Privacy Policy
JAC - Italy Design Center S.r.l., with registered office in Via Torino 21/b, 10044 – Pianezza (TO), Italy, VAT no. 09391390011 (“Company, “we”) is committed to maintaining the privacy of its users (“User”, “you”). This privacy policy (the “Privacy Policy”) describes how the Company collects and processes your personal data in the context of the provision of the Services (as defined below).
Users that own or otherwise use JAC-branded electric vehicles (“Vehicles") have the possibility to install a device on such Vehicles, called “TBOX” (“System”), that allows them to perform given functions – such as, inter alia, remote door switch command, remote window switch command, remote sunroof switch command, remote Vehicle search command, remote air conditioner switch command, remote charging plan command, vehicle status enquiry, remote travel plan command, remote flashing lights and horn command, remote control security code – as well as to collect and visualize the Vehicle information indicated below (“Services”). Users can access the Services by means of a proprietary mobile application called “JAC MOTORS” (“Application”).
For the purposes of this Privacy Policy, the Company, in its quality as data controller, is the entity that establishes the purposes and means of the processing of Personal Data. The data controller can be contacted at the following e-mail address [email protected].
The Company has appointed a Data Protection Officer that can be contacted at the following e-mail address [email protected].
The Company appointed AUTO KUNZ AG as local representative in the Swiss Confederation (the “Swiss Local Representative”). The Swiss Local Representative can be contacted as follows:
Kevin Baumann
Bremgarterstrasse 75 und 38 • CH-5610 Wohlen •
2. Device
Users can access the Application through various devices. A “Device” is any digital device used to access the Application, including without limitation mobile phone, tablet, or other consumer electronic device.
3. Personal Data processed by the Company
Through the Application and/or in the context of the provision of the Services, the Company may process the following personal data (“Personal Data”).
a. Device information
By clicking "install" in the mobile store (i.e. App Store, Play Store) of your Device, you express an explicit consent. By conferring such consent, you authorize the Company to install the Application, as well as to obtain certain data – personal and non-personal – related to the Device, the processing of which is necessary to enable the successful installation itself (e.g. Device model, operating system version, screen resolution, connection type, language, etc.). Since the processing of such information is essential for the technical operations of installing the Application on your Device, the only way you can object to such processing is to uninstall the Application itself.
If you do not agree with this Policy, you must not use any of the Services and the Application. If you change your mind in the future after accepting the Privacy Policy, you must stop using the Services and the Application and you may exercise your rights concerning your Personal Data as set out in this Policy.
In addition, the Company may collect information through the use of software development kits (SDKs) and other tracking technologies. Please note that third-party SDKs may have some changes in data types due to version upgrades, policy adjustments, etc. Please refer to the official instructions published by them. At present, this app ( iOS and Android versions both) accesses third-party SDKs as follows:
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Third-party name
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Purpose of use
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Types of personal information involved
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SDK Privacy Statement or Developer's Guide SDK |
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GMS (Android) |
Used to provide in-site mail push function
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Device ID, the user's logged-in personal account ID
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|
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HUAWEI AGC (iOS & Android) |
For rapid discovery, localization, and resolution of application crashes
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User device information, model, Android version, brand, device ID |
https://developer.huawei.com/consumer/cn/doc/overview/AppGallery-connect https://developer.huawei.com/consumer/cn/doc/development/hmscore-common-Guides/privacy-0000001261262707 |
b. Registering your Account
c. Edit your Account – Additional information
In addition to the Personal Data indicated in par. 3.b above, the Application allows you to complete your Account with additional information, such as your signature and your profile picture. One option for collecting your picture is by providing us access to your mobile phone gallery. If you choose this option, you will provide us with access to the photos saved on your mobile phone. Please note that the conferral of such additional Personal Data is fully discretional and that it will not impede you to create your Account and/or otherwise access the Services.
d. Vehicle Information
In order to provide you with the Services, and for the operation of the System, we will collect the following information:
· general Vehicle information: Vehicle VIN, Vehicle status, cruising range, total mileage, remaining state of charge, Vehicle charging status, Vehicle lock status, door status, trunk status, window status, sunroof status, opening setting, air conditioning status, backup status, accelerator pedal travel value, brake pedal status, Vehicle running status, Vehicle speed, parking status, gear signal;
· motor information: motor speed, torque, temperature, current, voltage;
· battery information: power level, voltage, current, temperature, highest/lowest cell code and corresponding voltage value, highest/lowest code of temperature probe and corresponding temperature value, battery health evaluation SOH, thermal management status, evaporator temperature, compressor power and temperature, charging plug temperature, AC input voltage;
· error detection and management information: alarm event name, error code, alarm level, alarm object, alarm source, alarm event level, alarm event occurrence time information.
e. Information collected via our Distributors
You may be provided the Services via the distributors of the Vehicles (“Distributors”). In such cases, the first step of your Account’s registration will be carried out by the Distributor performing the Services, who will provide us the following Personal Data: your e-mail address, the Vehicle’s VIN, the ID of the System installed on the Vehicle, the ICCID, IMSI and MSISDN of the System’s SIM card. In addition, Distributors may also provide us with transactional information relating to your purchase of the Vehicle and of the System.
f. Information relating to your requests submitted through the "Contact Us" section or via the Swiss Local Representative
When you request information by sending an e-mail to our customer service department via the "contact us" section or via our Swiss Local Representative, we will process your Account information, as well as any other Personal Data spontaneously provided by you with your request.
4. Sources of Personal Data
The Company may receive your Personal Data from third parties, including, in particular, Distributors or the Swiss Local Representative.
5. Purposes of the processing, legal bases and retention periods
a. Account registration
The Personal Data collected for your Account’s registration are processed exclusively for the purpose of allowing you to take full advantage of the Services, and, in particular:
i. for purposes related to the management of your Account;
ii. for administrative, accounting and legal purposes related to the management of the Services;
iii. for purposes of customer service;
iv. for purposes of sending transactional communication and periodic updates strictly related to the Services by e-mail, SMS and/or push notifications.
The legal basis for the processing of such Personal Data is the performance of contracts or pre-contractual obligations that you have signed for.
In this context, we will retain your Personal Data from the Account’s creation and until the latter is deleted and, thereafter, where strictly necessary, for further periods of time to the extent permitted by the applicable statutes of limitations.
Without prejudice to the above, if you decide to delete your Account, your Personal Data will be retained for a period not exceeding 3 months for administrative purposes only, without prejudice to further retention periods determined on the basis of the need to protect our legitimate interests (e.g. in case of claims and/or disputes in judicial and/or extrajudicial proceedings) and/or provided for by specific legal regulations.
b. Provision of the Services
We collect and process Personal Data to allow you to use the Services provided by the Company through the Application and the System.
The conferral of your Personal Data for such purpose is not mandatory; nevertheless, in lack thereof, we may not be able to provide you the Services.
In this context, we will retain your Personal Data from the commencement of the Services’ provision and for the period of time allowed by the applicable statutes of limitations and, thereafter, where strictly necessary to protect our legitimate interests (e.g. in case of claims and/or disputes in judicial and/or extrajudicial proceedings).
c. Improvement and development of the Services
We process Personal Data:
● to improve and develop our Services and receive feedback on the Company’s services;
● to continually review and improve the information provided on our Application to ensure it is user friendly.
● to improve the management and administration of our business and maintain compliance with our internal policies and procedures;
● to conduct surveys and research, to test features in development, and analyze the information we have to evaluate and improve our Application and Services, develop new features, and perform audits and troubleshooting activities.
We will retain your Personal Data for the time necessary to fulfil such purposes – in any case, no longer than 12 months from their collection – and subsequently anonymize or delete it.
d. Maintaining a safe and secure environment
We may use your Personal Data to detect and prevent fraud, abuse and security incidents in the following ways:
● verify and authenticate your identity and prevent unauthorized or illegal activity;
● enhance the safety and security of our Application and Services;
● conduct security investigations and risk assessments;
● prevent or take action against activities that are, or may be, in breach of our terms of service or applicable law.
We will retain your Personal Data from the Account’s creation for the time necessary to fulfil such purposes and subsequently anonymize or delete it.
e. Compliance with legal obligations
The legal basis for such processing of Personal Data is the fulfillment of legal obligations to which the Company is subject.
We will retain your Personal Data processed for such purpose for the period of time strictly necessary to enable us to fulfill the legal obligations to which we are subject and, in any case, for a maximum period of time of 10 years from the termination of the Services.
f. Ascertaining, exercise or defence a right in court or whenever judicial authorities exercise their functions
We may also need to process your Personal Data in order to enable us to ascertain, exercise or defend a right in court or whenever judicial authorities exercise their functions.
The legal basis for the processing of such Personal Data is the pursuance our legitimate interests. With this regard, we inform you that our legitimate interests pursued by means of the processing at stake are deemed to be fairly balanced with your interests, fundamental rights and freedoms as data subject. Please also note that such processing is not mandatory and you may object to it as specified in this Privacy Policy. In such case, we may not continue the processing except in presence of overriding legitimate grounds.
In this context, we will retain your Personal Data for the period of time allowed by the applicable statutes of limitations, from the termination of the Services.
g. To allow the Company to complete a potential merger, sale of assets, sale of business or business unit or other M&A transaction by disclosing and transferring your personal data to the third party(ies) involved
We may need to process your Personal Data in order to carry out extraordinary corporate transactions such as mergers, acquisitions, spin-offs, business divestitures, etc.
The legal basis for the processing of such Personal Data is the pursuance our legitimate interests. With this regard, we inform you that our legitimate interests pursued by means of the processing at stake are deemed to be fairly balanced with your interests, fundamental rights and freedoms as data subject. Please also note that such processing is not mandatory and you may object to it as specified in this Privacy Policy. In such case, we may not continue the processing except in presence of overriding legitimate grounds.
In this context, we will retain your Personal Data for the period of time strictly necessary to complete the transaction(s), starting from the Account’s creation.
6. Disclosure and transfer of Personal Data
Except as otherwise provided in this Privacy Policy, we reasonably attempt to ensure that we never intentionally disclose any of your Personal Data, to any third party without having received your permission, except as provided for herein or otherwise as permitted or required under law.
In pursuit of the purposes described above, your Personal Data may be shared with:
- employees and/or collaborators of the Company authorized and/or entrusted with the processing of Personal Data;
- parties delegated and/or appointed by the Company to carry out activities strictly related to the pursuit of the purposes indicated above (including management and technical maintenance of information systems);
- the Swiss Local Representative;
- IT providers;
- persons, companies or professional firms providing assistance and consulting services to the Company;
- Distributors, car dealerships, auto repair shops;
- banks and credit institutions;
- insurance companies;
- subjects, entities or authorities to whom the communication of your Personal Data is mandatory by virtue of legal provisions or orders of the competent authorities;
- third parties part of corporate transactions that may involve the Company;
with which the Company, where necessary, has entered into specific data processing agreements. In any case, only the Personal Data necessary and pertinent to the purposes of the processing to which they are assigned will be communicated to the aforementioned subjects.
7. Your Rights
You have the right at any time to request to delete, access or modify your information. To exercise these options, please contact us at [email protected].
In addition to the above, we inform you that, in the EEA and the Swiss Confederation, you always have the right to lodge a complaint with the competent Data Protection Authority, if you believe that the processing of your Personal Data infringes the applicable law.
If you wish to file a request regarding any of the above, you may contact us at: [email protected].
8. Opt In or Opt Out
You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to: [email protected]. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.
You can stop the collection of vehicle data and vehicle remote control services at any time, directly through the Application. This will not prejudice the processing of Personal Data collected before the opt out, which will be retained until you delete your Account and/or, in any case, in conformity with the other retention periods indicated above.
9. Data Security
We deploy industry standard measures to ensure the security, confidentiality, integrity and availability of the Personal Information we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Data on a ‘need to know’ basis for the provision of Services to you.
- the pseudonymization or encryption of Personal Data;
- the confidentiality, integrity, and availability of Personal Data;
- the resilience of the systems and services that process Personal Data;
- the ability to restore Personal Data in the event of a data breach.
10. Children's Privacy
The Application is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.
IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE APPLICATION, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY.
11. Questions Regarding Our Privacy Policy
If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at [email protected].
12. Revisions and Modifications to our Privacy Policy
We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly and inform you by means of a pop-up notification. Please review this Privacy Policy often so that you will remain updated regarding our current policies.
This Privacy Policy was last updated in March 2024.