LAST UPDATED ON 11 July 2020
LUPA Limited and its affiliates (collectively, “LUPA,” “we,” “us,” or “ourselves”) respect your right to privacy and value the protection of personal information about you or from you.
- we automatically collect through our Websites and Mobile Applications;
- we collect when you visit our Offline Experience Stores, Service Centers, and other LUPA locations (collectively, “LUPA Facilities”);
- we collect when you interact with us through email, social media, blogs, online forums, feedback channels and other online and offline channels including at conventions, expos, events or tradeshows; and
- we collect from third party sources.
MINORS UNDER THE AGE OF EIGHTEEN
Our products, services, Websites, and Mobile Applications are not intended for, or available to, minors under eighteen (18) years of age. If you are a minor under eighteen (18) years of age, do not provide any information to us and do not use, or register for, LUPA products, services, Websites or Mobile Applications. If we become aware that we have unknowingly collected Personal Information from a child under the age of 18 without verifiable parental consent, we will make reasonable efforts to delete such information from our records.
TYPES OF PERSONAL INFORMATION WE MAY COLLECT AND THEIR PURPOSES
Personal Information about you is primarily collected through the following mechanisms:
Personal Information that you voluntarily provide when you interact with our Websites or Mobile Applications. Generally, the Personal Information that you are asked to provide and the reasons why you are asked to provide it will be made clear to you at the point where we ask for your Personal Information.
- When you create an account with us, we collect the information you provide us, such as your name, email address, contact details and other information you provide to us. We collect or use your contact details, such as your name or e-mail address, as well as your user ID, password hints and similar security information required for authentication and access to our Websites and platform.
- You can subscribe to marketing communications. You may give consent to LUPA to send you relevant brand, company and product information about LUPA products and services, events, marketing and company communications using your name, mobile number, email address and relevant country/region.
- You can schedule an appointment to experience the Offline Experience Store through our Websites or Mobile Applications. You need to select the address of the Offline Experience Store you wish to visit, schedule a time for your appointment, and provide us with your name and mobile number so that we can arrange an appointment for you.
- Our Websites and Mobile Applications may, from time to time, update information and details about events, such as the LUPA Creator Program, which may require you to provide additional Personal Information. We will inform you about the scope and purpose of the Personal Information that you may need to provide.
- You can register for your LUPA account at any time though our Websites or Mobile Applications. You will need to submit your name, email address, mobile number and country/region when registering for a LUPA You can also choose whether to provide us with other related information about who you are, including your career, hobbies, location, etc.
- You can register to join our developer platform through our Websites. You will need to submit your name, email address, mailing address and basic company information when registering on the platform. When you register to join our development platform, we may contact you about your application and ask you to provide further information or documents to complete your application. We may involve you in subsequent online or offline feedback and evaluations as the platform, its tools and any submissions are assessed and evaluated.
- Our Mobile Applications and Websites can be used to provide you with mobile services, and you may also use our Mobile Applications and Websites to order and purchase certain mobile products and services. Depending on your actions on our Mobile Applications and Websites, we may require you to provide your name, email address and mailing address. You may also be required to provide payment information if you order and purchase products and services.
- In addition, recruitment channels are available on our Websites and Mobile Applications, which allow you to submit your resume to LUPA or authorize us to retrieve your resume, professional qualifications, summary of education, work experience and related professional information from partner recruitment websites for positions you are interested in.
Personal Information collected automatically by our Websites and Mobile Applications.
- When you visit and use our Websites and Mobile Applications, we will automatically collect some of your Personal Information from your device in order to better understand your needs and to improve the functionality of our Websites and Mobile Applications. The Personal Information we automatically collect includes your Internet Protocol (IP) address, device model, unique device ID, browser model, broad geographic location (such as country or city information), and other technical information. We collect and store the IP address assigned to your computer in order to provide you with the contents of the relevant Website or Mobile Application requested by you (e.g. online functionalities, texts, images and product information).
- We also collect Personal Information relating to the manner in which your device interacts with the relevant Website and Mobile Application, such as visited pages or clicked links, development tools used in order to improve our Website and Mobile Application and for internal statistical purposes.
Personal Information we collect when you visit our LUPA Facilities.
- Free WiFi service may be made available to you at our LUPA When you register to use our free WiFi service, you will need to provide your WeChat Account or mobile number (as applicable). Other than that, we will not collect any of your other Personal Information when you use our WiFi. We may use this information alone or in combination with other information for our internal business purposes or to improve your customer experience.
- Some LUPA Facilities have simulation equipment enabling you to experience our products and services in different ways, such as augmented reality and virtual reality headsets, smart walls, and interactive car modules. When you use these simulators, you may be asked to take photos, pick your favorite music and pictures, and choose amongst different content.
- In addition, you can apply to be a participant in market surveys and other marketing activities at our Offline Experience Stores. You can choose whether or not to provide us with relevant information in order to participate in the marketing activities.
- When you visit LUPA Facilities, we may also collect information pertaining to your preferences, how to best contact you, and any unique needs you may require when interacting with our sales or service personnel.
Personal Information we collect during your interactions with us.
- When you interact with LUPA through our social media accounts (i.e Facebook, Twitter, YouTube, LinkedIn, Instagram, etc.), we will get information about your social media account, account avatar, and other information made available by such social media platform. We may also ask you to provide us with your shipping address and contact information in order to send you promotional gifts.
Personal Information we obtain from third party sources.
- We may obtain Personal Information from other sources including our affiliates, partners, suppliers (such as third party application providers used in our in-vehicle services), contractors, agents, and social media, etc.
- Personal Information may also be collected by LUPA from other sources, such as public databases, for the purposes of reaching out to new, potential customers and providing you with personalized services.
We only collect information from third parties where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Information to us.
CATEGORIES OF INFORMATION WE COLLECT
Some jurisdictions require us to disclose the information we collect by category and the below provides a categorization of our data collection practices.
We have collected the following categories of personal information in the past twelve (12) months:
- Identifiers: This includes contact details, like your name, phone number or e-mail address, as well as your User ID, password hints and similar security information required for authentication and access to our platforms. We collect this information directly from you.
- Characteristics of protected classifications in certain jurisdictions (e.g. under California or federal law): This includes demographic information, which may include sex (such as gender and gender identity), age, race and/or ethnicity. We collect this information directly from you.
- Commercial information: This includes information on products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other Network Activity Information: This includes information such as Internet speed, error rates, app download and usage, firmware version, configuration settings, WiFi settings, Internet speed, voltage information, storage information, error rates, app download and usage, services and feature usage, crash diagnostics, and other performance information. We collect this information directly from your device. Some of this information may be collected using cookies and similar tracking technology.
- Geolocation data: This includes broad geographic location (e.g. country or city-level location). We collect this information directly from your device.
- Professional or employment-related information: This includes information such as your business contact details in order to provide services at a business level, or your contact details and information about your professional qualifications, including your curriculum vitae and references when you apply for a job with LUPA.
- Electronic and usage information: This includes information about how your device has interacted with our Websites, including the pages accessed and links clicked, or our products. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identifiers, advertising identifiers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.
We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels
- Participation in customer surveys or contests
- Facilitation in the delivery of our services and to respond to your inquiries
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA data owners only)
If you are located in the European Economic Area (EEA), our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect Personal Information from you only (i) when we need the Personal Information to perform a contract with you; (ii) when the processing is in our legitimate interests and not overridden by your rights; or (iii) when we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).
If we collect and use your Personal Information in reliance on our legitimate interests (or those of a third party), this interest will normally be for operating our Websites and Mobile Applications, communicating with you as necessary to provide our products and services to you, and pursuing our legitimate commercial interests, for instance, when responding to your queries, improving our Websites, Mobile Applications, products and services, or engaging with you throughout our business relationship. We may have other legitimate interests and, if appropriate, we will make clear to you what those legitimate interests are at the relevant time.
SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES
In general, LUPA will not share your Personal Information with any company, organization, or individual. However, we may share your Personal Information with the following categories of recipients:
- We may need to share your Personal Information with relevant law enforcement agencies, regulatory agencies, governments, courts or other governmental third parties. In such instances, we will only disclose your Personal Information to the extent it is necessary for (i) complying with applicable laws, regulations, or government orders, (ii) exercising, establishing, or defending LUPA’s legal rights, (iii) protecting your interests or others; (iv) protecting the public interest.
- Upon obtaining your consent, LUPA will transfer or disclose your Personal Information to a third party you have let BYTON share information with.
Sale of Personal Information
LUPA does not sell Personal Information.
Use of Personal Information
We may use the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
- To provide, support, personalize, and develop our Websites, Mobile Applications, products, and services;
- To create, maintain, customize, and secure your account with us;
- To process your requests, purchases, transactions, and payments and prevent fraud;
- To provide you with support and to respond to your inquiries, including investigating and addressing your concerns, as well as monitoring and improving our responses;
- To personalize your Website or Mobile Application experience;
- To help maintain the safety, security, and integrity of our Websites, Mobile Applications, products and services, databases and other technology assets, and business;
- For testing, research, analysis, and product development, including to develop and improve our Websites, Mobile Applications, products, and services;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA; or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of LUPA’s assets.
Sharing of Personal Information
LUPA discloses Personal Information to third parties for one of the above business or commercial purposes. Prior to disclosing personal information to any third party, LUPA enters into a contract with the third party which requires the third party to certify that it will keep personal information confidential and not further use, collect or sell personal information for any business or commercial purpose except as necessary to perform the contract between LUPA and the third party. LUPA discloses personal information for a business or commercial purpose to service providers.
PERSONAL INFORMATION COLLECTED BY THIRD PARTIES THROUGH OUR PRODUCTS AND SERVICES
We collect and track information about your online behaviors, approximate geographic location information (such as country or city information), and your use of our Websites and Mobile Applications. We only use this information for internal purposes, such as to improve our Websites and Mobile Applications. We will not share this information with any third party for other purposes.
The tables below list some of the internal and third party cookies we use. As the names, numbers, and purposes of these cookies may change over time, this page may be updated to reflect those changes.
The tracking technologies we use are common and are often used in other web pages or mobile applications that you visit. Cookies have different categories depending on the function and use of the cookies. The cookies used on our Website are of the following categories:
- Essential cookies: Essential cookies enable you to browse and use the features of websites and mobile applications. Without these cookies, the website service requested by the user will not be available. The main purposes of our use of essential cookies are: (1) to ensure that the functions of website pages are performed correctly; and (2) to allow users to save options when configuring the vehicle.
- Analytics and Customization cookies: These cookies collect information that is used in aggregate form or helps us customize our Websites and Mobile Applications for you. The purpose of these cookies is to understand which areas are more interesting to users, and learn more about the effectiveness of our advertising. All of these help us to provide you with services and features that better meet your needs. We use these cookies to (1) measure the usage of our Websites; (2) understand the effectiveness of our advertising; (3) review aggregate user behavior to improve our Websites and Mobile Applications; (4) provide services that we believe users may be interested in; (5) provide our media and advertising partners with your access information so they can conduct targeted advertising; (6) share your information with partners who provide services on our Websites and Mobile Applications.
- Marketing cookies: Marketing cookies are designed to provide you with advertising and communication information that is more relevant to your personal interests. Marketing cookies may save records of your visits to our Websites, and we may share this information with other partners. We also use these cookies to limit the amount of advertising. We use Marketing cookies to (1) improve advertising and targeted delivery, and (2) measure the effectiveness of advertising.
- Social networking cookies: Social networking cookies are used to enable you to share pages and content that you find interesting on our Websites or Mobile Applications through third party social networking and other websites. These cookies may be used for advertising purposes too.
You can adjust your browser settings at any time and choose to turn off cookies. However, please note that if you change your settings and block certain cookies, you will not be able to take full advantage of some of the features of our Websites and Mobile Applications and we may not be able to provide some of the features you have previously chosen to use. To prevent this, we recommend that you enable cookies. You can learn more about cookies at http://www.allaboutcookies.org. In addition, most advertising networks offer a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
- Google Analytics. We currently use Google Analytics of Google Inc. to enable the functionality of our Websites. The information received from Google Analytics is used only to improve our Websites and the type of information displayed to Website visitors, so we can better serve those interested in LUPA. Google Analytics is a web analysis service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“). Google Analytics uses “cookies”. The information generated by the cookie regarding your use of the Website is normally transferred to a Google server in the USA, and is stored there. Because the IP anonymize function is activated on our Website, your IP address will, within Member States of the European Union or other contracting states of the Agreement on the European Economic Area, first be shortened by Google. Only in exceptional cases will Google transfer the full IP address to a Google server in the USA, and will shorten it there. On behalf of the operator of this Website, Google will use this information in order to analyze your usage of our Website, to compile reports on Website activities, and to provide further services to the Website provider relating to the usage of the Website and the internet. The IP address transferred by your browser within the framework of Google Analytics will not be combined by Google with other data. In case you prevent the storage of cookies by setting your browser software accordingly, you may not be able to fully use all features on this Website. Furthermore, you can prevent collection by Google of the data generated by the cookie and relating to your use of the Website (including your IP address), as well as processing of this data by Google, by downloading and installing the browser plug-in provided under the following link: https://tools.google.com/dlpage/gaoptout.
- Google Firebase Analytics. We currently use Google Firebase Analytics of Google Inc. to enable the functionality of our Mobile Applications. The information received from Google Firebase Analytics is used only to improve our Mobile Applications and the type of information displayed to Mobile Applications visitors, so we can better serve those interested in BYTON. Google Firebase Analytics is a free application measurement solution that provides insight on application usage and user engagement, provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Firebase uses tracking technologies that allow us to analyze your use of these Mobile Applications for performance monitoring, for error logs and for analyzing user behavior, such as which screens were viewed and how often certain publications were opened. Firebase collects information about the use of the Mobile Applications and transfers it to Google in Ireland or the USA, where it is stored. The data is only collected anonymously and transmitted to Firebase. There is no link to other user data. Google will use this information to evaluate your use of our Mobile Applications and to provide us with other services associated with the use of Mobile Applications. For the personal data that is transferred to the USA, Google has submitted to the EU Privacy Shield. For more information about Google Firebase and privacy, visit https://policies.google.com/privacyand https://firebase.google.com/.
- Remarketing Tags. Our Websites make use of, and integrates, remarketing tags created by the social network Facebook Inc., located at 1601 South California Avenue, Palo Alto, CA 94304, USA. When you visit our Website, a direct connection between your browser and the Facebook server is created via the remarketing tags. This informs Facebook that you have visited our Website with your IP address. Facebook can thus assign the visit to our Website to your user account. We can use the information obtained in this way for our display of Facebook ads. We point out that, as the provider of the Website, we obtain no details of the content of the data transferred or its use by Facebook. Further information on this matter can be found in the Facebook data protection declaration at http://en-gb.facebook.com/about/privacy/. If you do not want your information to be collected by Facebook, you can deactivate this feature here: https://www.facebook.com/settings/?tab=ads. We also use Google AdWords Remarketing to advertise across the Internet. AdWords remarketing will display relevant ads tailored to you based on what parts of our Website you have viewed by placing a cookie on your machine. This cookie does not in any way identify you or give access to your computer. The cookie is used to say “This person visited this page, so show them ads relating to that page.” Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you. Google has additional information available about their Remarketing Privacy Guidelines, and Restrictions. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager, https://www.google.com/settings/u/0/ads/authenticated.
- LinkedIn Insight Tag. Our Websites use LinkedIn Conversion Tracking of LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”). LinkedIn Conversion Tracking is a re-targeting and analysis tool supported by the LinkedIn Insight Tag. The Insight Tag causes a cookie which is a tiny text file to be placed in your web browser when you visit our Website. The Insight Tag is integrated into this Website and enables the collection of data such as your IP address or the time of accessing this website or the collection of defined events (such as downloads or page views). In addition, interest-specific and relevant offers and recommendations can be displayed, which depend on the services, information and offers you have accessed on our Website. Furthermore, LinkedIn can compile statistics with aggregated data about the use and visit of our Website. If you are a LinkedIn member, demographic information, such as your approximate location, may also be collected. You can deactivate the LinkedIn cookie using this link. Further information about LinkedIn data processing activities can be found here.
- Twitter Pixel. Our Websites use the functionalities of Twitter, Inc., 1355 Market St., Suite 900, San Francisco, CA 94102, USA. Twitter conversion tracking pixel is a retargeting and analytics tool that connects data from the Twitter advertising network with actions performed when you visit our Websites. It enables us to learn how our users have interacted with BYTON advertising served to them on Twitter. You can change your data protection settings relating to Twitter in your Twitter account settings. Further information about Twitter processing activities can be found here.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We have implemented appropriate technical and organizational measures, such as encryption procedures and controls over the information systems storing your Personal Information, and management initiatives, including regular training of LUPA personnel who regularly handle Personal Information, that are designed to secure your Personal Information.
Storage Location. We will store Personal Information collected in the EU and USA on servers and public cloud servers located in the EU and in accordance with applicable data privacy laws and regulations. We may store Personal Information on servers and public cloud servers located in Europe and in accordance with applicable European laws and regulations.
Storage Period. Except as otherwise required by applicable laws and regulations, LUPA will store your information as follows:
- We will collect your Personal Information for our legitimate business purposes, such as providing services to you or meeting legal, tax, or financial requirements.
- When we do not have a legitimate business need to use your Personal Information, we will delete your Personal Information or anonymize it. If we are unable to anonymize or delete your Personal information – for example, because it is already stored in a backup – we will safely store your Personal information and separate it from other data processing activities.
CROSS BORDER TRANSFER
YOUR PRIVACY RIGHTS
Depending on your country or state of residence, you may have certain rights in relation to the collection and use of your Personal Information, these may include:
- In addition, if you are located in the EEA, you have the right to complain to a data protection authorityabout our collection and use of your Personal Information. For more information, please contact your local data protection authority.
- You will not receive any discriminatory treatment when you exercise any of your privacy rights.
LUPA does not employ solely automated decision-making, as a matter of course, that results in automated decisions being taken (including profiling) that legally affect you or similarly affect you. By “automated decisions” we mean decisions concerning you that are made automatically on the basis of a computer determination (using software algorithms) and without our human review. If you are to be subject to automated decision making, we will make it clear at the time and you have the right to contest the decision, to express your point of view, and to require a human review of the decision.
HOW TO CONTACT US
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your personal information.
Please use the contact details below, if you would like to:
- Exercise your rights;
- Learn more about your rights or our privacy practices; or
- Designate an authorized agent to make a request on your behalf.
If you are located in the EEA, the data controller of your Personal Information is LUPA SA