Toppal Sentry is acutely aware of the importance of personal information to users (referred to as "you") and is highly committed to the privacy and protection of personal information. In accordance with relevant laws and regulations, we have established the "Privacy Policy" ("this Privacy Policy").

Before using our products and/or services, it is essential for you to read and confirm that you have thoroughly understood the content outlined in this Privacy Policy and to make choices that you deem appropriate. For certain services, based on the sensitive personal information you provide voluntarily, we will process your sensitive personal information in the manner and for the purposes described in this statement. You have the right to refuse to provide us with sensitive personal information; however, refusing to allow us to collect and use this information may affect your use of related features. If you use such features, it is considered that you are aware of and agree to our collection of the sensitive personal information you provide.

We will collect or process personal information related to you through the Toppal Sentry official website, Toppal Sentry App, and potentially other clients or scenarios in which we now or in the future provide Toppal Sentry services ("our products and/or services"). It is important to note that this Privacy Policy applies universally to the standard privacy protection clauses of Toppal Sentry, and the user rights and information security measures stipulated in this Privacy Policy are applicable to all our products and services. If a particular product and/or service has its own privacy policy, that specific policy will take precedence. If you do not use the products or services provided by us, we will not collect the corresponding information.

If you have any questions about this Privacy Policy or related issues, you can contact us at any time by sending an email to toppal@txzing.com. We appreciate your understanding and support.

This Privacy Policy will help you understand the following:

1. How we collect and use your personal information

2. How we use cookies and similar technologies

3. How we entrust, share, transfer, and publicly disclose your personal information

4. How we protect and store your personal information

5. How you can manage your personal information

6. How we handle the information of minors

7. Updates and revisions to this Privacy Policy

8. How to contact us

9. Dispute resolution

Supplementary Provision: Definitions

I. How We Collect and Use Your Personal Information

(A) Scenarios of Personal Information Collection in Our Products and/or Services

We adhere to the principles of legitimacy, legality, and necessity. For the purposes described in this Privacy Policy, we collect and use the personal information that you provide voluntarily while using our products and/or services, information that we directly collect from your use of our products and/or services, and information provided by third-party partners authorized by you. If we intend to use your personal information for purposes not specified in this Privacy Policy, or use information collected for specific purposes for other uses, we will inform you in a reasonable manner and seek your consent again. To offer expanded business functionalities of our products and/or services, you may choose to authorize us to collect and use your information. If you refuse to provide this information, you will be unable to use the related extended functionalities or achieve the intended effects of our features, but it will not affect your use of the basic business functionalities of our products and/or services. If you disagree with the privacy policy, you may opt for a browsing-only mode, which allows access to part of the community content without collecting your personal information. When using our products and/or services, we may need to collect and use your personal information in the following scenarios:

1. User Registration and Login:

When you register or log into the Toppal Sentry official website or Toppal Sentry App, you need to provide your email account as identification information. We verify the validity of your identity by sending a verification code.

2. Personal Profile:

To display your profile, you may fill in/modify/add to your personal details on the Toppal Sentry App. Personal details include your avatar, nickname, etc., as displayed on the page. You can decide whether to provide the above information; not providing it will not affect your normal use of our products and/or services.

3. Toppal Sentry App Remote Vehicle Control:

If you link your vehicle to the Toppal Sentry App and use it for remote vehicle control, you need to provide your Toppal Sentry App account avatar, nickname, vehicle SN code, and vehicle VIN code to activate the vehicle system and link your account with the vehicle.

You can view various vehicle-related status information on the Toppal Sentry App, including data obtained from the vehicle end.

4. Customer Service and After-sales:

When communicating with our customer service personnel, to ensure the security of your account, we will use your account information to verify your identity. We may also provide you with dedicated service experts and repair specialists based on your service needs. When you require customer service or after-sales related to your order information, we will access your order details. During communication with our customer service, depending on your specific needs, additional information may be required to resolve issues, with specifics depending on the actual communication scenario. We retain records of your communication with customer service, which are documented through call recordings and manual entry to help resolve issues, provide feedback, or handle disputes.

5. Anomaly Investigation and Security Assurance:

To ensure the normal use of our products and/or services, maintain their proper functioning, and secure your account, we collect device information (including device identifiers such as IMEI/Android ID/IDFA/IDFV/OPENUDID/OAID/GUID/IMSI, network device hardware address (MAC address), device parameters and system information (device type, model, operating system, screen resolution, and related hardware information), and device network environment information (IP address)) and operational status while you use our products and/or services.

We collect operation logs and service logs (defined in this Privacy Policy as the content you post and browse, including the time, type, original network address, destination address, port, date and time of access, and login IP information) during your use of our products and/or services to identify product issues and optimize the product experience.

To enhance the security of your online car bookings and more accurately prevent phishing site fraud and protect account security, we may assess your account risk using your browsing information, online booking data, commonly used software information, and device information. We may record links we consider risky; we also analyze device information for transaction security, monitor traffic, investigate potential risks, and respond to anomaly reports to ensure your transaction security.

6. Event Participation:

When you register for events held by us or in cooperation with third-party online platforms, depending on the nature of the event, you may need to provide different personal information, and we may share this information with third parties providing the corresponding services, as specified in the event details and registration information.

7. Information Push and Promotion:

The Toppal Sentry App may push information related to our products and/or services (including behavior reminders, message alerts, vehicle status and usage behavior reminders, after-sales service reminders, event alerts, etc.). We will periodically send you information that we believe may be of interest to you, including advertisements, promotions, and marketing messages.

8. Data Analysis:

We may research, process, train, analyze

, and statistically evaluate the log information, order information, test drive data, vehicle purchase information, and event data from your use of our products and/or services to improve and optimize our products and services. The information used for data analysis does not identify your personal information, and we only retain the analysis results.

9. Personalized Content Recommendation:

To display personalized content in the Toppal Sentry App community forum, we may collect information about your use of our products and/or services to recommend content of interest to you. The personalized content recommendation is specifically for content within the community forum, and you can enable or disable this service through "My - Settings - Privacy Settings".

(B) System Permissions Used by Toppal Sentry App

To enhance your convenience and enjoyment of our products and/or services, thus improving your user experience, our products and/or services may require access to system permissions. These permissions are only activated after your explicit authorization and will only collect your personal information when necessary for the related functions or services. This section categorizes and organizes the system permissions we use to present them to you in a more systematic, comprehensive, and transparent manner. You can manage the relevant permissions based on your actual needs and check the usage of permissions in the Toppal Sentry App through "【】".

In accordance with relevant laws and regulations, we may collect and use your personal information without seeking your consent under any of the following lawful grounds:

1. It is necessary for us to fulfill obligations or duties as required by laws and regulations.

2. It is necessary for the conclusion or fulfillment of a contract we have entered into with you.

3. It is necessary to respond to force majeure events, or in emergencies, to protect the life, health, and property safety of natural persons.

4. Personal information that has been made public by the individual or is legally publicized can be processed within a reasonable scope as stipulated by the "Personal Information Protection Law of the People's Republic of China".

5. Other circumstances specified by laws and administrative regulations.

II. How We Use Cookies and Similar Technologies

(A) Use of Cookies

II. How We Use Cookies and Similar Technologies

(A) Use of Cookies

When you use our services, to provide you with a better service and a more relaxed login and access experience, we may place one or more small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. We send cookies to simplify your repeated login steps, store your product and service search information, and provide preference settings. We will not use cookies for any purposes other than those described in this Privacy Policy. You can manage or delete cookies according to your preferences. You can clear all cookies stored within the software, but doing so may require you to manually change user settings each time you visit, and previously stored information may be deleted, which could affect the security of the services you use.

(B) Use of Web Beacons

In addition to cookies, we also use other similar technologies such as web beacons. Our web pages often contain certain electronic images (known as "single-pixel" GIF files or "web beacons"). The use of web beacons helps to access certain cookies, thereby recognizing registered users and providing personalized services.

III. How We Entrust, Share, Transfer, and Publicly Disclose Your Personal Information

(A) Entrusted Processing

In the future, Toppal Sentry will entrust external partners (our third-party service providers, contractors, agents, etc.) to provide you with related services. For companies, organizations, and individuals whom we entrust with personal information processing, we sign strict confidentiality agreements or data processing agreements that clearly define the responsibilities, processing matters, and purposes of both parties. We require them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures. For detailed information on how we entrust external partners with processing, please see here.

(B) Sharing

We do not share your personal information with other personal information processors, except in the following cases:

1. Based on mandatory legal requirements.

2. Sharing necessary to realize our services/functions.

When you use functions provided by third parties in our products, we share the necessary information with these third parties to enable business functions, specifically as informed on the dedicated service page and with your consent.

Our products and/or services may include third-party SDKs. If you use services provided by third parties through their SDKs while using our products and/or services, these third parties may process your information. To ensure the utmost security of your information, we strongly recommend reviewing their privacy terms before using any third-party SDK services. For situations involving the embedding of third-party SDKs in the app to process personal information, please see here.

(D) Transfer

In principle, we do not transfer your personal information to other companies, organizations, or individuals. If involved in mergers, acquisitions, asset transfers, or similar transactions that involve the transfer of personal information, we will inform you of the recipient's name or identity and contact details and require the new entity holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require that entity to re-obtain your authorization and consent.

(E) Public Disclosure

We will not publicly disclose your personal information unless we have your separate consent or you voluntarily disclose the information yourself.

Special Note: Information that you publicly share or share yourself during the use of our products and/or services is not restricted by this Privacy Policy (such as content forwarded to other internet platforms). You should be cautious about any information you share that could be read, collected, and used by third parties. You should carefully consider the content you publish and distribute through Toppal Sentry and any personal information included therein. You fully understand that once you disclose information voluntarily, as long as you do not delete the information you have publicly posted, it may remain in the public domain indefinitely; in some cases, even if you delete the information you have publicly posted, it may still be cached, copied, or stored independently by other users or by third parties not affiliated with and not controlled by Toppal Sentry, or be preserved in the public domain by other users or third parties.

IV. How We Protect Your Personal Information

1. Technical and Organizational Measures:

We have implemented security measures that comply with industry standards to protect the personal information you provide from unauthorized access, public disclosure, use, modification, damage, or loss. We take all reasonably practicable steps to protect your personal information. For example, we use access controls, TLS encryption for data transmission, and encryption algorithms such as AES256 and RSA2048 or higher for data storage, along with the anonymization of sensitive information in displays. We utilize encryption technology to ensure data confidentiality and trusted protection mechanisms to guard against malicious attacks.

Access control mechanisms are deployed to ensure that only authorized personnel have access to personal information. We conduct security and privacy protection training courses to enhance our employees' awareness of the importance of protecting personal information. Only our employees, affiliates, and partners who need to know this information are allowed access to personal information, and we have established strict access controls and monitoring mechanisms for this purpose. All personnel who may come into contact with your personal information are required to fulfill corresponding confidentiality obligations. Failure to comply with these obligations may lead to legal liability or termination of our cooperation with them.

Some of our key business systems have completed cybersecurity level protection filings and have passed the cybersecurity level protection (level three) assessment.

2. Security Incident Response:

In the unfortunate event of a personal information security incident, we will inform you promptly in accordance with the requirements of laws and regulations. You will be notified about the basic situation of the security incident, the possible impact, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly notify you of the incident via email, letter, telephone, push notification, etc. If it is challenging to inform individuals one by one, we will use reasonable and effective methods to make announcements. In addition, we will also report the handling of personal information security incidents to the regulatory authorities as required.

We strive to ensure the security of your personal information and use technical means to limit unauthorized access, use, or disclosure of your personal information. Despite these measures, please understand that due to the current limitations of technology development and various potential malicious methods, even with our best efforts to enhance security measures, it is not always possible to absolutely guarantee the security of personal information. You should be aware that the systems and communication networks used by the Toppal Sentry App, in-vehicle application platforms, and car-related hardware may experience issues due to factors beyond our control.

V. How You Can Manage Your Personal Information

We highly value your concern for your personal information and strive to protect your rights to access, copy, correct, supplement, delete, and withdraw consent for your personal information, enabling you to adequately safeguard your privacy and security. In accordance with Chinese laws, regulations, and standards, you are entitled to exercise the following rights regarding your personal information:

(A) Access Your Personal Account Information

You have the right to access your personal account information stored in the Toppal Sentry App at any time. You can do this by clicking on "My" in the Toppal Sentry App.

(B) Correct or Supplement Your Personal Information

If you find that the personal information we process about you is incorrect, you have the right to request us to make corrections or supplements. You can do this by clicking on "My" in the Toppal Sentry App.

You can request the deletion of your personal information through the deletion entry within the app, except where your information has been anonymized or as otherwise stipulated by law. We will verify your identity when deleting personal information. You should cooperate in verifying your identity and specify the type of personal information you wish to delete. We will respond to your request according to national laws, regulations, and regulatory requirements.

After you or we assist you in deleting relevant information, due to applicable legal and security technology limitations, we may not be able to immediately delete corresponding information from backup systems. We will securely store your personal information and restrict further processing until the backup can be cleared or anonymized.

(D) Change the Scope of Your Authorization or Withdraw Your Consent

You can exercise your right to withdraw consent to the privacy policy in the "My" section of the Toppal Sentry App. Please understand that each business function requires some basic personal information to operate (see "I. How We Collect and Use Your Personal Information" in this Privacy Policy). Once you withdraw your consent or authorization, we cannot continue to provide the services corresponding to the consent or authorization withdrawn, nor will we process your personal information any longer. However, your decision to withdraw consent or authorization will not affect the processing of personal information based on your authorization prior to the withdrawal.

(E) Data Erasure

You can apply for data erasure in "My" on Toppal Sentry. Once you meet the conditions for application displayed on the Toppal Sentry App and successfully apply to deactivate your Toppal Sentry App account, we will cease providing our products and/or services to you. Unless otherwise provided by laws and regulations, we will delete your personal information or anonymize it.

VI. How We Handle Information of Minors

We take the protection of children's personal information very seriously. If you are a child, we require you to have your parents or other legal guardians carefully read this privacy policy and use our services or provide us with information only with the consent of your parents or other legal guardians.

If we identify that you are a child user, we will notify your parents or other guardians and require their consent to the rules for collecting and using children's personal information. We will only use, share, transfer, or disclose children's personal information when legally permitted, with clear consent from a parent or guardian, or when necessary to protect minors. If your parents or other legal guardians do not agree with you using our services or providing us with information as described in this policy, please immediately stop using our services and notify us promptly so that we can take appropriate measures. If a guardian discovers that we have collected personal information from a minor without consent, they can contact us using the details in section IX, and we will endeavor to promptly delete the data.

Protection of children's personal information will also be subject to strict controls on personal information access rights and comprehensive measures for recording and managing personal information processing. We always follow the principle of minimal necessary authorization and employ technical measures to avoid unlawful copying or downloading of children's personal information.

In the unfortunate event of a security incident involving children's personal information, we will inform the child and their guardian promptly in accordance with legal and regulatory requirements. We will provide details of the incident, including its nature and potential impact, the measures we have taken or will take, suggestions for prevention and risk reduction, and remedial measures for the child and their guardian. We will notify the child and their guardian about the incident through push notifications, emails, or messages as soon as possible. If it is not feasible to inform each individual directly, we will employ reasonable and effective methods to publish relevant warning information. Additionally, we will proactively report the handling of the children's personal information security incident as required by regulatory authorities.

VII. Updates and Revisions to This Privacy Policy

To provide better services and as our business evolves, this Privacy Policy will also be updated accordingly. Without your explicit consent, we will not reduce your rights under the previous privacy policies. We will issue updated versions and remind you of the updates through announcements or other appropriate methods before they take effect. Please make sure to log into the Toppal Sentry official website, App, or mini-programs regularly to stay informed about the latest privacy policy. We will also archive old versions of the privacy policy for your reference.

For significant changes, we will provide more conspicuous notifications (including but not limited to emails, text messages, or special notices on browsing pages) to explain the specific changes to the privacy policy. Significant changes referred to in this Privacy Policy include, but are not limited to:

1. Significant changes in our product and/or service models, such as the purposes for which personal information is processed, the types of personal information processed, and the ways personal information is used.

2. Major changes in our ownership structure, organizational structure, etc., such as business adjustments, bankruptcy mergers, and other changes in ownership.

3. Changes in the main recipients of personal information sharing, transfer, or public disclosure.

4. Significant changes in your rights regarding personal information processing and the manner in which they can be exercised.

5. Changes in the department responsible for handling personal information security, contact methods, and complaint channels.

6. When a personal information security impact assessment report indicates high risks.

VIII. How to Contact Us

If you believe your personal information rights have been violated, or if you have clues of personal information rights infringement and wish to complain or report, or if you have any questions, comments, or suggestions regarding this Privacy Policy, or any privacy complaints or rights requests, you can contact us through the following means:

Contact Email: toppal@txzing.com

IX. Dispute Resolution

The signing, performance, interpretation, and dispute resolution of this agreement shall be governed by the laws of the People's Republic of China.

The place of signing this agreement is Nanshan District, Shenzhen. In the event of a dispute arising from this agreement, either party should first send a communication letter to the other party to resolve the dispute through communication and negotiation. If the dispute remains unresolved 60 days after the other party receives the communication letter, either party has the right to submit the dispute to the people's court with jurisdiction in the place where the agreement was signed for resolution through litigation. The losing party shall bear reasonable costs of litigation such as court fees and attorney fees.

If any provision of this agreement is deemed invalid or unenforceable, such provision shall be deemed severable and shall not affect the validity and enforceability of the remaining provisions of this agreement.

Supplementary Provisions: Definitions

Personal Information: Refers to various information related to an identified or identifiable natural person recorded electronically or by other means, including but not limited to a natural person's name, date of birth, identification numbers, personal biometric information, address, telephone number, etc., excluding information that has been anonymized.

Sensitive Personal Information: Refers to personal information that, once leaked or illegally used, can easily harm the dignity of natural persons or endanger their personal and property safety, including biometric, religious beliefs, specific identities, medical health, financial accounts, travel tracks, and personal information of minors under fourteen years of age.

Log Information: Refers to the content you post and browse while using our products and/or services, including the time, type, original network address, target address, port, access date and time, and login IP information.

Device Information: Includes device identifiers (IMEI/Android ID/IDFA/IDFV/OPENUDID/OAID/GUID/IMSI), network device hardware address (MAC address), device parameters and system information (device type, model, operating system, screen resolution, and related hardware information), and device network environment information (IP address).