PRIVACY POLICY
Effective Date: [2025-03-26]
Last Updated: [2025-03-26]
USTEU Charge ("We", "Our" or "Ours") is committed to protecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, disclose and protect your personal information when you use the USTEU charging mobile application ("Application") and related services in Hong Kong, China. By accessing or using the Application, you agree to the terms of this Policy.
1. Scope and Applicability
This Policy applies to all users of the USTEU charging HK application in Hong Kong. It governs the processing of personal data collected through the application, including during account registration, charging, payment, and customer support interactions.
2. Information We Collect
2.1 Personal Information
We collect the following categories of personal data:
Account Information: Full name, email address, mobile number, profile photo, and password.
Vehicle Details: Electric vehicle (EV) model, license plate number (optional), charging history, and preferred charging settings.
Payment Information: Credit/debit card details, e-wallet credentials (e.g.,paycools), transaction records, and billing addresses.
Location Data: Real-time GPS coordinates (with your consent) or manually entered locations to locate nearby charging stations.
Identity document: Government-issued identification documents (such as passports, Hong Kong identity cards), used for verifying business accounts (if applicable).
2.2 Technical and Usage Data
Device Information: IP address, device model, operating system (iOS/Android), unique device identifiers (e.g., IMEI), and browser type.
App Analytics: Session duration, features accessed, error logs, charging station search queries, and interaction patterns.
Cookies and Tracking Technologies: Data collected via cookies, pixels, or SDKs to enhance functionality (e.g., authentication tokens, language preferences).
3. Purposes of Data Processing
We process your data to:
Deliver Services: Create and manage accounts, process payments, reserve charging stations, and provide real-time availability updates.
Personalize Experience: Recommend charging stations based on usage history, location, and preferences.
Improve Functionality: Analyze usage trends, debug errors, and optimize App performance.
Communications: Send service notifications (e.g., session completion), promotional offers (with consent), and policy updates.
Legal compliance: Fulfill the obligations stipulated by the laws of Hong Kong, China (such as tax reports, PDPA requirements) and respond to legitimate requests.
4. Legal Basis for Processing
Contractual Necessity: To fulfill user agreements (e.g., processing payments for charging sessions).
Consent: For marketing communications, precise location tracking, and optional data sharing.
Legitimate Interests: Fraud prevention, network security, and service improvements.
Legal obligation: Comply with the regulations of the relevant regulatory authorities in Hong Kong.
5. Data Sharing and Disclosure
5.1 Third-Party Recipients
Charging Network Partners: Share session details (e.g., time, location, payment) with station operators to facilitate reservations.
Payment processor: Paycooler for secure transaction processing or a local provider in Hong Kong (such as Omise).
Cloud Service Providers: Alibaba Cloud, or regional data centers for data storage and processing.
Analytics Tools: Google Analytics, Firebase, or Mixpanel for usage trend analysis.
5.2 Legal Disclosures
We may disclose data to:
The regulatory compliance of Hong Kong government agencies (such as the Land Transport Department).
Law enforcement under court orders or subpoenas.
Legal advisors during disputes or litigation.
5.3 Corporate Transactions
In mergers, acquisitions, or asset sales, user data may be transferred to successor entities.
6. International Data Transfers
Your data may be transferred to countries other than Hong Kong, China (such as Singapore, the European Union), and processed within those jurisdictions. We ensure such transfers comply with the PDPA requirements through the following methods:
Adequacy Decisions: Recipient countries with PDPA-approved data protection standards.
Safeguards: Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs).
7. Data Security Measures
We implement safeguards including:
Encryption: TLS/SSL for data in transit; AES-256 for data at rest.
Access Controls: Role-based permissions and multi-factor authentication (MFA).
Audits: Annual penetration testing and vulnerability assessments.
Incident Response: Breach notification to users and regulators within 72 hours, as required by PDPA.
8. Your Rights Under PDPA
You may:
Access/Correct Data: Review or update your profile via the App’s "Account Settings."
Data Portability: Request a machine-readable copy of your data.
Withdraw Consent: Opt out of marketing emails via the "Unsubscribe" link.
Deletion: Request erasure of non-essential data (excludes legal/accounting records).
Complaint: Contact the Personal Data Protection Commission of Hong Kong (PDPC).
To exercise these rights, email [gongjunfeng@usteacharge.com] or submit a request via the App.
9. Data Retention
We retain data only as long as necessary:
Account Data: Until account deletion (up to 30 days post-request).
Payment Records: 7 years for tax compliance.
Location History: 6 months unless anonymized for analytics.
10. Children’s Privacy
The App is not intended for users under 13. We do not knowingly collect data from minors without parental consent.
11. Policy Updates
We will notify users of material changes via in-App alerts or email. Continued use after updates constitutes acceptance.
12. Contact Us
For questions, requests, or complaints, contact:
USTEU Charge Data Protection Officer
UNIT 02, 10/F., BLOCK B, TONIC INDUSTRIAL CENTRE, 19 LAM HING STREET, KOWLOON BAY, KOWLOON, HONG KONG
Email: [gongjunfeng@usteacharge.com]
Phone: [+66 8586 36888]