Information on the processing of personal data ("Privacy Policy")
If you are reading this document ("Privacy Policy"), it is because you are visiting this website ("Website").
This Privacy Policy has been prepared pursuant to art. 13 of EU Regulation 679/2016 (hereinafter "GDPR") and the applicable privacy regulations
and provides you with some examples of how we process your Personal Data. For any clarification regarding this Privacy Policy or the methods
of processing your Personal Data, please send your request to: dpo-lpmi@[Link]. The information and Data provided by
you or otherwise acquired will be processed in compliance with the provisions of the GDPR and the confidentiality obligations that inspire the
activity of the Data Controller. From this Website it may be possible to connect through special links to other third-party websites. For such
processing activities, we invite you to consult the respective privacy policies. The Data Controller declines any responsibility for any management
of Personal Data by such third-party websites.
1. Leapmotor International B.V., located in Taurusavenue 1, 2132LS Hoofddorp, the Netherlands,
Who we are (hereinafter also "we" or "us") is the Data Controller of your Personal Data (hereinafter "Data").
2. We collect Data from our Website. The Data collected and the related processing purposes depend
What Data we on the management of the settings of the Browser and the Device in use.
collect and process The purposes for collecting your Personal Data are indicated in the section "Why we collect and
process your Data and legal basis".
a) Data provided by the user
When you use this Website, you may provide us with Personal Data. This is the case, for example,
when you send communications to the addresses indicated on the Website, when you use any
contact forms, when you participate in one of Our Events or when you subscribe to one of our
services (e.g. newsletter) or participate in one of our surveys, if any.
If you provide us with third party data, you will be held responsible for having shared such
information. You must be legally authorized to share it (i.e. authorized by a third party to share their
information, or for any other legitimate reason). You shall indemnify us against any liability in the
event of any complaints, claims or demands for damages that which may arise from the processing
of third-party Personal Data in violation of applicable data protection law.
b) Data collected by the Browser and the Device
When you use our Website we collect information on the Browser and Device you are using. This
information includes your IP Address, the date, time and the requested URL, the Unique Identifiers
and other information such as the type of your Browser or Device. Information related to your
Browser or Device may include your operating system, language, network settings, telephone
operator or internet provider, installed third-party applications and plug-in lists.
Some of this information is collected using Cookies and Other Tracking Technologies that are on your
Browser or Device. More information about Cookies can be found in our Cookie Policy.
3. Your Data is used for the following purposes:
Why we collect and
process your Data
and legal basis
a. Provide our Services and related support
allow navigation of the Website and the provision of services requested by you from time to time to
the Data Controller (for example newsletters, surveys, contact requests, information, downloads of
documentation on the Website, "Provision of the service"). This processing is based on the execution
of a contractual obligation or pre-contractual measures taken at your request;
b. Statistical purposes
for statistical purposes, without it being possible to trace your identity ("Statistics"). It should be
noted that this processing is not performed on Data and that therefore it can be freely carried out
by the Data Controller. This processing is based on the legitimate interest of the Data Controller.
c. Complying with legal obligations
We may use your Data to comply with legal obligations and orders to which we are subject to, which
are the legal basis for the processing of your Data.
Some legislations may require us to share your Data with public authorities. If this sharing is not
required by law of your country, we may still send your Data, as explained in more detail in the
following purpose "Protecting of our interests and your interests".
d. Protection of our interests and interests
To the extent permissible under by applicable data protection law, we may need to use your Data to
detect, react to and prevent fraudulent and illegal behavior or activities which could compromise the
security of our Services and our Website and Application. This may occur when you use our Website in
ways other than as permitted, or if you engage in inappropriate behavior at Our Events. These purposes
also include audits and assessments of our business operations, security audits, financial controls,
records and information management program, and otherwise related to the administration of our
general business, accounting, record keeping and legal functions.
These purposes are based on our legitimate interest in safeguarding our interests and protecting our
users, including you.
4. Data collected for the purposes indicated above are processed both manually and via automated
How we use your processing, namely, through programs or algorithms that analyze the Data inferred by your activities
Data (processing and the Data collected by the Browser and the Device.
methods)
5. We may disclose your Data to the following recipients and/or categories of recipients ("Recipients"):
How We May - Persons authorized by us to perform any of data-related activities described in this
Disclose Your document: our employees and collaborators who have undertaken an obligation of
Data confidentiality and abide by specific rules concerning the processing of your Data;
- Our Data Processors: external subjects to whom we delegate some processing activities. For
example, security system providers, accounting and other consultants, data hosting
providers, banks, insurance, etc. We have signed agreements with each of our Data
Processors to ensure that your Data is processed with appropriate safeguards and only
according to our instructions;
- System administrators: our employees or those of Data Processors to whom we have
delegated the management of our IT systems and are therefore able to access, modify,
suspend or limit the processing of your Data. These subjects have been selected, adequately
trained and their activities are tracked by systems that they cannot modify, as required by
the provisions of our competent Control Authority;
- Law enforcement or any other authority whose provisions are binding on us: this is the
case when we have to comply with a judicial order or the law or defend ourselves in legal
proceedings.
6. We are a global company and our services are available in multiple jurisdictions around the world.
Where your This means that your Data may be stored, accessed, used, processed and disclosed outside your
Data is jurisdiction, including within the European Union, United States of America, China or any other
located country where our Data Processors and sub-processors are located, or where their servers or cloud
computing infrastructure may be hosted. We take steps to ensure that the processing of your Data
by our Recipients is compliant with applicable data protection laws, including EU legislation to which
we are subject. Where required by EU data protection law, transfers of your Data to Recipients
outside the EU will be subject to appropriate safeguards (such as EU Standard Contractual Clauses
for data transfers between EU countries and non-EU countries), and/or other legal basis according
to the EU legislation. For more information about the safeguards implemented by us to protect Data
transferred to third countries outside the EU, you can write to us at: dpo-lpmi@leapmotor-
[Link].
7. The Data processed for the purposes of Provide our Services and related support (see Section 3.a)
How long we and Protection of our interests and your interests (see Section 3.d) will be kept for the time strictly
keep your necessary to achieve those same purposes, except for the purposes of Section 3.a) until your possible
Data opposition. However, the Data might be stored for a longer period in case of potential and/or actual
claims and resulting liabilities and/or in case of other mandatory legal retention requirement and/or
storage obligations.
Data processing to comply with legal obligations (see section 3.c) will be retained for the period
foreseen by the laws and regulations
You can ask us for more information on our data retention criteria and policy by writing us here: dpo-
lpmi@[Link].
8. At any time, you can ask to:
How to - Access your Data (right of access): depending on your use of our Services, we will provide
control your the Data we have about you;
Data and - Exercise your right to portability of your Personal Data (right to data portability):
manage your according to your use of our Services, we will provide you with an interoperable file
choices containing the Data we have about you;
- Correct your Data (right to rectification): for example, you can ask us to modify your e-
mail address or telephone number if they are incorrect;
- Limit the processing of your Data (right to restriction of processing): for example, when
you think that the processing of your Data is unlawful or that processing based on our
legitimate interest is not appropriate;
- Delete your Data (right to erasure): for example, when you do not want to use our Services
and may not want us to retain your Data any longer;
- Object to processing activities (right to object);
- Withdraw your consent (right to withdrawal).
You can exercise the above rights or express any concern or make a complaint regarding our use of
your Data directly at: privacy-rights-lpmi@[Link].
At any time, you can also:
- contact our Data Protection Officer (DPO), here: dpo-lpmi@[Link];
- contact the competent Supervisory Authority, here you can find the list of all Supervisory
Authorities by country: [Link]
9. We take reasonable precautions from a physical, technological and organizational point of view to
How we prevent the loss, misuse, or modification of Data under our control. For example:
protect your - We ensure that your Data is only accessed and used by, transferred or disclosed to
Data Recipients that need to have access to such Data.
- We also limit the amount of Data accessible, transferred or disclosed to Recipients to only
what is necessary to fulfill the purposes or specific tasks performed by the Recipient.
- The computers and servers where your Data is stored are kept in a secure environment,
are password controlled with limited access, and have industry-standard firewalls and
antivirus software installed.
- Paper copies of any documents containing your Data (if any) are also kept in a secure
environment as well.
- We destroy paper copies of documents containing your Data that are no longer needed.
- When destroying Data recorded and stored in the form of electronic files that is no longer
needed, we make sure that a technical method (for example, a low level format) ensures
that the records cannot be reproduced.
- Laptops, USB keys, mobile phones and other electronic wireless devices used by our
employees who have access to your Data are protected. We encourage employees not to
store your Data on such devices unless it is reasonably necessary for them to perform a
specific task as outlined in this Privacy Policy.
- We train our employees to comply with this Privacy Policy and conduct monitoring
activities to ensure ongoing compliance and to determine the effectiveness of our privacy
management practices.
- Any Data Processor that we use is contractually required to maintain and protect your Data
using measures that are substantially similar to those set out in this Privacy Policy or
required under applicable data protection law.
In case required by the applicable legislation, if a breach of security leading to the accidental or
unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Data transmitted,
stored or otherwise processed, will be notified to you and to the competent data protection authority
as required (for example, unless Data is unintelligible to any person or the breach is unlikely to result
in a risk to your rights and freedoms and those of others).
10. This Privacy Policy explains and covers the processing we carry out as Data Controller within our
What this Website.
Privacy Policy This Privacy Policy does not cover processing carried out by subjects other than us.
does not cover Regarding these cases, we are not responsible for any processing of your Data that is not covered by
this Privacy Policy.
11. If we should need to process your Data differently or for purposes other than those indicated herein,
Usage of Data you will receive specific notice before such processing begins.
for Other
Purposes
12. We reserve the right to adapt and/or modify this Privacy Policy at any time. We will inform you of
Changes to the any relevant adaptations/changes.
Privacy Policy
13. The icons illustrated in this Policy are “Data Protection Icons” by Maastricht University European
License Centre on Privacy and Cybersecurity (ECPC) CC BY 4.0.
14. Browser: refers to programs used to access the Internet (e.g. Safari, Chrome, Firefox, etc.).
Definitions
Cookies: refers to a small text sent to your Browser from our sites or our Partners or resellers. It
allows the site to store information such as the fact that you have visited the site, your language and
other information. Cookies are used for different purposes, for example, to record your preferences
regarding the use of Cookies (technical cookies), analysing and improving our Services, and creating
new services and features, or to personalize our Services.
Data Controller: refers to the legal person, public authority, service or other entity which, individually
or jointly, determines the purposes and means for the processing of your Personal Data.
Device: refers to the Electronic Device (e.g. iPhone) through which you visit our Website and/or the
websites and applications of our Partners.
IP address: is a unique number used by the Browser and your Device in order to connect to the
Internet. The Internet service provider provides this number allowing identification of the provider
and/or the approximate area where you are located. Without this Data, you cannot connect to the
Internet and use our Services.
Other Tracking Technologies: pixel tags (trackers used with Cookies and embedded in web pages to
track certain activities) or unique identifiers embedded in links to commercial communications that
send us information when clicked on.
Our Events: these are events / showrooms organized by us or in collaboration with other brands with
which we have signed partnership agreements.
Partners: means third-party entities who may communicate your Personal Data to us only after they
have contractually assured us that they have obtained your consent or that they have another legal
basis that legitimizes their communication/sharing of such Data with us. This definition also includes
selected Partners with whom we may share your Data. Partners may belong to the following product
sectors: manufacturing, wholesale and retail trade, financial, bank, transportation and warehousing,
information and communication services, professional, scientific and technical activities, travel
agencies, business support services, artistic, sports, entertainment and amusement activities,
activities of membership organizations, services of physical wellness centers, suppliers of electricity
and gas, rental, e-mobility and insurance companies.
Personal Data: means any information relating to an identified or identifiable natural person whether
directly or indirectly, as well as any information that is linked or reasonably linkable to a particular
individual or household. For example, an email address (if it refers to one or more aspects of an
individual), IP Addresses and Unique Identifiers are considered Personal Data. For your convenience,
we will collectively refer to all Personal Data mentioned also as "Data".
Processor: refers to an entity engaged by us to process your Personal Data solely on behalf of the
Data Controller and according to its written instructions.
Services: collectively, means all Services available on our Website.
Unique Identifiers: means information that can uniquely identify you through your Browser and/or
Device. On the Browser, your IP Address and Cookies are considered Unique Identifiers. On the
Device, advertising identifiers provided by manufacturers, such as Apple's IDFA and Android's AAIG,
which we use to analyze and improve our Services and creating new services and features are
considered Unique Identifiers. Please note that for these purposes and in line with the opinions of
the European Supervisory Authorities, we do not use other unique identifiers such as MAC addresses
and IMEIs as they are not resettable by the user.
Website: includes this Website and our social networks pages where this Privacy Policy is present.