DOGO APP Privacy Policy

Introduction

Welcome to our products and services! We understand that your personal information is important to you, and your trust is critical to us. We will strictly comply with legal and regulatory requirements and take appropriate security measures to protect your personal information and keep your personal information secure and under control. Based on this commitment, DOGO APP Service Provider (or 'We') has developed this DOGO APP Privacy Policy (hereinafter referred to as 'this Policy' or 'this Privacy Policy') to help you fully understand how We collect, use, share, store, and protect your personal information, as well as how you can manage your personal information when using our products and services, so that you can make informed choices.

Before you start using our products and services, please carefully read and understand this Policy, especially the terms highlighted in bold. Please ensure that you fully understand and agree to this Policy before using our services. If you have any questions, comments, or suggestions regarding the content of this Policy, you may contact us through the contact information provided at the end of this Policy.

1. Scope of Application

This Policy applies to all products and services provided by us through the mobile client (APP) and any new forms that may emerge with technological development. If We or our affiliates have separately established a privacy policy for specific products or services provided to you, the relevant products or services shall be governed by that separate privacy policy.

Except for the information collection and use activities described in this Policy, this Policy does not apply to other services provided by third parties other than us. Such other services are governed by their respective personal information collection and use rules separately notified to you.

When you use this Platform through an account assigned by your enterprise administrator, your enterprise or organization (i.e., the entity to which your Administrator belongs) is the primary controller of your personal information and is responsible for determining the purposes and means of processing. As a technology service provider, We will process your personal information as a processor based on the agreement with your enterprise administrator and your instructions. This Policy is intended to explain our data processing practices as a processor in the course of providing services.

2. Information Collection and Use

When you use our products/services, the personal information We need/may need to collect and use falls into the following two categories:

1. Essential information that you must authorize us to collect and use in order to provide you with the basic functions of our products and/or services. If you refuse to provide such information, you will not be able to use our products and/or services normally.

2. Additional information that you may choose to separately consent to or decline the collection and use of, in order to provide you with additional features of our products and/or services. If you refuse to provide such information, you will not be able to use the relevant additional features or achieve the intended functional effects, but this will not affect your use of the basic functions.

The specific functional scenarios We provide to you include:

(A) Helping You Become Our User and Account Management

1. Account Activation

APP accounts are created on the EMS energy management backend by the Platform operator or your enterprise administrator (hereinafter referred to as “Administrator”) on your behalf. When activating an account, the Administrator shall provide your necessary information (including but not limited to your phone number or email address). After activation, the system will send an activation link or verification code to the phone number or email address. You must follow the instructions to complete initial identity verification and set a password before the account becomes officially active. You warrant that the identity information you provide is true, accurate, and valid. If you represent an enterprise user, the Administrator is responsible for ensuring the authenticity of all user information entered.

If your account is created by an Administrator on your behalf, your Administrator should have obtained your authorization before creating the account. We will create the account based on the information provided by the Administrator and will make this Privacy Policy available to your Administrator to present to you prior to account activation. Your first login to the APP shall be deemed as your having read and agreed to all terms of this Policy.

After creating the account, the Administrator will assign you an English account name and an initial login password. You can log in to the Platform using the assigned account name and password. The Administrator has the right to manage your account permissions within the Administrator’s organization, including but not limited to changing your password, suspending or deleting your account, and determining the scope of data you can access. For the Administrator's management actions regarding your account, please contact your enterprise Administrator. We will provide necessary assistance as directed by the Administrator.

2. Account Management

After logging in, you may voluntarily set your personal profile information such as nickname and avatar. You may also fill in enterprise information such as company name, dealer name, and installer name, so that We can associate power station management with your enterprise identity. Failure to provide this information will not affect your use of the basic functions of the APP.

You are obligated to properly safeguard your account and password. Any risks arising from account disclosure shall be borne by yourself.

Authorized Login: With your separate consent, We may provide your account information (avatar, nickname, and other information as prompted on the page) to third parties, enabling you to conveniently register for third-party accounts or log in directly from third-party platforms. We will use your relevant information only within the scope of your separately granted authorization.

(B) Providing You with Power Station Management and Equipment Monitoring Services

To provide you with power station management services, We will collect and use your enterprise information and power station information as follows:

To provide you with equipment monitoring services, We will collect and use your device information as follows:

(C) Providing Security Protection and Log Recording

To fulfill legal obligations related to network security and to enhance the security of services provided by us, our affiliates, and partners, and to protect your or other users' or the public's personal and property safety from harm, We will collect your log information as follows:

(D) Customer Service and Dispute Handling

When you contact us or submit applications for pre-sale, after-sale, or dispute resolution, We may need you to provide necessary personal information to verify your identity in order to protect your account and system security.

To facilitate communication with you, help resolve your issues as quickly as possible, or record the processing plans and results of related issues, We may retain our communication, correspondence/phone call records and related content with you (including account information, other information you provide to prove relevant facts, or your contact information).

(E) Other Additional Services

1. Additional Services Based on System Permissions

To provide you with more convenient and higher-quality products and/or services and to enhance your experience, We may enable system permissions to collect and use your personal information in connection with the following additional services. If you do not consent to enabling the relevant permissions, this will not affect your use of the basic services of DOGO APP, but you may not be able to enjoy the user experience brought by these additional services.

You may enable or disable these permissions at any time at your discretion.

System Permission Table

PLEASE NOTE THAT ENABLING ANY PERMISSION MEANS YOU AUTHORIZE US TO COLLECT AND USE THE RELEVANT PERSONAL INFORMATION TO PROVIDE YOU WITH THE CORRESPONDING SERVICE. DISABLING ANY PERMISSION MEANS YOU WITHDRAW THAT AUTHORIZATION, AND WE WILL NO LONGER COLLECT AND USE THE RELEVANT PERSONAL INFORMATION BASED ON THAT PERMISSION, NOR CAN WE CONTINUE TO PROVIDE YOU WITH THE SERVICE CORRESPONDING TO THAT PERMISSION. YOUR DECISION TO DISABLE A PERMISSION WILL NOT AFFECT THE INFORMATION COLLECTION AND USE CONDUCTED BASED ON YOUR PRIOR AUTHORIZATION.

2. Cookie and Similar Technology Services

Cookies and similar device identification technologies are commonly used on the Internet. When you use our services, We may use related technologies to send one or more cookies or anonymous identifiers (hereinafter “Cookies”) to your device in order to collect, identify, and store information about your access to and use of this product. We undertake not to use Cookies for any purpose other than those described in this Privacy Policy. We use Cookies primarily to ensure the secure and efficient operation of our products and services, to help us verify the security status of your account, to identify anomalies such as crashes or delays, and to save you from having to repeatedly fill in forms or enter search terms.

Most browsers provide users with the functionality to clear browser cache data. You may perform such data clearing operations, or modify your acceptance level or reject our Cookies. These modifications may prevent you from using services or features that rely on Cookies.

3. Partners Involved in Data Use, and Transfer and Disclosure of Personal Information

(A) Partners Involved in Data Use

1. Basic Principles

When cooperating with partners, We will adhere to the following principles:

1) Legality, Legitimacy, and Minimum Necessity: Data processing shall have a legal basis and a legitimate purpose, and shall be limited to the minimum scope necessary to achieve the processing purpose.

2) Maximization of User Right to Know and Decide: During data processing, users' right to know and decide regarding their personal information processing shall be fully respected.

3) Maximization of Security Capability: We will take necessary measures to ensure the security of processed personal information, carefully evaluate the purposes for which partners use data, comprehensively assess the security capabilities of such partners, and require them to comply with the requirements of cooperation agreements.

2. Scope of Partners

If the specific functions and scenarios involve services provided by our affiliates or third parties, the scope of partners includes our affiliates and third parties.

3. Entrusted Processing

We may entrust authorized partners to process your personal information so that they can provide certain services or perform certain functions on our behalf. We will only entrust them to process your information for the lawful, legitimate, necessary, specific, and explicit purposes stated in this Policy. Authorized partners will only have access to the information necessary to perform their functions, and We will require them through agreements not to use such information for any purpose beyond the scope of entrusted processing. If an authorized partner uses your information for purposes not entrusted by us, they will separately obtain your consent.

4. Cooperation Scenarios

1) Security Protection: To protect the legitimate rights and interests of APP users from unlawful infringement, our partners may use necessary device, account, and log information.

2) Product Analysis: To analyze the stability of APP products and/or services, partners providing analytical services may need to use information such as service usage, device identifiers, and overall application installation and usage.

3) Other Cooperation Scenarios: We may entrust information to other partners that support our business, including those providing technical infrastructure services, cloud services, push notification services, and analysis of service usage patterns.

To ensure the stable operation and functionality of our application and to enable you to use more services and features, our application may embed SDKs or other similar applications from authorized partners. We will conduct strict security testing on the application programming interfaces (APIs) and SDKs used by authorized partners to obtain information, and will agree on strict data protection measures with authorized partners, requiring them to process personal information in accordance with this Policy and any other relevant confidentiality and security measures, unless separately authorized by you.

You may refer to the Third-Party SDK Data Collection and Usage Notice for details on the SDKs integrated into our application.

(B) Transfer

If We need to transfer personal information due to merger, division, dissolution, or declaration of bankruptcy, We will inform you of the name and contact information of the recipient and obtain your separate consent. The recipient will continue to perform this Policy and other legal obligations. If the recipient changes the original processing purpose or methods, it will obtain your consent again.

(C) Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

1. We may publicly disclose your personal information based on your active choice and other separate consent;

2. If We determine that you have violated applicable laws or regulations or seriously breached the relevant agreements and rules of this APP, or to protect the personal and property safety of APP users or the public from harm, We may disclose your personal information, including information about the relevant violations and the measures We have taken against you.

(D) Cessation of Operations

If We cease operations of our products and/or services, We will promptly stop further collection of your personal information. We will notify you individually or by announcement, and will delete or anonymize the personal information We hold that is related to the discontinued products and/or services.

(E) Circumstances Exempt from Obtaining Your Authorization and Consent Under Law

Please understand that in the following circumstances, in accordance with laws and regulations and national standards, partners' use, or our transfer or disclosure of your personal information does not require your authorization:

1. Necessary for the conclusion or performance of a contract to which you are a party, at your request;

2. Necessary for the performance of legal duties or legal obligations: We may share your personal information as required by laws and regulations, litigation, dispute resolution, or as required by administrative or judicial authorities in accordance with the law, or as necessary for the performance of other legal obligations;

3. Necessary for responding to public health emergencies, or for protecting the life, health, or property of natural persons in emergency situations;

4. Processing of personal information within a reasonable scope for the public interest, such as news reporting and public opinion supervision;

5. Processing of personal information that you have made public yourself, or other personal information that has been lawfully made public (such as information lawfully made public through legitimate news reports, government information disclosure, etc.), within a reasonable scope;

6. Other circumstances provided by laws and regulations.

4. Your Rights

You may access and manage your information through the following methods. We will respond to your requests in accordance with applicable legal requirements:

(A) Access, Correction, and Supplementation

You have the right to access, correct, and supplement your information through the following methods:

• Log in to the APP, go to “My” → “Personal Information” to view and edit your personal information;
• Log in to the APP, go to “My” → “Power Stations” to view and edit your power station information.

(B) Deletion

You may delete some of your information through the methods described in subsection (A) of this Article, or apply to delete all of your information by applying for account deletion.

In the following circumstances, you may request us to delete your personal information by contacting our customer service:

1. If our processing of personal information violates laws or regulations;

2. If We collect or use your personal information without obtaining your explicit consent;

3. If our processing of personal information seriously violates our agreement with you;

4. If the processing purpose has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;

5. If We stop providing products or services, or if the retention period has expired.

For deletion requests submitted through customer service, We will complete the processing within 15 working days after verifying your identity and notify you of the result in the manner you specify.

If We decide to honor your deletion request, We will also notify the entities that have obtained your personal information from us to the extent possible and require them to delete it promptly (unless otherwise provided by law or unless such entities have independently obtained your authorization).

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 the corresponding information from backup systems. We will securely store your personal information and restrict any further processing until the backup can be cleared or anonymized.

(C) Changing the Scope of Authorization

You may change or withdraw your consent for us to collect and process your personal information through the following methods:

• Manage APP system permission authorizations under “My”→ “Settings”→ “Privacy Authorization Management”;
• Independently manage the enabling and disabling of application permissions in your device system settings;
• For authorizations that you cannot change directly through the above methods, you may contact customer service to make modifications.

HOWEVER, PLEASE NOTE THAT FOR CERTAIN TYPES OF PERSONAL INFORMATION, SUCH AS INFORMATION NECESSARY FOR THE BASIC FUNCTIONS OF THIS APP OR INFORMATION NECESSARY FOR US TO PERFORM OUR LEGAL OBLIGATIONS, WE MAY NOT BE ABLE TO RESPOND TO YOUR REQUEST TO CHANGE THE SCOPE OF AUTHORIZATION. WHEN YOU WITHDRAW YOUR AUTHORIZATION, WE WILL NO LONGER PROCESS THE CORRESPONDING PERSONAL INFORMATION. HOWEVER, YOUR DECISION TO WITHDRAW AUTHORIZATION WILL NOT AFFECT THE PERSONAL INFORMATION PROCESSING CONDUCTED BASED ON YOUR PRIOR AUTHORIZATION.

(D) Account Deletion

You may delete your account through the following method:

• Log in to the APP, go to “My” → “Settings” → “Account Security” → “Delete Account” and follow the instructions to complete the account deletion.

After you voluntarily delete your account, We will stop providing products or services to you and will delete or anonymize your personal information in accordance with applicable legal requirements.

(E) Responding to Your Requests

For requests made by you or your guardian, close relatives, or other entitled parties, as well as your rights regarding personal information under the Laws of the People's Republic of China and other applicable laws, you may contact us through customer service or file a complaint directly with our dedicated personal information protection department. We will respond within 15 days.

To protect the security of your account and personal information, when you submit the above requests to us, We may first verify your identity (e.g., through additional account verification, requiring you to submit a written request, or other reasonable means) before processing your request.

In principle, We do not charge fees for your reasonable requests. However, for repeated requests that exceed reasonable limits, We may charge a reasonable fee. We may reject requests that are not directly related to your identity, requests that are repeated without reasonable cause, or requests that require excessive technical effort (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are impractical.

5. Information Storage

(A) Retention Period

We will retain your personal information only for the period necessary to achieve the purposes described in this Policy, unless mandatory retention is required by applicable law.

We determine the retention period for personal information based on the following criteria:

1. Maintaining business records related to you to address potential inquiries or complaints from you;

2. Ensuring the security and quality of the services We provide to you;

3. Whether you have consented to a longer retention period;

4. Relevant needs based on statutes of limitations or dispute resolution;

5. Whether there are other special agreements or legal provisions regarding the retention period.

After the retention period expires, We will delete or anonymize your personal information in accordance with applicable legal requirements.

(B) Storage Location

Personal information collected and generated in the course of our operations in different countries and regions will be stored within those countries and regions, or at the server locations operated by partners providing cloud infrastructure services to us. The specific storage location will be determined based on the country or region where you are located and the data center locations involved in providing services to you. Personal information collected and generated in the course of our operations within the territory of the People's Republic of China will be stored within China.

If it is necessary to transfer your personal information to a jurisdiction outside the country or region where you are located due to business requirements, We will strictly comply with applicable data protection laws, fulfill notification obligations, obtain your separate consent, and complete the corresponding legal procedures (security assessment, standard contractual clauses, or protection certification) based on the type of data transfer, to ensure that your personal information receives a level of protection outside the country that is equivalent to that within the country. Unless We obtain your separate consent or the law provides otherwise, We will not transfer your personal information to jurisdictions that do not provide an adequate level of data protection.

(C) Storage Security

1. Technical Measures for Data Protection

We have adopted security protection measures that meet industry standards and are reasonably feasible to protect your information from unauthorized access, public disclosure, use, modification, damage, or loss. For example, We use encryption technologies to enhance the security of personal information; data exchanged between your client and server is encrypted and protected by SSL/TLS protocols; We use trusted protection mechanisms to prevent malicious attacks on personal information; and We deploy access control mechanisms to ensure, to the extent possible, that only authorized personnel can access personal information.

2. Organizational Measures for Data Protection Management

We have established a data security management system centered on data and structured around the data lifecycle, enhancing the security of personal information from the dimensions of organizational structure, system design, personnel management, and product technology. We have appointed a Data Protection Officer (Data Protection Officer/Data Protection Lead) and a dedicated department. Through training programs and assessments, We continuously strengthen our employees' awareness of the importance of protecting personal information.

3. Response to Personal Information Security Incidents

If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information, thereby causing damage to your legitimate rights and interests, We will promptly activate emergency response plans and take reasonably necessary measures to minimize the impact on you. In the event of a personal information security incident, We will, in accordance with applicable laws and regulations, inform you of the basic information about the security incident and its potential impact, the measures We have taken or will take, recommendations for you to independently prevent and mitigate risks, and remedial measures for you.

4. Prevention of Account Security Risks

Please properly safeguard your personal information and account credentials, and only provide your information to others when necessary to prevent theft of information or unauthorized use of your account. If you suspect that your personal information, especially your account or password, has been compromised, please contact our customer service immediately so that We can take appropriate measures based on your request.

6. Policy Updates

TO PROVIDE YOU WITH A BETTER PRODUCT AND SERVICE EXPERIENCE, WE CONTINUOUSLY STRIVE TO IMPROVE OUR PRODUCTS, SERVICES, AND TECHNOLOGIES. WHEN NEW SERVICES OR BUSINESS PROCESSES CHANGE, WE MAY UPDATE THIS PRIVACY POLICY TO INFORM YOU OF THE SPECIFIC CHANGES. HOWEVER, WITHOUT YOUR EXPLICIT CONSENT, WE WILL NOT RESTRICT THE RIGHTS YOU ENJOY UNDER THIS POLICY. WE WILL PUBLISH ANY CHANGES TO THIS POLICY ON A DEDICATED PAGE. FOR MATERIAL CHANGES, WE WILL ALSO PROVIDE MORE PROMINENT NOTICE (INCLUDING THROUGH APP POP-UPS OR IN-APP NOTIFICATIONS).

MATERIAL CHANGES REFERRED TO IN THIS POLICY INCLUDE BUT ARE NOT LIMITED TO:

1. Material changes to the business model of the product, such as changes in the purposes of processing personal information, the types of personal information processed, or the methods of using personal information;

2. Changes in the subject of the Privacy Policy due to business restructuring, transaction mergers, or acquisitions, where the new recipient entity changes the original processing purposes or methods;

3. Material changes in the main parties with whom personal information is shared or to whom it is publicly disclosed;

4. Material changes to users' personal information rights and the methods of exercising such rights;

5. Changes in the contact information of the person responsible for personal information protection and the channels for filing complaints;

6. When the personal information protection impact assessment report indicates that the product has a material impact on individual rights and interests.

7. Protection of Minors

Our products and services are primarily intended for adults. If you are a minor, We ask that you ask your parent or other guardian to read this Policy carefully and use our services or provide information to us with the consent of your parent or other guardian.

IF YOU ARE A CHILD UNDER THE AGE OF 14, PLEASE DO NOT USE THIS SERVICE ON YOUR OWN. IF YOU NEED TO USE IT, YOU AND YOUR GUARDIAN SHOULD CAREFULLY READ THIS POLICY BEFORE USING OUR SERVICES, AND ENSURE THAT YOU HAVE OBTAINED YOUR GUARDIAN'S CONSENT TO THIS POLICY BEFORE USING OUR SERVICES UNDER YOUR GUARDIAN'S GUIDANCE, SO AS TO ENSURE YOUR SAFETY WHEN USING OUR SERVICES. WE WILL DEVELOP AND COMPLY WITH SPECIAL PROCESSING RULES FOR THE PERSONAL INFORMATION OF CHILDREN UNDER THE AGE OF 14 IN ACCORDANCE WITH LEGAL REQUIREMENTS.

If you are a parent or other guardian of a child, please ensure that the child uses our services with your authorization and consent. If you have any questions regarding a child's personal information, please contact our dedicated personal information protection department.

8. Contact Us

You may contact us through the following channels. We will respond to your request within 15 days:

• Customer Service Hotline: 4009-681-776
• Email: service@dogopower.com
• Online Customer Service: APP → “My” → “Help & Feedback”
• Office Address: No. 1255 Jinhai Road, Pudong New Area, Shanghai, China

Please note that We may not respond to questions unrelated to this Policy or your personal information rights.

If you are not satisfied with our response, particularly if you believe that our personal information processing practices have harmed your legitimate rights and interests, you may also seek a resolution by filing a lawsuit with the competent People's Court in the defendant's place of domicile.

Appendix: Definitions of Relevant Terms

DOGO APP: Refers to the mobile client (APP) of the EMS energy management platform.

DOGO APP Service Provider: Refers to the Internet information and software technology service provider of DOGO APP [DoGo Power Technology Co., Ltd.].

Personal Information: Refers to any information related to an identified or identifiable natural person recorded electronically or by other means, excluding information that has been anonymized.

Sensitive Personal Information: Refers to personal information that, once leaked or illegally used, may easily infringe upon the personal dignity of a natural person or cause harm to personal or property safety, including biometric identification information, religious beliefs, specific identities, medical health, financial accounts, location tracking information, and personal information of minors under the age of 14.

Children: Refers to minors under the age of 14.

Device Information: Includes device identifiers (IMEI, IDFA, MAC, OAID, IMSI, and other device-related information), application information (application crash information, notification switch status, application installation list, and other application-related information), device parameters and system information (device type, device model, operating system, and hardware-related information), and device network environment information (IP address, SSID, BSSID, WiFi information, base station information, and other network-related information).

Service Log Information: Includes APP login records, operation logs, fault logs, as well as IP address, browser type, telecommunications carrier, language used, and access date and time.

De-identification: Refers to the process of processing personal information so that it cannot identify a specific natural person without the aid of additional information.

Anonymization: Refers to the process of processing personal information so that it cannot identify a specific natural person and cannot be restored.