WattCycle Privacy Policy

Shenzhen Washi Energy Co., Ltd. (hereinafter referred to as "we", "us", or "WattCycle") respects and protects users' personal information and privacy rights. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use the WattCycle App (hereinafter referred to as "the App" or "the Service"), as well as your rights under applicable data protection laws.

Please read and fully understand this policy carefully before using the App. If you do not agree with any provision of this policy, you have the right not to use the App. Your continued use of the App will be deemed as your full understanding and voluntary acceptance of all provisions of this policy.

I. Types of Information We Collect and How We Use It

To enable core functions such as battery monitoring, data analysis, and Bluetooth connectivity, we may collect the following information to the extent permitted by applicable law:

1. Account Information

When you register for or use the account functions of the App, we may collect: personal identification information such as phone number, email address, nickname, and password.

Purpose: Account creation, login verification, password recovery, and necessary identity verification.

2. Device and Bluetooth Information

When you connect the battery or BMS device, we may collect: device name, serial number, and operating parameters (such as voltage, current, temperature, and SOC status).

Purpose: Real-time monitoring, data display, device identification, and communication.

3. Location Information

The App only temporarily requests location permissions when you perform Bluetooth scanning, searching, and device connection operations. This permission is used solely for the above functions and will not be stored, tracked, or used for other purposes.

4. Logs and Usage Information

To ensure service stability, we may automatically record: operation logs, error logs, feature usage information, and timestamps.

This information is used exclusively for service optimization, troubleshooting, statistical analysis, and security assurance.

We do not collect personal information unrelated to the above services.

II. Information Storage and Protection Measures

1. Storage Period

We determine the retention period based on the type of information and the purpose of processing:

• Account-related information: after your account is deleted, it will be deleted or irreversibly anonymized as soon as possible, subject to legal retention obligations, dispute resolution, and fraud prevention requirements.
• Log information: will be regularly anonymized or deleted in accordance with legal and security requirements.
• Personal information that exceeds the legal retention period will be promptly deleted or irreversibly anonymized.

2. Storage Location

In principle, we store your personal information on servers located within the jurisdiction where you use the App. If cross-border transfer of your personal information to other countries or regions (including affiliates, authorized service providers, or partners) becomes necessary, we will inform you in advance of the purpose of the transfer, the identity of the recipient, the types of personal information involved, and the security measures implemented. Where applicable law requires consent as the legal basis, we will obtain your voluntary, explicit, informed, and specific consent. We will also adopt appropriate internationally recognized safeguards (such as standard contractual clauses) and strictly comply with all mandatory compliance procedures under applicable data protection laws to ensure that cross-border transfers are legal and secure.

3. Security Protection Measures

We adopt internationally recognized security technologies and management measures to protect your information, including but not limited to:

• Encrypted storage and transmission
• Access control and authentication
• Security audits and system monitoring
• Regular security assessments and risk screening

Unless otherwise required by law or with your prior explicit consent, and except as reasonably necessary for providing and performing the Service, we will not provide, sell, rent, exchange, or transfer your personal information to any unrelated third party.

III. Your Rights

To the extent permitted by applicable law in your jurisdiction, you have the following rights regarding your personal information:

1. Right of Access and Transparency: you have the right to obtain information about our processing of your personal information and to request a copy of such information.
2. Right to Rectification: you have the right to request the correction of inaccurate or incomplete personal information.
3. Right to Erasure: you have the right to request the deletion of your personal information in cases provided by law.
4. Right to Restriction of Processing: in certain circumstances, you have the right to request the restriction of processing of your personal information.
5. Right to Data Portability: to the extent permitted by law, you have the right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.
6. Right to Object: based on your particular situation, you have the right to object to the processing of your personal information.
7. Right to Withdraw Consent: if you have given consent for the processing of your personal information, you have the right to withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
8. Right to Lodge a Complaint: if you have concerns about our processing of your personal information, you have the right to lodge a complaint with the competent data protection supervisory authority or seek other legal remedies.

How to Exercise Your Rights

You may exercise your rights by contacting us through the contact methods provided in the App (such as the Data Protection Officer's email address or customer service). To protect your information security, we may verify your identity and will respond to your reasonable request within the time limit prescribed by applicable law.

Contact Email: service@wattcycle.com

We will process your rights request within 30 days after verifying your identity. If the matter is complex or special circumstances prevent timely completion, we may extend the processing period as permitted by law and will inform you in advance of the reason for the extension and the new processing timeline.

For account deletion requests, we will process them within 30 days after identity verification and provide feedback. After account deletion, your account-related information will be deleted or anonymized in accordance with applicable law, except for information that must be retained to fulfill legal obligations, resolve disputes, prevent fraud, or meet compliance retention requirements.

For security reasons, we may require you to provide necessary identity verification information during the processing of the above requests.

IV. Third-Party Services and SDK Usage

To process in-app payments (for example, when you purchase products through our new store feature), we integrate software development kits (SDKs) provided by payment service providers. These SDKs may collect certain information as described below to enable payment processing, fraud prevention, and service improvement.

Stripe SDK

We use Stripe, Inc. ("Stripe") to process payment transactions. When you initiate a payment, the Stripe SDK may automatically collect and process the following types of information:

• Device Information: such as device model, operating system version, IP address, and unique device identifiers. This information is used to improve Stripe's products and to detect and prevent fraud.
• Payment Information: such as credit/debit card numbers, expiration dates, and security codes. Stripe processes this information directly and securely; our App does not store any sensitive payment data.
• Product Interaction Data: information about your interactions with the payment interface (e.g., button clicks, page views) to help Stripe analyze and optimize the payment experience and for fraud detection.
• User Identifier: if you are logged into your account, Stripe may associate your payment activity with a customer ID to maintain transaction history and prevent fraud.

Stripe's use of this information is governed by its own privacy policy, available at: https://stripe.com/privacy.

Apple Pay

If you choose to pay using Apple Pay, your payment information is handled entirely by Apple. The App does not have access to your actual credit card numbers. Apple Pay transactions are subject to Apple's privacy policy, available at: https://www.apple.com/legal/privacy/.

Important Notes

• The information collected by Stripe is used solely for payment processing, fraud prevention, and service analytics – not for cross-app tracking outside of our App.
• We transmit the necessary information to Stripe solely for the purpose of completing payment transactions. Any cross-border data transfers are conducted in accordance with Stripe's privacy policy and applicable law.
• We do not share your personal information with third parties for their own direct marketing purposes, unless required by law or with your voluntary, explicit, and informed consent.
• If we need to integrate additional third-party services in the future, we will inform you in advance by prominent means, disclosing the provider of such service, the types of personal information to be processed, the purposes and methods of processing, and providing a link to the third party's privacy policy. Where applicable law requires consent, we will obtain your voluntary, specific, and informed consent before integration or activation. We will also promptly update this Privacy Policy and fulfill all required notice and compliance procedures.

V. Protection of Minors

The App is primarily intended for adult users. If you are a minor under the age of majority as defined by the laws of your jurisdiction, you may only use the App and provide your personal information with the verifiable, explicit consent of your legal guardian. We reserve the right to request proof of such consent. If we discover that we have collected personal information from a minor without proper legal authorization, we will promptly delete or restrict processing of such information.

VI. Policy Changes

If this Privacy Policy changes, we will publish the revised version in the App or on our official website. If the changes involve material adjustments to the rules for processing personal information, we will notify you in advance through prominent means such as pop-ups, push notifications, or email.

You have the right to refuse the revised terms and stop using the App. Your continued use of the App after the changes take effect will be deemed as your acceptance of the revised Privacy Policy.