Privacy Policy of Shenzhen Washi Energy Co., Ltd.

I. Policy Statement

Shenzhen Washi Energy Co., Ltd. (incorporated in accordance with the laws of the People’s Republic of China; hereinafter referred to as Washi or we) regards the protection of users’ personal information as our core responsibility at all times, and strictly complies with the Personal Information Protection Law of the People’s Republic of China, the Cyber Security Law of the People’s Republic of China and other applicable laws and regulations. When you use Washi’s products or services, we may collect and use your personal information based on the principles of legality, legitimacy and necessity. This Privacy Policy is formulated to clearly inform you of the specific ways we collect, store, use and share your personal information, as well as the relevant rights and obligations of both parties. We recommend that you read and understand all the contents of this Policy carefully, so that you can make choices in line with your own wishes when using our products or services.

Your use or continued use of Washi’s products and services shall constitute your full understanding and consent to our processing of your personal information in accordance with the provisions of this Privacy Policy. If you disagree with any clause of this Policy, please do not use our products or services.

II. Personal Information We Collect

Information voluntarily provided by you with your explicit consent during your use of Washi’s products and services, including but not limited to your name, phone number, email address, service inquiries, product usage preferences and other relevant information. Such information is only used to fulfill your service requests and optimize your product experience.
Your personal information may contain sensitive information (e.g., precise contact details, specific service requirements, etc.). If you choose to upload or post such sensitive information through public channels, you shall bear the relevant risks on your own, and Washi hereby reminds you to handle such information with caution. If you voluntarily provide us with your sensitive personal information, it shall be deemed that you consent to our compliant processing of such information for the purposes and in the manners stipulated in this Policy.

III. Purposes of Collecting Personal Information

We collect your personal information only for the following legitimate purposes, and the scope of collection is strictly limited to the minimum necessary:

Conduct identity verification, prevent fraudulent acts, safeguard transaction security and protect the legitimate rights and interests of both parties;
Accurately identify your technical service needs and provide you with tailored solutions;
Match products and services that meet your needs to ensure the accuracy and effectiveness of service delivery;
Perform contractual obligations and provide the agreed products and services in accordance with your explicit requirements;
Comply with mandatory provisions of laws and regulations and fulfill compliance obligations.

IV. Data Security Protection

Washi attaches great importance to data security and has established a comprehensive and multi-tiered security protection system to fully safeguard the security of your personal information:

Technical Safeguards: We adopt advanced technical measures including encrypted data transmission, encrypted storage, access permission control and security audit, and build a sound security protection system to resist risks such as cyber attacks and data leakage, so as to ensure the integrity and confidentiality of information;
Institutional Safeguards: We have formulated strict information security management systems, conduct regular privacy protection training and assessments for employees, clarify the authority and responsibilities for information processing, and ensure that all employees strictly abide by the relevant provisions on data protection;
Risk Control: We have established an emergency response mechanism for data security, conduct regular security risk assessments and vulnerability detection, and promptly address potential security risks.

Please note that due to the openness and complexity of the network environment and the limitations of technological development, even with the above security measures in place, we cannot completely eliminate the inherent risks in the process of network transmission and data storage. Washi will continuously optimize its security protection capabilities and make every effort to minimize such risks.

V. Use of Personal Information

We strictly use your personal information in accordance with the provisions of this Policy and applicable laws and regulations, including the following specific circumstances:

Provide, maintain and optimize Washi’s products and services to ensure their normal operation;
Develop new products and services, and iterate and optimize the functions and experience of existing products and services based on user needs and product usage data;
Use such information for necessary scenarios including identity identification, customer service response, security prevention, compliant filing and data backup;
Send you marketing information such as product updates and service discounts relevant to your needs (you may unsubscribe from such information at any time in accordance with the provisions of this Policy);
Invite you to participate in surveys and evaluations related to our products and services to help us continuously improve service quality.

VI. Sharing of Personal Information

Washi strictly protects your personal information and will never disclose, sell or rent your personal information to any third party without your explicit consent, except for the following circumstances, and we will take strict measures to ensure information security in such cases:

With your prior explicit consent or authorization;
Sharing the necessary personal information with Washi’s legally authorized product or service partners for the purpose of fulfilling the service obligations stipulated in this Policy (we will sign strict confidentiality agreements with such partners, prohibiting them from using the information for any other purposes);
Reasonable internal sharing within Washi and its affiliated companies for internal business operation needs (limited only to the purpose of service provision or compliance);
In the event of business changes such as merger, acquisition, asset transfer or bankruptcy liquidation of Washi, your personal information will be legally transferred as part of the business assets to the new right holder (the new holder will continue to perform the privacy protection obligations stipulated in this Policy);
Disclosure or provision is mandatory pursuant to the provisions of laws and regulations or the legitimate requirements of judicial organs or competent administrative departments;
Within a reasonable and necessary scope for the protection of Washi, its affiliated companies, other users, public interests or the legitimate rights and interests of others (e.g., responding to fraud, settling legally due debts, etc.);
Processing of personal information that you have disclosed voluntarily or that has been legally disclosed (without violating mandatory provisions of laws and regulations and public order and good morals).

Pursuant to the provisions of laws and regulations, we are not required to obtain your prior consent for processing your personal information under the following circumstances:

It is necessary for the conclusion and performance of a contract to which you are a party;
It is necessary for the performance of statutory duties or obligations;
It is necessary for responding to sudden public health incidents, or protecting the life, health and property safety of natural persons in emergency situations;
Processing within a reasonable scope for the purpose of public interests such as news reporting and public opinion supervision;
Other circumstances prescribed by laws and administrative regulations.

Under the following circumstances, we may not be able to inform you of the processing of your personal information in a timely manner (we will inform you promptly after the emergency is eliminated, except where laws and regulations stipulate no such notification is required):

It is impossible to inform you in a timely manner in emergency situations for the protection of the life, health and property safety of natural persons;
Circumstances where confidentiality is required or no notification is needed pursuant to laws and administrative regulations.

VII. Your Rights and Methods of Exercise

You are entitled to the statutory rights to access, copy, rectify, supplement and delete your personal information, as well as the right to view records of personal information disclosure. The specific methods of exercising such rights are as follows:

You may submit relevant requests through your account manager, authorized distributor, or the channels listed in the How to Contact Us section of this Policy;
To protect the security of your account and the accuracy of information ownership, we may require you to complete identity verification before processing your request, and we will handle your request promptly upon the completion of valid verification;
If we are unable to meet your request due to legal restrictions, non-existence of the requested information, involvement of the legitimate rights and interests of others or other reasons, we will explain the specific reasons to you.

Additional Provisions on Your Rights

You have the right to choose not to provide certain non-essential personal information, but this may result in our inability to provide you with some products or services that rely on such information (e.g., personalized recommendations, specific after-sales support, etc.);
For the purpose of ensuring service quality, verifying the authenticity of transactions and protecting the legitimate rights and interests of both parties, we may reasonably record your telephone communications and email correspondence with Washi (such records are only used for internal compliance and service optimization);
If you no longer wish to receive our direct marketing information, you may unsubscribe through the unsubscribe link in the marketing information or contact our customer service to apply for unsubscription, and we will complete the processing within 15 working days;
If you do not wish us to share your personal information within Washi or with its affiliated companies, you may inform our customer service accordingly. However, if such sharing is a necessary prerequisite for providing specific products or services, we may no longer be able to provide the relevant services to you;
Minors under the age of eighteen shall obtain the consent and guidance of their parents or guardians prior to using our products or services. Guardians may contact us for assistance in handling matters related to the personal information of minors;
The terms of this Policy shall comply with the laws applicable to your place of residence. If the local laws grant you more comprehensive rights, this Policy shall not exclude or restrict such statutory rights.

VIII. Changes to the Policy

We may revise this Privacy Policy from time to time in light of updates to laws and regulations, business development needs or adjustments to products and services. The revised Policy shall form an integral part of this Policy. If the revised content results in a material reduction of your rights under this Policy, we will notify you of such revisions through the following methods prior to their effective date:

Public announcement on prominent positions such as Washi’s official website and product clients;
Sending a notification to your registered email address or mobile phone number;
Other reasonable notification methods.

Your continued use of Washi’s products and services after the revised Policy takes effect shall constitute your consent to the revised Privacy Policy. If you disagree with the revised content, you shall immediately stop using our products and services.

IX. Our Commitments

Washi always prioritizes the protection of user privacy, and winning and maintaining your trust is the core foundation of our sustainable operation. We hereby solemnly commit to:

Strictly abiding by relevant laws and regulations and the provisions of this Policy, standardizing the processing of your personal information, and not using such information beyond the scope of legitimate purposes and necessity;
Establishing a dedicated privacy protection management team responsible for formulating and implementing information protection systems, handling privacy-related complaints and disputes, conducting employee training and other related work. This team reports directly to the Board of Directors Office and the General Manager to ensure the effective implementation of privacy protection work;
Continuously investing resources to optimize data security technologies and management systems, and constantly improving the capability of personal information protection.

X. How to Contact Us

If you have any questions about this Policy, need to consult matters related to your personal information or wish to file a complaint, you may contact us through the following channels:

Online consultation or feedback submission via the Service & Support section on Washi’s products or official website;
Send an email to our customer service mailbox: pr@wattcycle.com.cn;
Call our customer service hotline: 400 0800 563 (Working Hours: Monday to Friday, 9:00-17:30 GMT+8);
Mailing address: 31/F, West Tower, Lepu Building, No.66 Xingke Road, Xili Community, Xili Sub-district, Nanshan District, Shenzhen City, Guangdong Province, P.R.China.

We will respond to your request within 15 working days after verifying your identity. If the situation is complex and requires an extension of the processing time, we will inform you in advance.

XI. Limitations on Responding to Requests

You understand and agree that we may not be able to respond to or fully meet your requests under the following circumstances (we will explain the specific reasons to you):

Your request conflicts with the obligations stipulated by laws and regulations;
The request involves national security, national defense security, public security, public health or major public interests;
The request is directly related to judicial procedures such as criminal investigation, prosecution, trial and enforcement of judgments;
There is reasonable evidence proving that you have intentional malice, abuse of rights or made a false request;
It is necessary to protect the vital legitimate rights and interests such as life and property of you or other natural persons, and it is impossible to obtain your consent;
Responding to your request will seriously damage the legitimate rights and interests of you or other individuals and organizations;
The requested information involves trade secrets, the privacy of others or other information protected by law.