Politique de confidentialité

En vigueur : 13 décembre 2021

This Privacy Policy (the “PrivacyPolicy”) serves to inform you of our policiesand procedures regarding the collection, use and disclosure of the informationwe receive when you access and use the website (the “Site”), services, software, mobile applications, content, newsletter,and all other products and services (all of the foregoing collectively, the “Services”) owned, controlled oroffered, directly or indirectly, by OneKey Auto Corporation (togetherwith its subsidiaries and affiliates, “OneKey,” the “Company”, “we,” “our” or “us”). OneKey believes that the privacy of its usersis paramount and strives to use Personal Information (as defined below) only inways outlined in this Privacy Policy. ThePrivacy Policy is incorporated by reference into any Services Agreement enteredinto between you and OneKey. By usingthe Services, you hereby warrant and represent that you have read, understandand agree to this Privacy Policy and the Services Agreement, and that you areover 18 years of age. PLEASE DO NOT USE,INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

  1. What We Mean by Personal Information

For purposes of this Privacy Policy, “Personal Information” means any information from or about a personthat either identifies that person directly or that makes that personidentifiable when it is combined with other information from or about thatperson from any source.

  1. Information We Collect

Information You Provide To Us

When you use the Services or otherwise communicate with us, wecollect information that you provide to us directly. For example, we collect information in thefollowing circumstances: you (i) visit the Site; (ii) register for the Servicesor create an account or profile or accept the creation of an account or profileon your behalf (an “Account”); (iii)use or access the Services; (iv) subscribe to newsletters; (v) purchase aproduct or service on the Site; (vi) request technical support; (vii) otherwiseuse our online Services where Personal Information is required for such useand/or participation, (viii) when you sign up for a newsletter, and (ix) whenyou contact us via the Site or when you otherwise communicate with us. You can choose not to provide information that is requested of youby us; however, this may limit your ability to use or access the Services.

The information you provide to us directly may include, withoutlimitation, the following information that may, alone or in combination withother data, constitute Personal Information:

· Informationyou provide in connection with registering an account or completing atransaction or purchase using the Services, including your name, company name, e-mail,physical address, phone number, and any other information you decide toprovide;

· Informationyou provide via email, through the “Contact” section on the Site or by usingthe contact details listed on various parts of the Site, including your name,e-mail, phone number, company name, location, inquiry, details regarding youractual or proposed charging site, and any other information you decide toprovide;

· Informationyou provide in order to subscribe to our newsletters and updates, includingyour email address, the topic for which you wish to receive updates, or anyother information you decide to provide us with. You may always unsubscribefrom these emails by following the instructions included;

· Ifyou are one of our customers, suppliers or prospects, we may process limitedPersonal Information in the course of our business relation with you, forexample when you place an order, request a demo or vice versa. Such PersonalInformation may include your name, company, title, e-mail address, telephonenumber, physical address, and order details;

· Transactionand limited (non-PCI) payment data; and

· Any otherinformation you may want to share with us, such as Personal Information relatedto recruitment / job applications.

Moreover, if you contact us, a recordof such correspondence may be kept.

Additionally, ifanother user refers you to us by providing us with your e-mail address, we maysend you a message. However, we will useyour e-mail address only to send such other user’s message unless you otherwiseaffirmatively provide your information to us.

Automatically Collected Information

Most of the datawe collect in and through the Services is technical in nature and is collectedand processed automatically through so-called application programminginterfaces, software development kits, cookies and similar software-basedtechnologies. Alone or in combination with other data, such automaticallycollected data may constitute Personal Information. The data we may collect byautomated means may include, without limitation:

· Device data: including, but not limited to,data on device advertising ID’s and similar hardware qualifiers, and preciselocation data.

· Usage data: including, but not limited to,search terms entered and pages viewed.

· Network and internet information: including,but not limited to, URLs, Internet Protocol addresses, bounce rates, use ofspoofing, active (TCP/IP) ports, number of sessions initiated, click streams,location information and network/Wi-Fi access points.

· Information we collect on the use of the Sitevia cookies: please see the “How We Use Cookies and Other Technologies” sectionbelow for more information.

Google Analyticsis an element of the Site. By using cookies, Google Analytics collects andstores data such as time of visit, pages visited, time spent on each page of theSite, the Internet Protocol address, and the type of operating system used inthe devices used to access the Site. By using a browser plugin available athttp://www.google.com/ads/preferences/plugin/ provided by Google, you can optout of Google Analytics.

Information YouShare on Third Party Websites or through Social Media Services

The Services mayinclude links to third party websites and social media services where you willbe able to post comments, stories, reviews or other information. Your use ofthese third-party websites and social media services may result in thecollection or sharing of information about you by these third party websitesand social media services. We encourage you to review the privacy policies andsettings on the third party websites and social media services with which youinteract to make sure you understand the information that may be collected, used,and shared by those third party websites and social media services.

How We Use Cookies and Other Technologies

Some of thefeatures in the Services require the use of “cookies” - small text files thatare stored on your device’s hard drive. We use cookies to measure which pagesare being accessed, and which features are most frequently used. This enablesus to continuously improve the Site to meet the needs of our visitors.

The followingsets out how we may use different categories of cookies and your options formanaging cookie settings:

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate the Site and use their features, such as accessing secure areas of the Site and using the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.

Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.

Functionality cookies

Functionality cookies allow our Sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.

To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.

Targeting or advertising cookies

From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Site. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Site. By way of example, as you browse the Site, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Site. Third parties, with whom we partner to provide certain features on the Site or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.

To learn more about these and other advertising networks and their opt out instructions, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.

We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of users, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates. Our advertisement partners may use a “pixel tag” to collect anonymous information about your visits to the Site and to other websites, and they may use that information to target advertisements for goods and services. This information is collected anonymously, ina manner that does not personally identify you.

  1. Use of Collected Information

We use the information you provide to us for the following purposes: (i) to further our legitimate interests in providing the Services, including without limitation to collect and remit payment for paid features, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi) to enforce our Terms of Service, (vii) to resolve any disputes between users of the Site or between such users and us, (viii)comply with a legal requirement or process, including, but not limited to,civil and criminal subpoenas, court orders or other compulsory disclosures; (ix)to further our legitimate interest in protecting our rights, property, or safety and the rights, property and safety of the Services, our users or the public, and (x) to contact you to obtain feedback from you regarding the Services.

In addition to the purposes described above, we use the information collected automatically to (i) to further our legitimate interests in monitoring and analyzing the use of the Services and for the technical administration of the Site, (ii) improve the Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify thatusers of the Services meet the criteria required to process their requests. We and or our advertising partners may use demographic and geo-location, as well as information logged from your hardware or device, including data such as IP address, device modeland ID, MAC address, operating system, application usage data, device time zone, region and language, and click ID, to ensure relevant advertising is presented within the Services.

  1. Third Parties We Share Personal Information With

We may disclose Personal Information you provide to us or that we collect automatically in and through the Services with the following categories of third parties:

· Service providers, such as payment processors, web hosting and data storage service providers, and helping us deliver and develop the Services. data storage service providers, marketing service providers, and communications service;

· Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and

· Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

  1. Links to Other Websites

You may opt to link your Account to your social media account or other accounts, such as Google, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to the Services. We do not exercise control over third party services or other websites that provide information, or links from within the Site or the Services. Your interactions with these third-party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on yourcomputer’s browser, collect data or solicit Personal Information from you. Other websites and services follow different rules regarding the use ordisclosure of the Personal Information that you submit, and the collection anduse of such information and access of any third-party websites are subject tosuch third party’s privacy policy. Weencourage you to read the privacy policies and other terms of such thirdparties before using their services.

  1. Security

We understand theimportance of privacy and security of Personal Information to our users andhave made them a priority. Stable uses a variety ofindustry-standard security technologies and procedures to help protect PersonalInformation about you from unauthorized access, use, or disclosure and trains Stableemployees on privacy and security issues. However, we cannot guarantee thatunauthorized third parties will never be able to overcome those measures or useyour Personal Information for improper purposes, and we do not promise thatPersonal Information about you or private communications will be protected fromunauthorized disclosure or use.

  1. Do Not Track Signals and Similar Mechanisms

Stable does nottrack its customers over time and across third party websites to providetargeted advertising and therefore does not respond to Do Not Track (DNT)signals.

  1. Managing Your Privacy

We keep your dataon your behalf and for your benefit. You can correct or terminate and deleteyour Account information by following the instructions on the Services or bye-mail, which you mayalso access for further assistance and questions regarding the Privacy Policyor for a copy of your Account data. If you cancel your Account or request us todelete your information, Stable will limit its access to Personal Informationto perform what is requested by you and will delete information accessible to Stablewithin seven business days.

  1. Your Rights

We take steps tohelp ensure that you are able to exercise your rights regarding PersonalInformation about you in accordance with applicable law. If you would like toaccess, review, erase, withdraw your consent, or object to, or restrict theprocessing of Personal Data we collect about you, you may submit a reques. We willpromptly review all such requests in accordance with applicable laws. Dependingon where you live, you may also have a right to lodge a complaint with asupervisory authority or other regulatory agency if you believe that we haveviolated any of the rights concerning Personal Information about you. We encourage you to first reach out to u, so we have anopportunity to address your concerns directly before you do so.

  1. California Residents

California Civil Code Section 1798.83 requires certain businessesthat share customer Personal Information with third parties for the thirdparties’ direct marketing purposes to respond to requests from Californiacustomers asking about the businesses’ practices related to suchinformation-sharing. We currently do not share or disclose your PersonalInformation to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, wewill implement an opt-out policy as required under California laws.

Furthermore, subject to certain exemptions,California residents have the following rights with respect to PersonalInformation we may have collected about them:

Requests to Know

You have the right to request that wedisclose:

The categories of Personal Information we have collected about you;
The categories of Personal Information about you we have sold or disclosed for a business purpose;
The categories of sources from which we have collected Personal Information about you;
The business or commercial purposes for selling or collecting Personal Information about you;
The categories of Personal Information sold or shared, if any, about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
The specific pieces of Personal Information collected. The delivery of our response may take placeelectronically or by mail. We are not required to respond to requests to knowmore than twice in a 12-month period.

Requests to Delete

You have the right to request that we deleteany Personal Information about you that we have collected. Upon receiving averified request to delete Personal Information, we will do so unless otherwiserequired or authorized by law. You may submit a request to delete PersonalInformation

Right to Opt Out of the Sale of PersonalInformation]

You have a right to opt out of the sale ofPersonal Information. You may, at any time, direct us to not sell PersonalInformation about you to third parties. If you exercise your right to opt out of the sale of PersonalInformation about you, we will not sell Personal Information about you. Any PersonalInformation collected in connection with your request to opt-out of the sale ofPersonal Information about you will be used only to facilitate that request.You may opt out of the sale of

Categories of Personal Data the We Have Soldin the Last 12 Months

We have sold the following categories ofPersonal Data during the last 12 months:

· Internet or other electronic networkactivity information: Browsing history, search history, andinformation regarding a consumer’s interaction with an Internet website,application, or advertisement

· Inferences: Inferences that could be used to create a profile reflecting aconsumer’s preferences, characteristics, psychological trends, predispositions,behavior, attitudes, intelligence, abilities or aptitudes.

Authorized Agents

You may designate an authorized agent to makerequests on your behalf. You must provide an authorized agent writtenpermission to submit a request on your behalf, and we may require that youverify your identity directly with us. Alternatively, an authorized agent thathas been provided power of attorney pursuant to Probate Code sections 4000-4465may submit a request on your behalf.

Methods for Submitting Consumer Requests andOur Response to Requests

Upon receipt of a request, we may ask you foradditional information to verify your identity. Any additional information youprovide will be used only to verify your identity and not for any otherpurpose.

We will acknowledge the receipt of yourrequest within 10 days of receipt. Subject to our ability to verify youridentity, we will respond to your request within 45 days of receipt. If werequire more time (up to 90 days), we will inform you of the reason andextension period in writing. In order toprotect your privacy and the security of Personal Information about you, weverify your request by email and video or teleconference.

Any disclosures we provide will only coverthe 12-month period preceding the verifiable consumer request's receipt. Theresponse we provide will also explain the reasons we cannot comply with arequest, if applicable.

We do not charge a fee to process or respondto your verifiable consumer request unless it is excessive, repetitive, ormanifestly unfounded. If we determine that the request warrants a fee, we willtell you why we made that decision and provide you with a cost estimate beforecompleting your request.

The Right to Non-Discrimination

You have the right not to be discriminatedagainst for the exercise of your California privacy rights described above.Unless permitted by the CCPA, we will not:

· Deny you goods or services;

· Charge you different prices or rates forgoods or services, including through granting discounts or other benefits, orimposing penalties;

· Provide you a different level or quality ofgoods or services; or

· Suggest that you may receive a differentprice or rate for goods or services or a different level or quality of goods orservices.

  1. International Transfers of PersonalInformation

Stable is based in the United States. As a result, Personal Information that wecollect in and through the Services and on the Site may be transferred to ourU.S. offices. In addition, we may work with third-party service providers inthe U.S. and in other countries to support our business activities. Thus,Personal Information may be transferred to, stored on servers in, and accessedfrom the United States and countries other than the country in which thePersonal Information was initially collected. In all such instances, we use,transfer, and disclose Personal Information solely for the purposes describedin this Privacy Notice and in compliance with applicable laws.

  1. Data Retention

We keep Personal Information related to yourAccount for as long as it is needed to fulfill the purposes for which it wascollected, to provide our services, to deal with possible legal claims, tocomply with our business interests and/or to abide by all applicable laws.Thereafter, we either delete Personal Information about you or de-identify it.Please note that even if you request the deletion of Personal Information aboutyou, we may be required (by law or otherwise) to retain the PersonalInformation and not delete it. However, once those requirements are removed, wewill delete Personal Information about you in accordance with your request.