1. Basic Policy
Following this principle, we have established an in-house system and strategies for protecting your personal data (hereafter referred to collectively as “personal information” or “your data”) set forth in the General Data Protection Regulation (hereafter referred to as “GDPR”), which we are committed to implementing, maintaining, and continuously improving. And as a special reminder, our protection system and activities are designed to comply with all relevant legislation, and to be worthy of your trust.
In this policy, you will be able to familiarize yourself with how and what we collect, use and disclose, and how we protect your data, as well as your individual rights.
2. What types of personal information do we collect?
2.1. Brief introduction
In order to provide more detailed information of our products (for example, the G3) to the customers, personal information, such as customers’ name, email address, and phone number, may be collected. But we confirm that we only collect the minimum and necessary information, and of course, the purpose and extent of the utilization of the information will be clearly and accurately explained before this is submitted.
This policy applies to the personal information that we collect or process when you interact with our website. Our collection only happens at your request.
2.2. What types of personal information do we collect?
2.2.1 Your basic information, including your name, email address, telephone number. In order to show you our cars’ detailed information, such as configuration and price, and to contact you, send news or any other information you may specifically want to know.
2.2.2 Contents of contact, including your email, input form from the website, notes made during a telephone call, letters, responses to our surveys. In order to answer your questions or provide customized services under your request.
2.2.3 Information automatically obtained by our websites (cookie, IP address, browser type, date and time of access). Also, we will introduce our cookies policy below. In order to remember who you are, and defend you from illegal attacks, remember your actions to improve your user experience.
2.3. How do we collect your information?
Your information is collected by the following means:
2.3.1 Directly from you, such as by telephone, in writing, clicking our button, verbally, or over our website.
We will not collect your personal information from other channels.
2.4. Right to refuse to provide personal information
In any situation, we will not compel you to provide personal information. You can still get our cars’ information though our public material. You always have the right to choose whether or not to provide your personal data to us. However, if you decide not to provide your basic information mentioned in 2.2.1, it may not be possible for us to provide certain services, such as contacting you.
2.5. Information from minors
In any situation, we do not contemplate, or intend to collect personal information or data directly from minors. In the event that a minor provides us with his or her personal data without the consent of his or her parents, please contact our local representative, or contact us. After we verify the information you submitted, we will immediately cease use of the personal information and take any necessary action, including deletion, in good faith.
2.6. Sensitive Data
WE WILL NOT COLLECT YOUR SENSITIVE DATA (racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership) and data related to criminal offences unless otherwise referred to in GDPR.
Your consent will be the legal basis of the processing of personal information/data (hereafter referred to as “Processing”). This is needed for the performance of a contract, in order to take steps at your prior request to enter into a contract, for the purposes of the legitimate interests pursued by us or by a third party, or for compliance with legal obligations.
3.2. Withdrawal of consent and how to withdraw
At any time, you may withdraw your consent. But please be aware that the withdrawal of your consent will not affect the lawfulness of processing based on consent before such an action. You may withdraw your consent by contacting our representative of personal information, refuse to give your consent to our new policy, or by contacting us.
4.How do we use your information/data?
We will use your personal information/data only for the purpose(s) and within the scope we made clear to you. We will not use your Personal Information for other purposes or beyond the indicated scope. At any change of the purposes we use your information, we will seek to renew your authorization. If you do not agree, you can withdraw your consent or refuse to give your consent to our new policy.
4.2 The personal information you submit will be used for the following purposes:
a) Making contact, showing prices related to our goods. You can choose to accept or reject marketing and promotional communications. We will give you the opportunity to withdraw your consent for receiving promotional communications at any time via the unsubscribe link at the bottom of each promotional communications email you may receive from us ,or you can withdraw your consent by contacting our representative dealing with personal information, refuse to give your consent to our new policy, or by contacting us.
b) Corresponding to your individual inquiries and requirements.
c) Providing email, telephone, and other necessary contact for guidance, advertising. If you do not want to receive such message, please contact us.
We may contact you with promotional communications via email, SMS or other channels, such as telephone.
When information is to be used for purposes other than the above, the purpose and limits of the proposed use are made clear to you prior to the acquisition or use of the personal information and are only collected or used with the consent of you.
5.1 What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your device when you browse our website. Cookies are then sent back to the originating server on each subsequent visit, or to another server that recognizes that cookie.
Cookies are widely used in order to make the website work, or to work more efficiently, as well as to provide information to us.
Cookies do lots of different jobs, like letting you log in efficiently, remembering certain preferences, and generally improving the user experience.
Cookies may tell us, for example, whether you have browsed our website before or whether you are a new visitor.
We only serve cookies directly from us to your device. We do not serve any third party cookies.
Cookies can remain on your device for different periods of time. Some cookies are 'session cookies', meaning that they exist only while your application is open. These are deleted automatically once you close the application. Other cookies are 'permanent cookies', meaning that they survive after the application is closed. They can be used by us to recognize your device when you open and browse our website again.
a) retain authentication information in order to provide our website to you;
b) retain your language preference;
remember who you are;
defend against illegal attacks;
remember your actions to improve your user experience；
5.3 How to control or delete cookies
You may find further information on how to disable cookies or manage your cookie settings for the browser that you use from the following list:
6. Provision to third parties and joint use of personal information
6.1.Sharing information to third parties () and joint use of information
We will not share your information with others unless we obtain your consent.
6.2. Monitoring of subcontractors
When using your personal information, we may share such information to ZEM to the extent of legitimate use.
We will require ZEM to strictly manage your personal information as if it were us, and ensure necessary and appropriate monitoring of ZEM, and where using your personal information, we will comply with the security of such information by entering into a contract which includes matters which must be stated by ZEM in accordance with GDPR.
6.3. Scope and purposes of joint use of personal information
We and ZEM may use your personal information independently ONLY within the above approved scope of use.
As a rule, you can get check the scope and purposes of the jointly used of your personal information easily from the following (you can also learn ZEM’s private policy though Annex I ):
6.3.1 We and ZEM will share your basic information that submitted to Xpeng’s website, including your name, email address, telephone number.
6.3.2 We and ZEM will share your contents of contact, including your email, input form from the website, notes made during a telephone call, letter, answers to our surveys.
6.3.3 We share your above information with ZEM,just in order to show you our cars’ detailed information, such as configuration and price, and contact you conveniently, send news or any other information you specifically want to know directly,or sign a car purchase contract with you locally if you want to buy our car.
7. How do we handle your personal information?
7.1. Maintenance of accurate Personal Information
We have implemented appropriate measures to ensure that your personal information/data is kept accurate and up-to-date.
7.2. How long do we store your personal information?
We will retain your personal information for as long as needed or permitted in light of the purposes for which it was collected and no longer than for a duration of a 10 years period after the end of the business relationship with you.
The criteria about storage is the length of time we have an ongoing relationship with you to participate in our website;
After such period, we confirm that we will safely erase or anonymize your information.
7.3. Automated means
We will not make decisions on automated means.
7.4. How to exercise your rights to your personal information?
Generally speaking, you have the following rights based on GDPR. You may exercise such rights by contacting our representative dealing with Personal Information or contacting us. If you exercise such rights, except for exceptions stated in GDPR, we will conduct a necessary identity verification, and as a result, contact such customer within 15 days or sooner after receiving your request.
7.4.1 Your right of access
You have the right to know whether your personal information is being processed or not, and, where that is the case, access to such information.
7.4.2 Your right to rectification
You have the right to request rectification of your inaccurate personal information.
7.4.3 Your right to erasure
You have the right to request erasure regarding the use of personal information in certain cases.
7.4.4 Your right to restrict the use
You have the right to request a restriction regarding the use of personal information in certain cases
7.4.5 Your right to lodge a complaint
7.4.6 Your right to data portability
You have the right to receive personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit such information to another controller without hindrance from us.
7.5. How to complain to supervisory authorities?
You may lodge a complaint with a country, territory, international organization, or other supervisory authorities regarding the processing by us of your personal information.
8. Transfers of your personal information to third countries
Your personal information will be stored on the Aliyun server (click here to know more about Aliyun) located in Frankfurt, Germany.
But when the transfer of Personal Information is necessary for the performance of a contract between you and ourselves, or the implementation of pre-contractual measures taken at your request, we may transfer personal information, for processing and storage, to countries outside the European Union and /or the European Economic Area (EEA), including countries that do not have the same level of protection for Personal Data, but always within the framework of articles 44 to 46 of the GDPR. In case of transfer to a country which lacks an adequacy decision by the European Commission, we will take measures of the standard data protection to lawfully transfer your personal information.
9. What is our secure management of your personal information?
9.1. Compliance with relevant legislation, regulations, and guidelines
We comply with the GDPR as well as other relevant laws, regulations, and industry guidelines in Norway.
9.2. Security measures
We ensure we will make every possible effort to protect your personal information with preventive and security measures to protect against unauthorized access, loss, destruction, tampering, and leaks. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.
9.3. Organizational system
We have an organizational system in place for the protection of Personal Information within our company, which includes a Personal Information Protection Officer for the Group as a whole and a Personal Information Management Officer for each division. The system also includes an audit department for the implementation of internal audits.
9.4. In-house rules for the handling and management of personal information
We have established rules for the handling of Personal Information, to ensure that standards for the appropriate acquisition, maintenance, use, and disposal of Personal Information are established and adhered to. We have also defined a code of conduct and concrete rules for the activities of those handling Personal Information, to prevent unauthorized access, loss, destruction, tampering and leaking of Personal Information.
9.5. In-house training
We implement staff training in relation to the protection of Personal Information and work to protect Personal Information by ensuring that the content of the training is thoroughly understood throughout our company.
9.6. Continuous review of in-house rules relating to the handling and management of personal information
Our legal department continually reviews and improves our rules for the handling of Personal Information and the organizational system for implementing those rules, to ensure that their implementation continues to be effective and appropriate.
10. Revision and publication of this policy
This Personal Information Protection Policy is subject to revision at any time to respond to revisions and changes in related laws and regulations and to social needs related to Personal Information. Any revisions are published on this website without delay and the most recent revision date is clearly shown.
11.How to contact for inquiries and complaints?
We have established a center for responding to customer inquiries and complaints about the personal information collected and held by us. This center responds conscientiously, efficiently, and in the appropriate scope to such inquiries/complaints after confirming the identity of you or your representative. Depending on the request, the response may require several days. But we will try to reply you within fifteen days or sooner.
If you have any questions or comments about this policy, or privacy matters generally, please contact us via：
Email address: firstname.lastname@example.org
Phone number: +47 67979798
Our Representative in Norway: Zero Emission Mobility AS, a company legally established and existing under the laws of Norway, business registration number 924021616.
Personvern v/Zero Emission Mobility AS
Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.
Date：April 30th, 2020