Update Date: [2025-09-24]Effective Date: [2025-10-01]
Your privacy is crucial to us. Our privacy policy is designed to enhance transparency and help you understand our privacy protection measures in an easy-to-read and navigate format. To this end, we have prioritized providing a privacy policy summary for you to quickly understand our policies. If you wish to learn more, you can read the full text after the summary. Please read the following sections to understand how we collect, use, share, and protect your information to provide you with a seamless product experience.

Introduction

[Wanbang Digital Energy Co., Ltd.] Registered Address: No. 39 Longhui Road, Wujin National High-tech Industrial Development Zone, Changzhou City, Jiangsu Province (hereinafter referred to as "we" or "us") attaches great importance to and is committed to protecting users' personal information and privacy security.

We provide our products/services through our official website and may also provide them through other clients or scenarios in the future. We may process personal information related to you as a result. This privacy policy is closely related to your use of our various products/services. The collection and processing of personal information may vary depending on the specific product/service scenario. Please refer to the specific scenario of your product/service use. We hope that before using our products/services, you will carefully read and confirm that you have fully understood the contents of this privacy policy, so that you can make appropriate choices according to the guidance of this privacy policy.

Our products or services have privacy protection concepts embedded in their design from the outset. We will follow this privacy policy to collect and use your information when you use the corresponding products/services, but we will not collect personal information solely because you agree to this privacy policy through forced bundling. The specific situation shall prevail based on the actual products/services you use. If a particular product/service has a separate privacy policy, that separate privacy policy shall take precedence. We strive to express ourselves in a concise, clear, and easy-to-understand manner, and for provisions that have a significant impact on your rights and personal sensitive information involved, we use bold text to prominently mark them for your attention. Please read carefully.

If you have any questions, comments, or suggestions regarding this privacy policy, you can contact us through the contact information provided in the "Contact Us" section of this privacy policy.

I. How We Collect Personal Information

This section will introduce you in detail what personal information we will collect. We divide this into several categories: personal information you provide to us, personal information generated based on your use of our services, and personal information we receive from others. Sometimes, we may also collect other personal information with your permission. Now, let's understand these in more detail.

1. Personal Information You Provide to Us

Cooperation consultation: When you learn about enterprise, product, and service information on our official website and wish to cooperate with us in various ways including but not limited to station construction, charger purchase, interconnection, distribution agent, and marketing, you may leave your personal information including: name, phone, email, country, province, city, company name, demand type, and demand description. We will contact you through the contact information contained in your personal information.

Customer service: When you contact our customer service, our system may record the communication between you and the customer service, and use your account information for identity verification. When you need our customer service, we may query your relevant order information to provide you with appropriate help and processing. When you need customer service to assist you in modifying relevant information, you may also need to provide additional information beyond the above to complete the modification.

2. Providing Security for You

To improve the security of your use of the services we provide, and to more accurately prevent phishing website fraud and Trojan viruses, we may use or integrate your personal information and information obtained from our affiliates and partners with your authorization or shared according to law, to comprehensively judge your account and transaction risks based on your usage habits and common software information, including verifying identity, preventing, discovering, and investigating potential fraud, network viruses, cyber attacks, and other security risks, as well as behaviors that violate our or affiliates' agreements, policies, or rules, to protect your, other users', our or affiliates' legitimate rights and interests, and record some links ("URLs") that we consider risky.

3. How We Collect Cookies and Similar Technologies

Cookie and similar device information identification technologies are widely used in the internet. When you use our products/services, we may use related technologies to send one or more Cookies or anonymous identifiers ("Cookies") to your device to collect, identify, and store information about your access to and use of our products/services. We use Cookies mainly to ensure the secure and efficient operation of products and services, help you have a more relaxed access experience, improve products and services, and simplify the steps and processes for you to fill out forms. We will not use Cookies for any purpose other than those described in this privacy policy.

You can manage or delete Cookies according to your preferences. Most browsers automatically accept Cookies, but you can usually modify your browser settings to reject Cookies as needed. In addition, you can also clear all Cookies saved in the software, but you may not be able to use features or services that depend on Cookies as a result.

4. Exception Explanation

Please be fully aware that according to laws and regulations, when the following legitimate reasons exist, we do not need to obtain your authorization and consent to collect your personal information:

  1. Necessary for entering into and performing a contract to which you are a party;
  2. Necessary for fulfilling statutory duties or legal obligations, such as statutory duties or legal obligations directly related to national security, national defense security, public security, and judicial investigation, prosecution, trial, and judgment execution;
  3. Necessary to protect the life, health, and property safety of natural persons in case of emergency public health events or other emergency situations;
  4. Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other acts for public interest;
  5. Processing personal information within a reasonable scope in accordance with the provisions of the Personal Information Protection Law of the People's Republic of China regarding personal information that has been publicly disclosed by the individual or otherwise legally disclosed;
  6. Other circumstances provided by laws and administrative regulations.

II. How We Share Personal Information

This section explains with whom we share information, what this information may include, and why we share information, including when information needs to be transferred outside the country where it was collected.

(1) External Provision

We treat your personal information with a high duty of diligence. Unless we have your authorized consent or comply with other legal bases related to laws and regulations, we will not provide your personal information to any other company, organization, or individual.

Some of the products/services we provide require the participation of third parties to complete, so we may provide some of your personal information to our affiliates and third-party service providers or partners to ensure and optimize the products/services we provide to you. We will strictly restrict and manage the external provision of personal information in accordance with laws and regulations.

  1. Prior explicit consent or authorization obtained from you.
  2. To achieve product/service functions. To achieve product capabilities or provide services to you, we will provide your personal information to the following third parties.
    - Our affiliates: We will share your information among affiliates under unified management, control, or with significant interests, and are bound by the purposes declared in this privacy policy. If our affiliates change the purpose of personal information processing, they will seek your authorization and consent again.
  3. Provided according to applicable laws and regulations, administrative or judicial requirements. For example: ① Providing your information according to the requirements of laws and regulations, legal procedures, or competent administrative and judicial authorities.
  4. To handle disputes or controversies between you and others at your request.
  5. Rights protection. When it is truly necessary within the scope required or permitted by laws and regulations to protect the interests, property, or safety of us, our affiliates or partners, you or other users, or the public from damage.
  6. Research on new projects and services. To provide you with better services, we may explore and advance potential business cooperation projects with third-party partners, and may share some of your personal information with potential business partners after appropriate processing such as de-identification and anonymization.

(2) Transfer

We will not transfer your personal information to any company, organization, or individual without your explicit consent.

When we are involved in transactions such as merger, acquisition, division, dissolution, or asset transfer involving personal information transfer, before transferring your personal information, we will inform you of the recipient's name and contact information, and require the company, organization, or individual receiving your personal information to continue to be bound by this privacy policy. Otherwise, we will require that company, organization, or individual to seek your authorization and consent again.

(3) Public Disclosure

We will comply with relevant laws and regulations to keep your personal information confidential. We will not actively disclose personal information that you have not disclosed yourself, unless required by laws and regulations or with your separate consent.

(4) Exceptions to Consent for Sharing, Transfer, and Public Disclosure

Please be fully aware that according to laws and regulations, when the following legitimate reasons exist, we do not need to obtain your prior authorization and consent for sharing, transferring, or publicly disclosing your personal information:

  1. Necessary for entering into and performing a contract to which you are a party;
  2. Necessary for fulfilling statutory duties or legal obligations, such as statutory duties or legal obligations directly related to national security, national defense security, public security, and judicial investigation, prosecution, trial, and judgment execution;
  3. Necessary to protect the life, health, and property safety of natural persons in case of emergency public health events or other emergency situations;
  4. Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other acts for public interest;
  5. Processing personal information within a reasonable scope in accordance with the Personal Information Protection Law of the People's Republic of China regarding personal information that has been publicly disclosed by the individual or otherwise legally disclosed;
  6. Other circumstances provided by laws and administrative regulations.

III. How We Store Personal Information

In this section, we will provide you with information about how long we keep your information, why we keep your information, and emphasize that we may need to keep your information to comply with legal, court, and other obligations.

In accordance with laws and regulations, we store the personal information collected and generated in China within China. We will not transfer your personal information outside China. If we transfer information outside China, we will strictly follow the requirements of relevant laws and regulations or separately seek your authorization and consent.

We only retain your personal information for the period necessary to achieve the purposes described in this privacy policy, unless otherwise provided by laws and regulations or separately authorized by the personal information subject. Depending on the different products/services you use, the retention period of your personal information may vary. The main criteria we use to determine the retention period of personal information are:

  1. Completing product and service purposes related to you and maintaining corresponding product and business records to respond to your possible inquiries or complaints;
  2. Ensuring the security and quality of services we provide to you;
  3. Whether you agree to a longer retention period;
  4. Based on relevant requirements of the statute of limitations;
  5. Whether there are other special agreements or legal provisions regarding the storage period.

After the storage period expires, we will delete or anonymize your personal information.

IV. How You Control Personal Information

Giving you control over your personal information and settings is a core component of our product or service experience. In accordance with applicable laws and regulations, we will take appropriate technical measures to ensure that you can exercise the following rights over your personal information. When you exercise your rights, we may require you to provide proof of identity to ensure that we protect the confidentiality and security of customer information. We will respond to processing opinions or results within fifteen (15) days after receiving your request and verifying your identity. Based on certain exceptions, we may decline your request within the scope permitted by applicable laws and regulations.

(1) Exercise of Your Rights

You can exercise your rights, including access, correction, deletion, and authorization management, through "Contact Us."

(2) Responding to Requests

For your reasonable requests, we generally do not charge fees, but for repeated requests that exceed reasonable limits, we may charge a certain cost fee based on the situation. For requests that are unnecessarily repetitive, require excessive technical means (for example, require developing new systems or fundamentally changing current practices), pose a risk to the legitimate rights and interests of others, or are extremely impractical (for example, involve information stored on backup tapes), we may decline to fulfill them.

Notwithstanding the above provisions, we cannot respond to your requests in the following situations:

  1. Necessary for entering into and performing a contract with you;
  2. Necessary for us to fulfill responsibilities or obligations prescribed by laws and regulations;
  3. Directly related to national security or national defense security;
  4. Directly related to public security, public health, or major public interests;
  5. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
  6. Necessary to protect the life, health, or property safety of you or others in emergency situations;
  7. Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other acts for public interest;
  8. Where there is sufficient evidence that you have subjective malice or abuse of rights;
  9. Processing within a reasonable scope personal information that has been publicly disclosed by the individual or otherwise legally disclosed in accordance with the Personal Information Protection Law of the People's Republic of China;
  10. Where responding to your request would cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
  11. May involve trade secrets;
  12. Other circumstances provided by laws and regulations.

V. Our Privacy Security Policy

(1) Data Protection Measures

We attach great importance to the security of your personal information. We have adopted security protection measures that meet industry standards and are reasonably feasible to protect your information and prevent personal information from being accessed, disclosed, used, modified, damaged, or lost without authorization. For example, we use encryption technology to improve the security of personal information. Data exchanged between your browser and server is protected by SSL protocol encryption, and we provide HTTPS protocol secure browsing. We use trusted protection mechanisms to prevent personal information from malicious attacks. We deploy access control mechanisms to ensure that only authorized personnel can access personal information. We regularly hold information security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

(2) Security Certification

We have passed internationally authoritative security certifications such as ISO27001, ISO27701, ISO37301, and TISAX industry certifications. We have established good coordination and communication mechanisms with regulatory authorities and third-party evaluation institutions to timely resist and address various information security threats and provide comprehensive protection for your information security.

(3) Security Incident Response

In the unfortunate event of a personal information security incident, we will immediately establish an emergency leadership group for personal information security incidents, activate emergency response plans, prevent the expansion of security incidents, and promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the incident-related situations by email, letter, phone, push notification, etc. When it is difficult to inform individually, we will issue announcements in reasonable and effective ways. At the same time, we will proactively report the handling of personal information security incidents in accordance with regulatory requirements.

(4) Special Notice

The internet is not an absolutely secure environment. We strongly recommend that you use secure methods and complex passwords to help us ensure the security of your account. If you find that your personal information has been leaked, especially if your account or password has been compromised, please contact us immediately through the method provided in "Contact Us" so that we can take appropriate measures.

We also ask for your understanding that due to technical limitations and possible malicious methods, in the internet environment, even if we make every effort to strengthen security measures, it is impossible to always guarantee 100% security of information. We will do our best to ensure the security of the personal information you provide to us.

(5) Privacy Protection Concepts and Execution Supervision

We have embedded privacy protection concepts into product design in accordance with industry best practices. Specifically, we have established privacy compliance specialists who go deep into business lines to ensure that privacy protection is embedded in all aspects of business planning and design, product or system development, design, and verification, and have achieved digital management of the above requirements.

We have also established the "Three Lines of Defense" — business unit self-inspection, privacy compliance professional team audit, and internal and external audit — to achieve a closed-loop management of measurement, audit, and inspection.

VI. Our Protection of Minors

We attach great importance to the protection of minors' personal information. Our products and services are mainly for adults. We do not actively or directly collect personal information from minors. If we find that we have collected minors' personal information without prior verifiable consent from their guardians, we will strive to delete the relevant information as soon as possible. If you find that we have unintentionally collected minors' personal information, please notify us through the method provided in "Contact Us," and we will strive to delete the relevant data as soon as possible.

VII. Policy Updates

To provide you with better services, along with the development of our business, this privacy policy will be updated in a timely manner.

We will not reduce your rights under this privacy policy without your explicit consent. We will issue updated versions and remind you of updates to relevant content before they take effect through announcements or other appropriate methods. Please also log in to the official website in a timely manner to learn about the latest privacy policy. If there are significant changes to this privacy policy, we will also provide more prominent notifications, such as SMS or direct emails to you. Significant changes to this privacy policy include but are not limited to:

  1. Significant changes to our service model, such as changes in the purpose of processing personal information, types of personal information processed, and ways of using personal information;
  2. Significant changes in our ownership structure and organizational structure, such as owner changes caused by business adjustments, bankruptcy and mergers, etc.;
  3. Changes in the main objects of personal information sharing, transfer, or public disclosure;
  4. Significant changes in your rights to participate in personal information processing and how you exercise those rights;
  5. Changes in the department responsible for personal information security, contact information, and complaint channels;
  6. When the personal information security impact assessment report indicates high risks.

VIII. Contact Us

We have a dedicated personal information protection manager to handle your needs. If you have any questions about this privacy policy, or any complaints or comments about the processing of your personal information, you can contact us through the following channels.

  • - Personal Information Protection Manager Email: [Dataprivacy.group@wbstar.com]
  • - Hotline: [400-828-0768]
  • - Mailing Address: [No. 39 Longhui Road, Wujin National High-tech Industrial Development Zone, Changzhou City, Jiangsu Province - Information Security Department]

Under normal circumstances, we will complete identity verification and processing response within fifteen (15) days. In exceptional cases involving deletion requests for vehicle data, we will complete the response within 10 working days as required.