARVALA's Privacy Policy have equal legal value, but that in the event of conflict, the English version shall prevail.

Last revision: Feb 21, 2023.

APP USER SERVICE AGREEMENT

This is an agreement between you and SHANGHAI YIXING INTELLIGENT TECHNOLOGY CO.,LTD and its affiliates ("ARVALA"). Please read the User Agreement, and the other applicable rules, policies, and terms available at the arvalascooter.com website, or on or through the ARVALA Device or its companion app (collectively, this "Agreement") before using the ARVALA Device. By using the ARVALA Device, you agree to be bound by the terms of this Agreement. If you do not accept the terms of this Agreement, then you may not use the ARVALA Device. You may need your own ARVALA account to register and use your ARVALA Device, and you may be required to be logged in to the account. Your use of any of the Services is subject to any additional rules, policies and terms that apply to those Services.

The ARVALA Device Terms of Use are as follows:

"ARVALA Device" means devices provided by ARVALA, including but not limited to,ARVALA M10,ARVALA M11,ARVALA M13], and in each case, any ARVALA accessories or apps for these devices.

"Services" means our provision of Software, and support and other services that we provide ARVALA Device users, including but not limited to the function of “Moment” or “Device”.

"Software" means all software we make available to you for use on a ARVALA Device, but excludes third-party digital content.

1 . Features and Software

  1. New Rider Tutorial. Your ARVALA Device may be a transportation product or is a recreational product. Before mastering riding skills, you need to learn and practice. Neither we nor our affiliates is responsible for injuries or damage caused by a driver's inexperience or failure to follow the instructions in the Product Manual, User Manual or in the New Rider Tutorial. If you are using ARVALA Device for riding, you are solely responsible for driving safely, observing all traffic rules in your region, and using your own judgment while driving and selecting routes.
  2. Sharing Services. Your ARVALA Device may have features that allow you to share your experience with other users locally or worldwide via using “Moment” or other features. If you choose to upload your activities worldwide, it means that your information, including but not limited to post, pictures, comments will be transferred to local or global users.
  3. Discovery Services. Some apps of ARVALA Devices have features that allow you to discover other users or activities nearby. When you use these features, you may access online mall or community and find your riding rankings in your city.
  4. Use of the Software. Except as provided in this Agreement, you may use the Software only on a ARVALA Device. For additional terms that apply to the Software, see the terms contained in the Legal or similar section in companion apps of your ARVALA Device, or user manuals.
  1. Connectivity and Availability
  1. Internet and Wireless Connectivity. Your ARVALA Device may require an Internet connection or data plan from a third-party provider in order to use some features. In such cases, your Internet connection or data plan is subject to the fees, restrictions, terms and limitations imposed by your provider.
  2. Availability Some Services may be unavailable, vary (by device or geography, for example), be offered for a limited time, or require separate subscriptions. In addition, if your ARVALA Device requires wireless data services and is located in an area where it cannot access such services, you may not be able to use some or all of the Services or other features of your ARVALA Device. We are not responsible for the unavailability of wireless data services or any corresponding loss of Services.
  1. Intellectual property
  1. You may use this Software to publish your original works, opinions and views you are entitled to express, or release data, writing, information, signature, photos, personal information, links and other information contents. You shall guarantee that ownership and all intellectual property rights of information you uploaded are owned or legally authorized to you. Any using Software and Service behavior will NOT constitutes violation to us or any third party’s legal rights. In the condition that any infringement disagreement or complaint of copyright is raised by any third party based on any of the above-mentioned content that you uploaded, we are entitled to delete any above-mentioned data or content and is entitled to recourse your related legal responsibilities. Provided that ARVALA or third party losses in connection with your act (regardless intentional or negligent), you shall indemnify and assume legal responsibilities to the damaged parties.
  2. All original contents published by you (including but not limited to writings, pictures and videos), the intellectual property right is belonged to you. You can grant or authorize your original contents to any third party in any forms. It does not need our consent.
  3. When you use our Services or share, publish or upload any content protected by intellectual property rights in relation to our Services, it will be viewed as you grant us non-exclusive, free of copyright royalty, irrevocable, transferrable, sub-licensable and worldwide license. Under this License, we are granted to use such content in any product, Service and promotion in any forms, including but not limited to, website, released application or other internet products or social media software.
  1. General

a.Information Received.

The Software will provide us with information about use of your ARVALA Device and its interaction with the relevant Services. Information provided to ARVALA may be processed in the cloud to improve your experience and our products and services, and may be stored on servers outside the country in which you live. We will handle any information we receive in accordance with our privacy policy.

b.Amendments.

We may amend and update any of this Agreement's terms at our sole discretion by posting the revised terms on the arvalascooter.com website. Your continued use of the ARVALA Device after the effective date of the new Agreement constitutes your acceptance of the terms.

c.Termination.

When you fail to comply with Agreement or our policy, including rules of community, in posting or using in any way, any content or information, or under any requirements or permitted by Laws, we are entitled to delete such content or information. Under following circumstances, we are entitled to reject or terminate part or all Services we provide to you (including terminate or restrict your access to account) immediately:

(a) To protect our community or Services;

(b) You cause legal risks or violate laws, regulations or policy requirements;

(c) You violate this Agreement or our policy (including rules of community);

(d) You infringed intellectual property rights or other legal right of others;

(e) Required by Laws or other legal requirements.

d.Disputes/Binding Arbitration.

This Agreement shall be governed by and construed in accordance with the laws of Peoples’ Republic of China. Any dispute arising from or in connection with this Agreement shall be submitted to China International Economic and Trade Arbitration Commission in Beijing for arbitration which shall be conducted in accordance with the Commission’s arbitration rules in effect at the time of applying for arbitration. The arbitral award is final and binding upon both parties. You agree to those terms by entering into this Agreement or using a ARVALA Device or the Services.

e.Disclaimer of Warranties and Limitation of Liability.

THE INFORMATION AND MATERIALS REGARDING ARVALA ON OUR SOFTWARE, THE ARVALA OR SEGWAY INC. WEB SITE OR USER MANUALS MAY CONTAIN INACCURACIES AND TYPOGRAPHICAL ERRORS. WE DO NOT WARRANT THE ACCURACY, COMPLETENESS, OR USEFULNESS OF SUCH INFORMATION. WE RESERVE THE RIGHT, IN OUR SOLE DISCRETION, TO CORRECT ANY ERRORS OR OMISSIONS. WE MAY MAKE ANY OTHER CHANGES TO THE SITE, THE MATERIALS AND THE PRODUCTS, PROGRAMS, SERVICES OR PRICES (IF ANY) DESCRIBED IN THE SOFTWARE, SITE OR USER MANUALS AT ANY TIME WITHOUT NOTICE.

THE INFORMATION AND MATERIALS ON THIS SOFTWARE, SITE OR USER MANUALS ARE PROVIDED "AS IS" WITHOUT ANY REPRESENTATION OR WARRANTY, EXPRESS OR IMPLIED, OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, NONINFRINGEMENT, OR FITNESS FOR ANY PARTICULAR PURPOSE. SOME JURISDICTIONS DO NOT ALLOW FOR THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU

  1. Contact Information.

For help with your ARVALA Device, the Services, Software or resolving other issues, please contact us.

SHANGHAI YIXING INTELLIGENT TECHNOLOGYCO.,LTD

Email: shaoyiqun@arvalascooter.com

web: www.arvalascooter.com

APP PRIVACY POLICY

Update!

Our Privacy Policy was updated and entered into force on [ May 17, 2022 ]. We have revamped the Privacy Policy front and back so that from this date onwards, this Privacy Policy can provide privacy details on how we manage your Personal Information for our Product or Service provided by us.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

[Kindly Reminder]

  1. If you are a user of ARVALA device, please read carefully the relevant provisions on the protection of Personal Information of minors under the age of fourteen in the "Miscellaneous" section of this Privacy Policy.
  2. Access to this Privacy Policy: You can view this Privacy Policy by clicking "Mine -- Settings" in this ARVALA App.

This Privacy Policy will help you understand the following:

  • Our Commitment to You
  • What Information is Collected and How We Can Use It
  • When We Share Your Information
  • Security Safeguards
  • Retention Policy
  • Accessing Other Features on Your Device
  • You Have Control over Your Information!
  • Specific Issues to Users in the People’s Republic of China
  • Miscellaneous
  • Contact Us

OUR COMMITMENT TO YOU

"ARVALA" is an application developed by SHANGHAI YIXING INTELLIGENT TECHNOLOGY CO.,LTD to provide related Products and Services of ARVALA.

This Privacy Policy explains what information SHANGHAI YIXING INTELLIGENT TECHNOLOGY CO.,LTD and its affiliated companies ("ARVALA") collect and why we collect, and how you can update, manage, export, delete your information. Should we ask you to provide certain information by which you can be identified when using ARVALA Products or Services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Please refer to section of Products or Services for details.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our Personal Information collection and usage practices, as well as full confidence that ultimately, you have control of any Personal Information provided to ARVALA.

In this Privacy Policy, "Personal Information" means information that can be used to identify an individual, either from that information alone or from that information combined with other information ARVALA has access about that individual. Such Personal Information may include but not limit to the information you provide to us or upload, device information, etc. Please further read Types of Information we collect as you use our Services or Products.

By using ARVALA Products or Services, you are trusting us with your information. We are committed to comply with any locally applicable data protection laws, e.g. Personal Information Protection Law of the People's Republic of China. We are committed to protecting the privacy, confidentiality and security of your Personal Information by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact our Data Protection Officer.

Email : shaoyiqun@arvalascooter.com 

Telephone: 86+13825663768

Please make sure to provide your correct contact information so that we can response to you in time.

WHAT INFORMATION IS COLLECTED AND HOW WE CAN USE IT

TYPES OF INFORMATION COLLECTED

We collect information to provide better Products and Services to all our users.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

We may collect the following types of information (which may or may not be Personal Information):

Information you create or provide to us:

When you create a ARVALA account, you will provide us with your Personal Information that includes your username, passcode, email, nickname, your chosen image to represent yourself, channel you use for this account registration.

When you use our social Services, we will also collect the contents you create, upload, save or receive from others. This includes contents such as post you write and upload, photos and videos you upload, comments you make to other post or others make toward your post, the location you post and your UID.

Information we collect as you use our Products and Services:

Basic user information：basic information you need to provide to use our Products and Services. For example, username , and email address.

Device information: information related to your device. For example, hardware model, IMEI number, device/system/platform MAC address and SIM card IMSI information.

Vehicle information: information related to your vehicle. For example, vehicle type, vehicle brand, vehicle model, vehicle warning information, fault and so on.

Location information (only for specific Services/functionalities): we may collect your local information when you use ARVALA App. For example, for your driving safety, we may collect your vehicle location, phone GPS location, IP addresses, country code and city code.

Log information: information related to your use of our devices. For example, we may collect network request information, standard system logs, crash information and other anonymous identifier technologies. These information will be saved in local and won’t be sent to us unless you request. Please note, these information will only be used for solving problems and we won’t save to server.

Feedback information: after your authorization, we will collect your feedback information after sale of our Products. The feedback information will include issues user feedback such as photos, words, contact information, APP version, mobile type (IOS or Android), feedback time from us.

THE INVOCATION OF DEVICE PERMISSIONS

When you use "ARVALA", we may need to invoke some of your device permissions (see the table below, the specific permissions are subject to the software version you use). We will ask for your consent separately in the form of a popup before invoking the corresponding permissions for the first time. You can follow the specific guidelines of the mobile operating system to select to disable some or all permissions under device Settings or similar functions. If you cancel these permissions, we will no longer be able to collect and use your information, nor will we be able to provide you with the above-mentioned functions corresponding to these permissions.

Obtain Device Permissions Application Scenarios/Services Purpose Type of Collected Information Impact of Permission Rejection

Email Address

  • Activate devices
  • Register accounts
  • Login accounts

Activate and register accounts.

check CAPTCHA

login accounts

Email Address

  • Activation,registration may not be possible
  • CAPTCHA may not be checked

Location • Click "Location" to recommend surrounding user nearby • After clicking "Device", users can： (1) View map and track (Bluetooth connection is required) (2) Use the mobile phone to unlock the device by induction • View maps, tracks • Sensor unlock of the device •Post associated location Location • Unable to get users nearb surrounding • Unable to view maps, tracks • The device cannot be unlocked by induction

Bluetooth Connect the device to view maps and tracks via Bluetooth View maps and tracks Location & trajectory Unable to view maps and track

Access to photos, media content, and files on the device Post photos, audio and in “Moment” Upload photos, Photos Unable to post photos

Camera Post photos in “Moment” Take photos Photos Unable to post photos

Allows the App to write external storage Install the App on the external memory card Install the App on the external memory card / The App cannot write external storage

Phone status, , and mobile network information • Activate devices and register accounts • Use “Moment” • Activate and register • Post in “Moment” phone status, network information • Activation, registration may not be possible • May not be able to post

Allows the App to read from external storage Users need to read the external memory card Read external storage Photos, media content and files External stored photos may not be posted

Allows the App to display the system alarm window When the App displays the system alarm window Display the Alarm window / The system alarm window cannot be displayed

Allows the App to modify system settings data Modify the function of "ARVALA" App Modify system configuration data / The app cannot modify system Settings data

Allows the app to mount and unmount file systems with removable storage The file system of removable storage needs to be mounted and unmounted Mount and unmount a file system for removable storage / The App cannot mount and unmount the file system for removable storage

Allows the App to request packages to be installed "ARVALA" App update or patch Installing software packages / The App cannot request installation packages

Allows the App to obtain information about currently or recently running tasks When users receive a message notification in the "ARVALA" App Get current activity status of the App Current activity status of the App Unable to get the current activity status of the App, which affects the user's notification experience

Personal Information is collected for providing Services and/or Products to you, and legal compliance on our part under applicable laws.

We collect information to provide better Products and Services to all our users.

We may use your Personal Information for the following purposes:

Providing, processing, maintaining, improving and developing our goods and/or Services to you, including after-sales and customer support and for Services on your device or through our websites.

Communicating with you about your device, Service or any general queries, such as updates, customer inquiry support, information about our events, notices.

Analyzing and developing statistical information on use of our Products and Services to better improve our Products and Services.

Optimizing the performance of your device.

Storing and maintaining information about you for our business operations or legal obligations.

Providing local Services without communicating with our servers.

Here are more examples on how we use your information (which may include Personal Information):

Setting up your ARVALA Account. Personal Information collected when creating a ARVALA Account through our mobile devices is used for creating your personal ARVALA Account and profile page for the user.

Displaying vehicle Information. Your vehicle information will be showed when device connected via Bluetooth, you can check device information through our APP, like speed, mileage, battery information, firmware version, and taillight settings.

Providing location based Services. When using ARVALA app to connect the vehicle, your location access is required. You may turn this off at any time by going into the device settings or discontinue use of that application.

Providing after-sales Services. We use your log information if you request for after-sales Services. These information will be sent to the after-sales engineer by email. Please note, these information will only be used for solving problems and we won’t save to server.

USE OF COOKIE AND SIMILAR TECHNOLOGIES

Cookie and similar technologies are common and widely used technologies on the Internet. When you use our Services, we may use related technologies to send one or more Cookies or anonymous identifiers to your device to collect and store information about your access and use of this product. We use Cookie and similar technologies mainly to ensure the safe and efficient operation of Products and Services.

We may set Cookies or anonymous identifiers for authentication and security to confirm whether you log in safely, or whether you have encountered illegal acts such as being compromised or defrauded. These technologies will also help us improve the efficiency of our Services and increase the speed of login and response.

We promise that we will not use Cookies for any purpose other than those stated in this Privacy Policy.

WHEN WE SHARE YOUR INFORMATION

We do not share your Personal Information with companies, organizations, or individuals outside of ARVALA except in the following situations:

With your prior explicit consent:

Disclosure may be made to Third-party Service Providers and affiliated companies listed in this section in accordance with this Privacy Policy and applicable local data laws and regulations to provide the Products or Services that you have requested when we have your prior explicit consent.

In each case described in this section, you can be assured that privacy will only share your Personal Information in accordance with your consent. Your consent to ARVALA will engage sub-processors for the processing of your Personal Information. You should know that when ARVALA shares your Personal Information with a Third-party Service Provider under any circumstance described in this section, ARVALA will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws and this Privacy Policy. ARVALA will contractually ensure compliance by any Third-party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Your location Information. We will use Google map to collect your location information (to the extent of city) so as you can show your location information when “location” function.

Important Notice Send Out. We will send out important notice which is legally permitted by applicable to be delivered to your email address or App interface. Important notice will include recall information, mandatory repair and maintenance information.

Google Statistics Service. We will use Google statistics service to analyze unidentifiable information to anticipate the trend of Product and/or Service.

SHARING WITH OUR GROUP AND THIRD-PARTY SERVICE PROVIDERS

In order to conduct business operations smoothly in providing you with the full capabilities of our Products and Services, we may disclose your Personal Information from time to time to other ARVALA affiliated companies, or our Third-party Service Providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, and ARVALA’s representatives. Such Third-party Service Providers would be processing your Personal Information on ARVALA’s behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this information, please contact us. Please make sure to provide your correct contact information so that we can response to your request in time.

In order to provide you with a better Product and Service experience, our Product applications will embed SDKs of authorized partners or other similar applications. We will do our prudential obligation to conduct strict security monitoring on the software tool development kit (SDK) used by our partners to obtain information to protect data security. The third-party SDK we access mainly serves the needs of you and other users. Therefore, we may adjust the third-party SDK we access when meeting new Service requirements and business function changes. We will promptly publicly explain to you the latest status of accessing third-party SDKs.

At present, the third-party SDK that the company application of ARVALA accesses is listed as follows:

No. Name Function Type of Personal Information to be collected Privacy

1 Gaode Map SDK To achieve map display, used to achieve positioning Type of Personal Information to be collected Device identification information, geographic location information https://lbs.amap.com/pages/privacy

We also may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our Services, such as the number of customers in certain demographic groups who purchased certain Products or who carried out certain transactions.

For Legal Reasons:

ARVALA may disclose your Personal Information without further consent when required under applicable law. For example, when required by applicable laws, to protect your safety or the safety of others, or to assist local judicial agencies in investigating illegal and criminal activities, your Personal Information may be disclosed without your consent.

SECURITY SAFEGUARDS

ARVALA’S SECURITY MEASURES

We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect from your using of ARVALA Products and Services and on ARVALA websites. We will use all reasonable efforts to safeguard your Personal Information.

For example, when you access your ARVALA Account, you can choose to use our two-step verification process for better security. When you send or receive data from your ARVALA device to our servers, we make sure they are encrypted using Secure Sockets Layer (“SSL”) and other algorithms.

All your Personal Information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your Personal Information has the highest security level.

We use encryption to keep your data in confidential while in transit.

We have the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and Services;

We have the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

We regularly test assess and evaluate the effectiveness of technical and organizational measures for ensuring the security of the processing.

We restrict access your Personal Information to our employees and Third-party Service Providers who access the information to help provide you with our Products and Services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud-based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We will take all practicable steps to safeguard your Personal Information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any Personal Information which is transferred from you or to you via the Internet.

WHAT YOU CAN DO

You can play your part in safeguarding your Personal Information by not disclosing your login password or account information to anybody unless such person is duly authorized by you.

ARVALA cannot be held responsible for lapses in security caused by third party accesses to your Personal Information as a result of your failure to keep your Personal Information private. Notwithstanding the foregoing, if any other user on the Internet uses your account without authorization or any other security breach, you must notify us immediately.

Your assistance will help us protect the privacy of your Personal Information.

RETENTION POLICY

Except that the storage period of vehicle trajectory information is only six months, we will retain your information (including your Personal Information) until it is no longer necessary to provide our Product or Service to you or until your account is deleted or you choose to reset Product to the factory default settings-whichever comes first. Please note the following examples that we will delete your information. Deletion means a permanent irreversible erasure and you will not be able to recover your information later.

Example 1: All the Personal Information on the specific Product may be erased when you reset your device to factory default settings. You can do it via our application “factory default settings” option in settings. Beware that factory default settings can’t be undo, you should make sure that you don’t need the information any more.

Example 2: Upon you deregister or delete your ARVALA account, your information will be deleted immediately.

IF YOU NO LONGER WANT US TO USE YOUR PERSONAL INFORMATION TO PROVIDE YOU WITH OUR SERVICES, YOU CAN DELETE YOUR ACCOUNT THROUGH THE PATH OF "SETTINGS--DELETE ACCOUNT" OR SEND AN EMAIL TO US TO SUBMIT A DELETION REQUEST. PLEASE NOTE THAT YOUR APPLICATION TO DELETE PERSONAL INFORMATION MAY NOT BE RESTRICTED BY THE MINIMUM STORAGE PERIOD FOR THE TIME BEING UNDER THE FOLLOWING CIRCUMSTANCES:

IF YOUR ACCOUNT HAS UNREASONABLE ABNORMAL BEHAVIOR OR SUSPECTED FRAUDULENT BEHAVIOR, OUR ANTI-CHEATING SYSTEM MAY JUDGE YOUR ACCOUNT AS A SUSPECTED ACCOUNT. WE MAY KEEP YOUR NECESSARY PERSONAL INFORMATION TEMPORARILY UNTIL YOU MAKE A REASONABLE EXPLANATION FOR THE SUSPECTED VIOLATIONS TO PROTECT OUR LEGITIMATE BUSINESS INTERESTS.

ACCESSING OTHER FEATURES ON YOUR DEVICE

Our applications may need access to certain features on your device such as Wi-Fi network status. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us.

YOU HAVE CONTROL OVER YOUR INFORMATION!

CONTROLLING SETTINGS

ARVALA recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways ARVALA makes available for you to choose to restrict the collection, use, disclosure or processing of your Personal Information and control your privacy settings:

Toggle on/off for the Location Access functions;

Log in and out of the ARVALA Account;

Turn on or turn off other Services and functions that process sensitive or Personal Information;

Account deletion function: You can use this function through the path of "Settings-- Delete Account ".

If you have previously agreed to us using your Personal Information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at shaoyiqun@arvalascooter.com.

ACCESS, UPDATING, CORRECTING OR ERASURE YOUR PERSONAL INFORMATION

You have the right to request access to and/or correction of any other Personal Information that we hold about you. When you update your Personal Information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your Personal Information, we shall proceed to respond to your request within any timeframe (normally 15 working days) set out under your applicable data protection laws.

A copy of your personal data collected and processed by us will be provided to you free of charge upon your request. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please write to or email us.

You have the right to obtain from us the erasure of your Personal Information.

You have the right to obtain from us the restriction of processing your Personal Information.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You have the right to receive your Personal Information in a structured, commonly used format and transmit the information to another data controller.

DATA TRANSFER

Kindly note that data protection laws vary from different countries, with some provide more protection than other countries. Regardless of where your information is processed or transferred, we apply the same protection measures in accordance with this Privacy Policy. We also comply with certain legal regulations such as GDPR with regard to data transfer.

IF YOU CHOOSE TO UPLOAD YOUR ACTIVITIES WORLDWIDE, IT MEANS THAT YOUR INFORMATION INCLUDING USERNAME, POST, PICTURES, VIDEOS, COMMENTS AND THE LOCATION YOU POST WILL BE TRANSFERRED CROSS BORDER OR YOUR CURRENT HOME JURISDICTION (I.E. YOUR LOCAL SERVER). LIKEWISE, IF YOU CHOOSE TO COMMENT A WORLDWIDE POST, VIDEO, YOUR COMMENT WILL BE SEEN AND COMMENTED WORLDWIDE.

We also would like to state the technical measures to safeguard the international data transfer:

We use encryption to keep your data in confidential while in transit. We have the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and Services;

We have the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

We regularly test assess and evaluate the effectiveness of technical and organizational measures for ensuring the security of the processing.

Below are the practical self- check measures we strongly recommend your attention and regularly review:

Security and hacked accounts

1.Help with my compromised account

2.Help with my hacked account

Help with my compromised account

If your account has been compromised but you're still able to log in, this page will help you secure your account and stop unwanted behaviors. If you can't log in to your account, please contact us.

Has my account been compromised?

Have you:

Seen unintended Direct Messages sent from your account Received a notification from us stating that your account may be compromised Received a notification from us stating that your account information has changed, and you didn't change it Noticed your password is no longer working and you are being prompted to reset it

If you've answered yes to any of the above, please take the following steps:

  1. Change your password

Please change your password immediately from the Password tab in settings or click on request a password reset. Please select a strong password you haven't used before. If you can't log in, your account may have been hacked.

  1. Make sure your email address is secure

Make sure that the email address attached to your account is secure and that you are the only one with access to it. You can change your email address from your app and visiting the Account settings tab.

Your account should now be secure, and you shouldn't see the unexpected account behaviors moving forward. If you're still experiencing issues, please file a support request for assistance.

Protect your account with simple precautions

If your account has been compromised, take these additional precautions:

Scan your computers for viruses and malware, especially if unauthorized account behaviors continue to be posted after you've changed the password. Install security patches for your operating system and applications. Always use a strong, new password you don't use elsewhere and would be difficult to guess.

Consider using login verification. Instead of relying on just a password, login verification introduces a second check to make sure that you and only you can access your account.

How do accounts become compromised? (Did somebody hack me?)

Accounts may become compromised if you've entrusted your username and password to a malicious third-party application or website, if your account is vulnerable due to a weak password, if viruses or malware on your computer are collecting passwords, or if you're on a compromised network.

Unexpected updates don't always mean that your account was hacked. Occasionally, a third-party application can have a bug that causes unexpected behavior. If you see strange behavior, changing your password and/or revoking connections will stop it, as the application will no longer have access to your account.

Help with my hacked account

If you think you've been hacked and you're unable to log in with your username and password, please take the following two steps:

  1. Request a password reset

Reset your password by requesting an email from the password reset form. Try entering both your username and email address, and be sure to check for the reset email at the address associated with your account. If you're able to log in after the password reset, please check if your account has been compromised and re-secure your account.

  1. Contact Support if you still require assistance

If you still can't log in, contact us.

EVEN WE TRY OUT BEST TO SECURE SAFETY TRANSFER OF YOUR DATA, WE WOULD LIKE TO STATE THE RISKS OF DATA LEAKAGE RISKS AS BELOW:

As we practice best way to keep your information safe, if you think your information has been compromised, below the worst scenario you may expect:

Received spam mails/messages from unknown source.

May receive phishing or other attempted scams emails.

Photos you shared been publish to other public sharing sites.

SPECIFIC ISSUES TO USERS IN THE PEOPLE’S REPUBLIC OF CHINA

If you use ARVALA Products and Services within the territory of the People’s Republic of China, in accordance with the "Personal Information Protection Law of the People’s Republic of China" (hereinafter referred to as the "PIPL"), ARVALA will act as a controller or processor of Personal Information and take the following additional responsibilities:

PRINCIPLES OF HANDLING PERSONAL INFORMATION

The processing of Personal Information always follows the principles of lawfulness, fairness, necessity and good faith, and will not process Personal Information through misleading, fraud, coercion or otherwise.

The processing of Personal Information always has a definite and reasonable purpose, and is directly related to the purpose of processing, and conducts in a way that minimizes the impact on personal rights and interests.

The processing of Personal Information always follows the principles of openness and transparency, and discloses the rules for processing Personal Information, and clearly indicates the purpose, method and scope of such processing.

The quality of personal information shall be ensured in the processing of personal information to avoid the adverse impact on personal rights and interests caused by inaccurate or incomplete personal information.

COLLECTION, STORAGE, USE, PROCESSING, TRANSMISSION, PROVISION, DISCLOSURE, AND DELETION OF PERSONAL INFORMATION

If you use ARVALA Products and Services within the geographic area of the People's Republic of China, ARVALA will collect and process your Personal Information in accordance with the PIPL. Personal Information under the PIPL is a variety of information related to an identified or identifiable natural person that is recorded electronically or by other means, and does not include anonymized information. The processing of Personal Information includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of Personal Information.

In principle, ARVALA will not collect sensitive Personal Information as required by the PIPL. Sensitive Personal Information is Personal Information that, once leaked or illegally used, can easily lead to the infringement of the personal dignity of natural persons or the harm of personal and property safety, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts and other information. And the Personal Information of minors under the age of fourteen. Only when it is really necessary to use our Products and Services (such as providing location-based Services. When using ARVALA app to connect the vehicle, your location access is required. You can Turn off this setting at any time by entering the device settings or stopping the use of the application), and with your express consent, we will collect and use your sensitive Personal Information in accordance with the security measures described in the "Security Safeguards" section of this Privacy Policy to ensure the security of your personal sensitive information.

ARVALA will store Personal Information collected from China within China.

ARVALA will not provide Personal Information to overseas, unless it is necessary for business and other reasons to provide Personal Information outside the People’s Republic of China, and it meets the conditions stipulated in Article 38 and Article 39 of the PIPL. If ARVALA provides Personal Information outside the People’s Republic of China, it will inform individuals of the name of the overseas recipient, contact information, processing purpose, processing method, types of Personal Information as well as the methods and procedures for individuals to exercise the rights stipulated in the PIPL to the overseas recipient, and obtain individual consent from individuals.

ARVALA will meet the requirements of being a Personal Information controller or processor in accordance with Chapter 5 of the PIPL.

PROTECTION OF THE RIGHTS OF PERSONAL INFORMATION SUBJECTS

ARVALA will ensure and promote Personal Information subjects to exercise their rights in accordance with Chapter 4 of the PIPL

Right to access and copy Personal Information

Right to portability of Personal Information

Right to correct Personal Information

Right to delete Personal Information

Right to withdraw consent (rights to stop processing and refuse automated decision-making)

Right of explanation

Personal Information processing rights of the deceased

WE HAVE INTRODUCED SOME OF YOUR ABOVE-MENTIONED RIGHTS IN THE "YOU HAVE CONTROL OVER YOUR INFORMATION!" SECTION (SUCH AS: CONTROLLING SETTINGS, ACCESS, UPDATING, CORRECTING OR ERASURE YOUR PERSONAL INFORMATION, WITHDRAWAL OF CONSENT), IF YOU WISH TO EXERCISE OTHER RIGHTS OR HAVE ANYTHING TO US FOR SUGGESTIONS OR QUESTIONS, YOU CAN ALSO CONTACT US OR "CONTACT US" AT THE END OF THIS PRIVACY POLICY. After receiving your valid request, we will respond within 15 working days and notify you of the actions we have taken. If we are unable to respond to your request, we will make explanation. You also have the right to lodge a complaint with the Personal Information protection department of the People's Republic of China about our collection and use of your Personal Information.

MISCELLANEOUS MINORS

We consider it the responsibility of parents to monitor their children’s use of our Products and Services. Nevertheless, it is our policy not to require Personal Information from minors under the age of fourteen or offer to send any promotional materials to persons in that category.

ARVALA does not seek or intend to seek to receive any Personal Information from minors under the age of fourteen. Should a parent or guardian have reasons to believe that a minor under the age of fourteen has provided ARVALA with Personal Information without their prior consent, please contact us to ensure that the Personal Information is removed and the minor under the age of fourteen unsubscribes from any of the applicable ARVALA Services.

[ONLY FOR NANO/L6/L8 USERS] OUR NANO/L6/L8 CAN BE USED BY MINORS UNDER THE AGE OF FOURTEEN. DURING YOUR USE OF THIS PRODUCT, WE MAY COLLECT PERSONAL INFORMATION OF MINORS UNDER THE AGE OF FOURTEEN. WE WILL COLLECT AND PROCESS THIS KIND OF PERSONAL INFORMATION IN ACCORDANCE WITH OUR RULES FOR THE PROCESSING OF MINORS' PERSONAL INFORMATION.

IF YOU PURCHASE THIS PRODUCT AND DELIVER IT TO A MINOR USER UNDER THE AGE OF FOURTEEN, PLEASE URGE THE MINOR’S PARENTS OR OTHER GUARDIANS TO AGREE TO THE RELEVANT PROVISIONS OF THIS PRIVACY POLICY AND CREATE A ARVALA ACCOUNT.

IF YOU ARE A MINOR UNDER THE AGE OF FOURTEEN, YOU NEED TO ASK YOUR PARENTS OR OTHER GUARDIANS TO AGREE TO THE RELEVANT PROVISIONS OF THIS PRIVACY POLICY BEFORE YOU CAN CREATE A ARVALA ACCOUNT.

WHEN YOU USE THE APPLICATION ONLY FOR NANO/L6/L8 PRODUCT ACTIVATION, WE WILL ONLY COLLECT YOUR . WHEN YOU CREATE YOUR ARVALA ACCOUNT, YOU NEED TO AGREE TO THE RELEVANT PROVISIONS OF THIS PRIVACY POLICY. IF YOU FAIL TO CREATE A ARVALA ACCOUNT, IT WILL NOT AFFECT YOUR USE OF NANO/L6/L8.

ORDER OF PRECEDENCE

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

UPDATES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the ARVALA websites or through our software, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of Products and Services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more Personal Information from you or when we wish to use or disclose your Personal Information for new purposes.

DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products and services offered by a third party. ARVALA Products and Services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use Personal Information which they collect from you. Our Privacy Policy does not apply to other sites linked from our Services.

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to ARVALA’s collection, use or disclosure of your Personal Information, please contact us at the address below referencing "Privacy Policy":

SHANGHAI YIXING INTELLIGENT TECHNOLOGY CO.,LTD 

Email: shaoyiqun@arvalascooter.com

web: www.arvalascooter.com

Thank you for taking the time to understand our Privacy Policy!