Shuobin New Energy

1. Controller and Contact Information

Controller: Xuzhou Shuobin New Energy Technology Co., Ltd

Office Address: 1110, Building 2, Yixiang Community, South of Zixia Road, Zizhuang Town, Jiawang District, Xuzhou, 221000, CN

Website: shuobinx.com

Business Support Email: support@shuobinx.com

Key Accounts Email: maxuesong@shuobinx.com

2. Scope of Covered Services

Our services include, but are not limited to, the following business and app modules:

• New energy technology development.
• Technical consulting, technical services, and technology transfer.
• Energy storage technology services.
• Photovoltaic equipment and component sales, installation, and maintenance.
• Wind power generation equipment sales.
• Charging pile and charging facility sales, installation, and operation services.
• Accumulator battery and lithium battery sales and technical services.
• Power transmission, distribution, and control equipment sales.
• Electromechanical equipment sales.
• Energy-saving and environmental protection equipment sales.
• New energy vehicle and accessory sales.
• Battery recycling technical consulting.
• Energy-saving technology promotion services.
• Contract energy management.
• Hardware products, building materials, and labor protection supplies sales.
• Domestic trade agency.

3. Data We Collect

Category	Examples	Purpose	Retention Principle
Account and identity data	Name, business role, enterprise identifier, login credentials, account IDs	Account creation, authentication, authorization, customer support	Retained while account is active and as required by law or contract
Contact data	Email, service contact history, support tickets	Communication, technical support, key account services	Based on support lifecycle and legal obligations
Device and app data	IP address, OS version, device model, language, app version, crash logs, diagnostics	Security, troubleshooting, performance optimization	Retained for the shortest period needed for stability and auditability
Usage and event data	Feature usage, timestamps, interaction flows, service logs	Service analytics, product improvement, operations management	Aggregated or deleted according to schedule
Location and infrastructure data	Approximate location, facility region, charging or equipment site metadata	Dispatch, maintenance, map visualization, service routing	Minimized and retained according to operational need
Commercial and transaction data	Order records, contract references, billing metadata	Contract performance, finance, legal compliance	Retained per accounting and legal retention periods
Advertising and attribution data	Advertising ID, consent signals, campaign source, impression/click/conversion events	Monetization, fraud prevention, measurement, capping	Controlled by consent and platform policy

4. Legal Bases for Processing

Depending on jurisdiction, we process personal data based on:

• Performance of a contract.
• Legitimate interests (service security, product improvement, fraud prevention, enterprise operations).
• Consent (for certain cookies, personalized advertising, optional analytics, and specific tracking technologies).
• Compliance with legal obligations (tax, accounting, regulatory, and law-enforcement cooperation where lawful).
• Protection of vital interests and public-interest tasks where applicable by law.

5. App Store and Platform Compliance

• Google Play: We provide data safety disclosures, identify collected/shared data categories, define processing purpose, and support deletion requests where applicable.
• Apple App Store: We provide App Privacy details, nutrition-label style disclosures, ATT-related behavior handling, and in-app privacy access points.
• Store metadata and in-app disclosures are maintained to reflect actual data behavior and SDK integrations.
• We monitor policy updates and implement remediation windows for policy enforcement cycles.

6. Advertising, Monetization, and SDK Compliance

Our applications may integrate ad monetization and mediation services where legally permitted and contractually configured. Typical ad formats include splash ads, rewarded video ads, interstitial ads, and banner ads.

Potentially integrated platforms may include: Google AdMob, Google Ad Manager, Unity Ads, AppLovin MAX, ironSource, Meta Audience Network, Mintegral, Pangle, Liftoff Monetize (Vungle), InMobi, Chartboost, Smaato, Start.io, Digital Turbine Exchange, Moloco, BidMachine, and other equivalent approved providers or mediation partners.

• Consent management may use compliant frameworks such as Google UMP and IAB TCF where applicable.
• Ad identifiers and related signals are processed per user consent and platform policy.
• Regional limitations may disable personalized advertising and switch to contextual or limited ads.
• We maintain app-ads.txt transparency records for authorized digital sellers where required by integration architecture.
• Users can manage consent and ad preferences through in-app settings, OS settings, or platform-provided controls.

7. Cookies and Similar Technologies

We and our service providers may use cookies, SDK storage, local storage, beacons, and equivalent technologies for authentication, security, analytics, language preferences, and advertising performance measurement. Where required, we provide consent banners or controls prior to non-essential storage or tracking.

8. Regional Privacy Rights and Country/State Policy Adaptation

We adapt rights handling and disclosure behavior to market requirements, including but not limited to:

• European Economic Area and UK: GDPR and UK GDPR rights such as access, rectification, erasure, restriction, portability, objection, and withdrawal of consent.
• Switzerland: rights under Swiss data protection law.
• United States: CCPA/CPRA style rights for California and other state privacy laws where applicable (access, delete, correct, opt-out of targeted advertising or sale/sharing definitions where legally triggered).
• Canada: PIPEDA-aligned fair information principles and user access rights.
• Australia and New Zealand: APP/IPP-aligned handling and complaint channels where applicable.
• Any additional jurisdiction where our services are distributed: local legal requirements may apply and supersede conflicting sections to the extent required by mandatory law.

We do not discriminate against users for exercising lawful privacy rights.

9. Age Policy and Children Protection

• Our enterprise-facing services are generally intended for adults and authorized business users.
• We do not knowingly collect personal information from children where prohibited by law.
• For regions requiring child-specific protection (including COPPA-like requirements), features and ad behavior may be limited, disabled, or age-gated.
• If we become aware of unlawful child data processing, we will promptly delete or de-identify relevant data and implement corrective actions.

10. Data Sharing and International Transfers

• We may share data with processors and partners for hosting, analytics, customer support, payment and accounting, security, and ad mediation.
• We require contractual safeguards, confidentiality obligations, and security controls from vendors.
• Cross-border transfers may occur where operations, cloud infrastructure, or partners are global; safeguards may include standard contractual clauses or equivalent mechanisms.

11. Data Security

We use administrative, technical, and organizational safeguards including access controls, encryption in transit where feasible, security monitoring, segmentation, and incident response procedures. No system can guarantee absolute security, but we continuously improve controls based on risk.

12. Data Retention and Deletion

We keep personal data only as long as necessary for stated purposes, legal compliance, dispute resolution, and contract performance. After retention periods, data is deleted, anonymized, or irreversibly de-identified according to internal policy and legal allowances.

13. Your Rights and How to Exercise Them

For access, correction, deletion, objection, consent withdrawal, portability requests, or complaint submissions, contact us at support@shuobinx.com. We may request verification before processing requests and respond within legally required timelines.

14. Third-Party Links and Services

Our website and apps may link to or integrate third-party services. Third-party privacy practices are governed by their own policies. We recommend reviewing their disclosures before use.

15. Policy Updates

We may update this Privacy Agreement to reflect legal, technical, or business changes. Material updates will be published with revised effective dates and, where required, additional notice mechanisms.

16. Data Subject Request Workflow

Step	What We Do	Typical Outcome
Request intake	Receive requests through official contact channels and register the request.	Reference ID issued for tracking.
Identity verification	Validate requester identity and authorization scope.	Unauthorized or unclear requests are paused for clarification.
Scope determination	Identify systems, data categories, and legal basis related to the request.	Applicable rights and lawful limits are documented.
Execution	Perform access, correction, deletion, restriction, objection, or export actions as appropriate.	Data operations completed with audit trail.
Response closure	Provide written outcome and rationale, including reasons for any lawful refusal.	Request closed within required legal timeline.

17. International Transfer and Vendor Safeguards

• We evaluate recipient jurisdiction, transfer necessity, and proportionality before cross-border data transfer.
• We apply contractual safeguards, access controls, and confidentiality requirements to processors and partners.
• We review third-party vendor privacy commitments, security posture, and incident notification obligations periodically.
• Where required, transfer impact assessments or equivalent compliance checks are performed and recorded.

18. Security Incident and Breach Notification

• We maintain incident detection, triage, containment, remediation, and post-incident review procedures.
• In the event of a confirmed breach involving personal data, we notify relevant authorities and affected users when required by law.
• Notifications include known impact scope, protective recommendations, and remediation progress where available.
• We continuously improve controls after incidents through root-cause analysis and corrective action plans.