Overseas Version

Privacy Policy

Effective Date: March 10, 2026

Last Updated: March 10, 2026

This Privacy Policy explains how SEELOP EV Tech Limited (“UMCHR”, “we”, “us”, “our”) collects, uses, stores, protects, shares, and transfers your personal data when you use our electric vehicle charging platform, mobile application, websites, and related services (the “Services”).

This policy applies to users outside mainland China and complies with the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and other applicable global data protection laws.

1. Controller Information

Data Controller: SEELOP EV Tech Limited

Address: RM18, 27/F HO KING OOMM CTR2-16 FAYUEN ST MONG KOK HONG KONG

Contact for privacy requests: UMCHR@UMCHR.com

Support Hotline: +85255819819

2. Personal Data We Collect

We collect only necessary, relevant, and limited personal data:

2.1 Account & Registration Data

• Phone number, username, password

• Third‑party login identifiers (OpenID, nickname, avatar)

• Contact information

2.2 Identity & Verification Data

• Full name, government ID number (where required)

• Biometric facial data (only for verification with explicit consent)

• Payment and bank account information (for e‑wallet and billing)

2.3 Location Data

• GPS location, IP address, Wi-Fi/cell tower data

• Collected only with your explicit consent

2.4 Vehicle & Charging Data

• License plate number, VIN

• Vehicle and battery parameters

• Charging records, station usage, order history

2.5 Device & Log Data

• Device model, IMEI, MAC, IDFA, OAID

• Operating system, network status

• Usage logs, crash logs, access timestamps

2.6 Customer Support Data

• Support tickets, chat records, call recordings

• Information you voluntarily provide

3. Purposes & Lawful Bases for Processing (GDPR)

We process your data only on the following lawful bases:

• Your explicit, freely given, specific, and informed consent

• Necessity to perform a contract with you

• Compliance with a legal obligation

• Protection of vital interests

• Public interest task

• Legitimate interests (not overridden by your rights)

Purposes:

• Provide, maintain, and improve charging Services

• Verify identity, secure accounts, prevent fraud

• Process payments and manage orders

• Locate nearby stations and provide navigation

• Optimize performance, troubleshoot issues

• Comply with legal and regulatory requirements

4. Your Privacy Rights (GDPR & CCPA)

You may exercise the following rights free of charge, where applicable:

GDPR Rights

• Right to access your personal data

• Right to rectification of inaccurate data

• Right to erasure (right to be forgotten)

• Right to restriction of processing

• Right to data portability

• Right to object to processing

• Right to withdraw consent at any time

• Right to lodge a complaint with a supervisory authority

CCPA Rights

• Right to know what data is collected and how it is used

• Right to delete personal data

• Right to opt out of the “sale” of personal data

• Right to non‑discrimination for exercising privacy rights

How to Exercise Your Rights

Submit a request via:

• Email: UMCHR@UMCHR.com

• In‑App path: Me → Settings → Account & Security

We will respond within timeframes required by applicable law after verifying your identity.

5. Data Sharing & Disclosure

We do NOT sell your personal data for monetary consideration.

We may share data only:

• With your explicit consent

• With authorized service providers (payment, mapping, cloud, customer support) under strict data processing agreements

• As required by law, court order, or government request

• To protect safety, property, or legal rights

• In connection with a merger, acquisition, or asset transfer

6. Cross‑Border Data Transfers

Your personal data may be transferred to and stored in the People’s Republic of China.

For transfers from the EEA/U.K.:

• We use EU Standard Contractual Clauses (SCCs) 2021

• We implement appropriate safeguards, encryption, and data minimization

7. Data Retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, or as required by law.

After account closure, data will be deleted or anonymized in accordance with applicable laws.

8. Data Security

We use industry‑standard security measures:

• Encryption in transit and at rest

• Strict access control and approval procedures

• Security monitoring, vulnerability scanning, and risk assessments

• Employee confidentiality and privacy training

We will notify users and regulators as required by law in the event of a data breach.

9. Cookies & Similar Technologies

We use cookies and similar technologies to:

• Maintain login sessions

• Improve security and functionality

• Personalize your experience

You may:

• Accept or reject non‑essential cookies

• Disable cookies in browser or device settings

(Disabling may affect optional features but not core Services.)

10. Third‑Party Services

Our platform may include third‑party SDKs, links, or services. This policy does not apply to third parties. We encourage you to review their privacy policies.

11. Minors’ Privacy

Our Services are intended for users aged 18 and older.

We do not knowingly collect data from minors.

If you believe we have collected minor data, contact us immediately for deletion.

12. Policy Changes

We may update this policy. Material changes will be notified via in‑App notice, email, or website.

Continued use after the update constitutes acceptance.

13. Governing Law

This policy complies with applicable data protection laws in your jurisdiction.

Nothing in this policy limits your mandatory statutory rights as a consumer or data subject.