Last Updated: April 7, 2025
Effective Date: April 7, 2025

    [Preface]This Privacy Policy applies to the Fleet APP mobile application (hereinafter referred to as "the App") provided by Jiangsu Sea-Level Data Technology Co., Ltd. (hereinafter referred to as "our Company").
    We understand the importance of your personal information and are committed to protecting its security and reliability. We strive to maintain your trust by adhering to the following principles: accountability, purpose limitation, consent, data minimization, security, individual participation, and transparency. We also pledge to implement industry-standard security measures to safeguard your personal information.
    To better protect your personal information, we recommend that you carefully review this updated Privacy Policy. If you have any questions or objections, please contact us using the methods provided in Section 9.

1.How We Collect and Use Your Personal Information
1.Definition of Personal Information and Personal Sensitive Information
Personal information refers to various types of information recorded electronically or in other ways that can be used alone or in combination with other information to identify the identity of a specific natural person or reflect the activities of a specific natural person. The specific types of personal information collected by our company shall be subject to the following description. Personal sensitive information refers to personal information that, once leaked, illegally provided, or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. The specific types of personal sensitive information collected by our company shall be subject to the following description.
2. How does our company collect and use your personal information
(1) Register and Login
When you create and log in to the client, you need to provide your email number and password.
(2) Mobile phone diagnosis
When you use the mobile diagnosis feature, our company collects your phone’s brand, model, Android system version, unique device identification number, network status, screen size, memory usage, app user information, carrier, IP address, DNS server address, which are used for error collection and bug diagnosis of your mobile client.
Product Adaptation
In order for our company’s products to be compatible with your device, we will collect your unique device identification number, operating system name, and version.
3.You understand and agree that in the following situations, our company does not need to obtain your authorization or consent for the collection and use of your personal information:
(1) Our company fulfills its obligations as stipulated by laws and regulations;
(2) Directly related to national security and defense security;
(3) Directly related to public safety, public health, and major public interests;
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(5) For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain your authorization and consent;
(6) The information related to you is disclosed to the public by yourself;
(7) Necessary to sign and fulfill the contract according to your request;
(8) Collecting your personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;
(9) Necessary for maintaining the safe and stable operation of our Fleet APP products or services, such as discovering and handling product or service failures;
(10) Other circumstances stipulated by laws and regulations.

2.Permission Usage Statement
To provide complete services, we will dynamically request related permissions while the app is running. Under the premise of ensuring normal functionality, we may request the following sensitive permissions from you:
1.Camera permissions (android. permission. CAMERA)
a) My avatar setting function: mainly used when taking a photo with the camera as an avatar
b) Vehicle Management - Vehicle Terminal - Module - Scan Activation Code: Mainly used by scanning barcodes with a camera, but you can also manually enter them
2. Accurate positioning permissions(android.permission.ACCESS_FINE_LOCATION)
a) Location page: When you bind a terminal and enter the location page, or click on "My Location" on the location page, we will request this permission from you, mainly for displaying your location information on GoogleMap.

3.How does our company use cookies and similar technologies
To collect the aforementioned personal information, both our company and authorized third-party partners may use technologies to understand and remember your specific usage preferences, providing you with a more personalized experience through the following technologies:
1.Cookie:To ensure the normal operation of the client, our company will store small data files called cookies on your mobile device. Cookies typically contain identifiers, site names, as well as some numbers and characters. With the help of cookies, websites can store your preferences and other data. Our company will not use cookies for any purposes other than those stated in this privacy policy. You can manage or delete cookies according to your preferences.

4. How Our Company Shares, Transfers, and Discloses Your Personal Information
1. Sharing
Our company will not share your personal information with any company, organization, or individual outside of our company, except in the following circumstances:
(1) We have obtained your explicit authorization or consent in advance;
(2) According to applicable laws, regulations, legal procedures, mandatory government orders, or judicial rulings, it is necessary to share your personal information;
(3) Within the scope required or permitted by law, it is necessary to provide your personal information to third parties in order to protect the interests, property, or safety of the company, its users, or the general public from harm;
(4) Your personal information may be shared between our affiliated companies. Our company will only share necessary personal information, and this sharing is also subject to the purpose of this privacy policy statement. If the affiliated company wants to change the purpose of processing personal information, it will seek your authorization and consent again;
(5) To achieve the purposes stated in this privacy policy, certain services of our company will be provided by authorized partners. Our company may share some of your personal information with partners to provide better customer service and user experience. For example, when distributing physical prizes, our company must share your personal information with logistics service providers in order to arrange delivery, or arrange for partners to provide services. Our company will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary for providing services. Our company's partners have no right to use the shared personal information for any other purpose. If you refuse our company's partners to collect personal information necessary for providing services, it may result in you being unable to use the third-party service in the client. Our company's authorized partners include the following types:
①Partners entrusted by our company for information promotion and advertising: You confirm that our company has the right to share the indirect user profiles, de-identified or anonymized statistical/analytical information created using your relevant information with partners entrusted for information promotion and advertising to help them with advertising, decision-making suggestions, improving advertising effectiveness, and further understanding user needs. Our company promises that, without your consent, we will not share personal information that can identify your identity.
2. Transfer
Our company will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
(1) After obtaining your explicit consent, our company will transfer your personal information to other parties;
(2) When it comes to mergers, acquisitions, or bankruptcy liquidation, if there is a transfer of personal information, our company will require the new company or organization holding your personal information to continue to be bound by this privacy policy. Otherwise, our company will require the company or organization to seek your authorization and consent again.
3. Public disclosure
Our company will only publicly disclose your personal information under the following circumstances:
(1) After obtaining your explicit consent;
(2) Legal Disclosure: Our company may publicly disclose your personal information in the event of legal, procedural, litigation, or mandatory requirements from government regulatory authorities.

5. How does our company protect your personal information
1. Our company has implemented security measures that comply with industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. Our company will take all reasonable and feasible measures to protect your personal information. For example, our company uses encryption technology to ensure the confidentiality of data; Our company will use trusted protection mechanisms to prevent data from being maliciously attacked; Our company will deploy access control mechanisms to ensure that only authorized personnel can access personal information; And our company will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
2. Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that in the Internet industry, even if we try our best to strengthen the security measures, it is impossible to always guarantee the security of information 100% due to technical restrictions and possible malicious means. Our company will try our best to ensure the security of the personal information you provide us.
3.You acknowledge and understand that the system and communication network you use to access our company's services may encounter issues due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to using complex passwords, regularly changing passwords, and not disclosing your account password and related personal information to others.

6. Your rights
According to relevant laws, regulations, standards in China, as well as common practices in other countries and regions, our company guarantees that you exercise the following rights over your personal information:
1.Accessing your personal information
You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise your data access rights, you can access them yourself through the following methods:
(1)Access basic information such as avatar, nickname, gender, birthday, etc.:
①After entering the client, click on 'Mine'
②Click on the avatar bar
③Conduct information queries and access
2. Correct your personal information
When you discover that there are errors in the personal information processed by our company regarding you, you have the right to request our company to make corrections. You can submit a correction request through the methods listed in "Accessing Your Personal Information".
3. Delete your personal information
In the following situations, you can request the deletion of personal information from our company:
(1) If our company's handling of personal information violates laws and regulations;
(2) If our company collects and uses your personal information without your consent; (3) If our company's handling of personal information violates our agreement with you;
(4) If you no longer use our company's products or services, or if you cancel your account；
(5) If our company no longer provides you with products or services.
If our company decides to respond to your deletion request, we will also notify the entities that have obtained your personal information from our company to delete it in a timely manner, unless otherwise stipulated by laws and regulations or these entities have obtained your independent authorization.
When you delete information from our company's services, our company may not immediately delete the corresponding information from the backup system, but will delete this information when the backup is updated.
4. Withdrawal of consent
You can change the scope of your authorization for our company to continue collecting personal information or revoke your authorization by disabling the device function. You can also revoke all authorization for our company to continue collecting your personal information by canceling your account.
5. Exit account
You can log out of the previously registered account at any time by following the steps below:
(1) After entering the client, click on 'Mine'
(2) Click on 'My Settings'
(3) Click on 'Log Out'
After logging out of the account, our company will cease to provide you with products or services, except as otherwise provided by laws and regulations.
In the following situations, as required by laws and regulations, our company will not be able to respond to your request:
(1) Directly related to national security and defense security;
(2) Directly related to public safety, public health, and major public interests;
(3) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(4) There is sufficient evidence to suggest that you have subjective malice or abuse of power;
(5) Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests;
(6) Involving trade secrets.
6. Cancel account
You can cancel the previously registered account at any time. After the account is cancelled, the relevant information of the original account will be cleared and cannot be retrieved, and the following operations cannot be performed:
(1) Personal information, historical information, vehicle records, etc. in the account will be cleared;
(2) The rights in the account will be cancelled, and the purchased service products will be deemed as automatically forfeited;
In the following situations, according to legal and regulatory requirements, our company may not be able to respond to your request:
(1) Directly related to national security and defense security;
(2) Directly related to public safety, public health, and major public interests;
(3) Related to criminal investigation, prosecution, trial, and execution of judgments;
(4) There is sufficient evidence to suggest that you have subjective malice or abuse of power;
(5) Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests;
(6) Involving trade secrets.
Cancel operation
Click on the "Settings icon in the upper left corner - General settings - Account security - Cancel account", and then click "Confirm cancellation".

7. How Our Company Handles Children's Personal Information
Our products, websites, and services are primarily intended for adults. Children are not allowed to create their own user accounts without the consent of a parent or guardian.
In cases where personal information of children is collected with parental consent, our company will only use or disclose this information when legally permitted, with the explicit consent of the parents or guardians, or when necessary to protect the child.
Although the definition of a child may vary according to local laws and customs, our company considers anyone under the age of 18 as a child.
If our company discovers that it has collected personal information of a child without first obtaining verifiable parental consent, we will make efforts to delete the relevant data as soon as possible.

8. How This Privacy Policy is Updated
Our company's privacy policy may change. Without your explicit consent, we will not reduce the rights you are entitled to under this privacy policy. We will publish any changes made to this privacy policy on this page. For significant changes, we will provide more prominent notifications. Significant changes to this privacy policy include, but are not limited to:
1、Significant changes in our service model, such as changes in the purpose of processing personal information, types of personal information processed, or the way personal information is used;
2、Significant changes in our company’s ownership structure or organizational structure, such as changes in ownership due to business adjustments, bankruptcy, or mergers and acquisitions；
3、A change in the main parties with whom personal information is shared, transferred, or disclosed;
4、A significant change in your rights related to the processing of personal information and how these rights can be exercised;
5、Changes in the department responsible for personal information security, contact information, or complaint channels
6、When personal information security impact assessment reports indicate a high level of risk.
Our company will also archive previous versions of this privacy policy for your reference.

9. How to Contact Our Company
If you have any questions, comments, or suggestions regarding this privacy policy, you can contact our company through the following methods. Generally, we will respond to you within 15 working days.
Email：4001887999@sea-level.com.cn
Phone：+86-025-52316655

10. Dispute Resolution
Any disputes arising from or related to this privacy policy shall be submitted to the competent court in the place of signing this agreement (i.e., Nanjing, Jiangsu) for litigation.