Applicable to ENGWE connected electric bicycles and related APP services）
Version: V1.0
I. Applicability
This Data Notice applies to ENGWE connected electric bicycles, as well as the ENGWE APP and backend support services directly related to the functions of such products.
When you purchase, connect, use, manage, or interact with an ENGWE electric bicycle through the APP, the product and related services may generate, collect, record, or process data relating to vehicle operation, device connection, riding records, after-sales support, and additional functions actively used by you.
This Data Notice is intended to inform prospective purchasers, users, and actual controllers of connected devices of:
1. what data is generated by this product and related services;
2. the sources, main purposes, and processing boundaries of the relevant data;
3. which data can be directly accessed by users;
4. which data can be exported;
5. which data can be provided to third-party recipients upon user request;
6. which data can be deleted, and the applicable limitations;
7. which data is not externally disclosed, or is disclosed only in a limited manner, due to cybersecurity, trade secrets, system integrity, or protection of others’ rights and interests.
This Data Notice, together with the ENGWE Privacy Policy, the ENGWE Data Access, Export, Sharing and Deletion Rules, and related policies such as after-sales support policies, constitutes ENGWE’s external disclosure framework for data relating to connected products and related services. Where personal data is involved, the relevant processing is also subject to applicable data protection rules. The Data Act does not replace the General Data Protection Regulation (GDPR).
II. Scope of Connected Products and Related Services
1. Connected Products
ENGWE-branded connected electric bicycles, including built-in or external IoT communication modules, sensors, control systems, and vehicle-side capabilities relating to vehicle status, diagnostics, and riding records.
2. Related Services
Digital services directly related to the functions of the above Connected Products, including but not limited to:
• APP account registration and login;
• vehicle binding and unbinding;
• vehicle status display and settings;
• riding records, routes, and history queries;
• fault diagnostics and feedback;
• community posting, comments, and image uploads;
• backend processing directly related to after-sales support, system operation and maintenance, permission management, and security protection.
III. Data Categories
1. Vehicle Operation and Status Data
During vehicle operation, parking, charging, or connected status, the product may generate vehicle operation data, riding statistics data, vehicle status data, operational performance data, vehicle control and settings data, device status and operation record data, device diagnostic data, connection status data, location-assistance status data, and riding behavior data.
Main purposes:
To display vehicle status to users, support riding records and history queries, provide fault identification and after-sales support, assist safety and performance maintenance, and support data access, export, or third-party sharing within a specific scope upon user request.
2. Device Identification and Connection Data
During vehicle binding, connection, identification, and management, the related services may collect and process device identification data and connection data.
Main purposes:
To identify devices, establish or maintain binding relationships, display compatibility and version information, support diagnostics and after-sales service, and ensure the security of device and service connections.
3. Location and Riding Route Data
When users enable location, navigation, riding record, or related map functions, the related services may collect and process:
• mobile device location information;
• precise vehicle location;
• vehicle riding routes and route history.
Main purposes:
To enable location, navigation, riding route recording, riding history review, location-related functions, and sharing functions actively selected by users.
This category of data is highly sensitive and involves personal movement routes and travel habits. We apply strict security safeguards, including encryption, during collection and processing. User access, export, deletion, and third-party sharing of such data are subject to higher control requirements.
4. Account and Basic Profile Data
During registration, login, and account settings of EGNWE APP, the related services may collect and process:
• email address;
• password;
• country/region;
• nickname;
• avatar or account photo.
Main purposes:
To create and maintain user accounts, support identity recognition, enable account management, and provide related services.
Passwords are used only for authentication and security verification, and are not treated as data items accessible, exportable, or shareable by users.
5. Feedback, After-Sales, and Support Data
When users submit issue feedback, repair requests, enquiries, or after-sales requests, the related services may collect and process:
• user email address or other contact information;
• device name;
• user’s country;
• issue type;
• feedback text;
• feedback photos;
• logs or diagnostic materials relating to issue identification.
Main purposes:
To identify issues, provide after-sales support, conduct fault analysis, and complete the service process.
Free-text content, attachments, and logs may contain additional personal data or third-party information. Therefore, external disclosure of such data is usually subject to stricter restrictions.
6. Community and User-Generated Content
When users use photo editing, community posting, commenting, or sharing functions, the related services may collect and process:
• photos uploaded to the community;
• comment content;
• other content actively published by users.
Main purposes:
To enable community interaction, content display, comments, and user communication functions.
This category of data generally constitutes user-generated content and may also involve public visibility settings, deletion requests, and protection of others’ rights and interests.
7. Usage Logs and System Operation Data
During the operation of the APP and backend services, ENGWE may process log information relating to service operation, troubleshooting, and security maintenance.
Main purposes:
To ensure normal service operation, troubleshoot faults, handle security incidents, optimize stability, and maintain system integrity.
Raw logs are generally not made fully available externally. Where appropriate, users may be provided with necessary summaries or result explanations directly related to their requests.
IV. How Users May Access These Data
Depending on data type, risk level, and system availability, ENGWE provides users with the following access methods:
1. Direct Online Viewing
Data that users may directly view in the ENGWE APP includes but is not limited to:
• real-time vehicle status data;
• basic riding statistics data;
• device identification data such as device name, model, and version;
• basic display content in historical riding records;
• basic account profile data;
• basic information of submitted feedback records;
• community posts.
2. Export upon Request
For data that is structurally stored and reasonably extractable, users may export relevant data of the corresponding module through the relevant function in the ENGWE APP.
In principle, exportable data includes but is not limited to:
• vehicle operation data;
• riding statistics data;
• vehicle status data;
• basic account profile data;
• community content and feedback records submitted by the user.
Exported data will be provided in a structured, commonly used, and machine-readable format. For data that can be provided in real time or continuously, ENGWE will determine whether to provide continuous access based on technical feasibility.
3. Provision to Third-Party Recipients upon Authorization
Where legal requirements are met, identity and control-right verification has been completed, and the user has validly initiated the request, ENGWE may provide relevant data to a third-party recipient designated by the user.
Typical scenarios include:
• repair, maintenance, and fault diagnostics;
• insurance or claims support;
• fleet management;
• other data services independently selected by the user.
The scope of third-party receipt will be limited by the following factors:
• the scope of user authorization;
• data type and sensitivity;
• system security and trade secret protection;
• whether third-party information is involved;
• recipient identity verification and security conditions.
V. Data That Is Generally Not Fully Disclosed, or Is Disclosed Only in a Limited Manner
To protect network and product security, trade secrets, others’ rights and interests, and system integrity, the following data is generally not provided to users or third parties as complete raw data, or is provided only in a limited manner:
1. passwords, authentication credentials, key materials, and other authentication data;
2. underlying control parameters relating to device or platform security mechanisms;
3. raw data that may expose system vulnerabilities, interface strategies, anti-abuse logic, or internal security monitoring rules;
4. complete raw logs, debugging logs, and internal risk-control markers;
5. data containing third-party personal data, protected commercial information, or internal R&D information;
6. portions of full raw sensor data that exceed the user’s reasonable access purpose and whose disclosure may impair security or reveal trade secrets.
Where applicable, ENGWE may instead provide:
• summary information understandable to users;
• necessary extracts directly related to after-sales service, repair, or the user’s request;
• versions subject to de-identification, aggregation, truncation, or scope control.
VI. Deletion and Retention Rules
Users may delete specific data directly in the ENGWE APP or submit deletion requests to ENGWE. Deletable data includes but is not limited to:
• community posts;
• certain route and location records;
• account avatar, nickname, and other profile data;
• feedback attachments;
• account deletion and subsequent processing relating to the account.
However, in the following circumstances, ENGWE may defer deletion, partially retain data, or replace deletion with anonymization or restriction:
1. where necessary to complete after-sales support, dispute handling, warranty performance, or fault traceability;
2. where necessary to comply with applicable legal obligations, financial and audit requirements;
3. where necessary to ensure network and product security, identify abuse, and maintain service integrity;
4. where necessary to protect the lawful rights and interests of third parties.
Where immediate deletion is not carried out or only partial deletion is performed, ENGWE will explain the reasons in the applicable interface or processing result.
VII. User Requests and Identity Verification
To prevent unauthorized data access, sharing, or deletion, ENGWE will apply different levels of identity and control-right verification depending on the type of request.
For high-risk requests, such as:
• exporting precise location or route data;
• authorizing a third party to continuously receive device data;
• deleting data closely related to the device binding relationship;
• requesting access to highly identifiable data, such as full display of serial numbers or MAC addresses,
ENGWE may require users to complete additional verification, including but not limited to:
• login status confirmation;
• secondary verification;
• device binding relationship verification;
• supplementary confirmation of current control rights, purchase relationship, or usage relationship.
VIII. Updates to This Data Notice
If product functions, APP-related services, data structures, export capabilities, or third-party access mechanisms change, ENGWE may update this Data Notice accordingly and provide users with the latest version through the official website, APP, or other appropriate means.
IX. Contact and Further Information
Users may obtain further information on the following matters through the EU Data Act section in the ENGWE APP, customer service, the issue feedback page, or the designated entry on the ENGWE official website:
• data access;
• data export;
• authorization of third-party receipt;
• deletion requests;
• personal data processing.
