This Privacy Policy only applies to Tracksolidor relevant services offered by Shenzhen Jimi IoT Co., Ltd (hereinafter referred to as “we” or “us”). You are welcome to use the location services provided by this application. We work hard to protect your privacy and personal information. This Privacy Policy applies to all scenarios where you use the services provided by this application.

This application mainly provides location services, voice services, video services, and picture services. If you do not agree to or do not understand any part of this Privacy Policy, you must not proceed to use this application. By continuing to use this application, you have fully understood and agreed to all of this Privacy Policy.

This Privacy Policy will help you understand the following content:

1. What information we collect

2. How we use cookies and other technologies

3. Storage of information

4. Information security

5. How we use your information

6. Sharing your information

7. Your rights

8. About Telemetry Data

9. Protection of minors

10. Changes to this policy

11. Contact information

The details of this Privacy Policy are as follows:

1. What information we collect

To provide better services to you, we may collect information provided by you or generated during your use of our services in the following ways:

1.1 When you create an account with your email address, you provide us with youremail addressandmobile number. We are fully aware that email addresses and mobile numbers are sensitive information; we collect such information to comply with the internet real-name system stipulated in relevant laws and regulations. If you decline to provide such information, you may be denied access to the application and its relevant functions.

1.2 When you use this application, to ensure the normal use of all our services, in accordance with relevant laws and regulations, and to better our services and secure your account, we may collect the following data:device model, operating system, browser name and version, unique device identifier, login IP address, application version number, network access mode, type, and status, and crash log information of the application. Such information is essential for providing services.

1.3 Requesting for network data and remote version update is the basic function of this application. To this end, we may need permissions toaccess your device status and external storage. We will apply for these two permissions for the first time you use our services. If you decline to grant such permissions, the application cannot provide services. If you wish to continue to use these services after the decline, you can go to the system permissions management module and re-grant the read and write permissions on the mobile status and external storage.

1.4 When we have your consent, we may acquire yourprecise location information (GPS information)to offer you location services. Such information belongs to sensitive information; by declining to provide such information, you will be unable to view your current location, but you can still use other functions.

1.5 When you use picture, recording, or video services, we may collect thesepicture, recording, and video content, as collecting such information is essential for the basic services of the device. This information is stored on a cloud server; you are entitled to request to delete it.

1.6 When you use the location services, we may use the location function of Baidu, OpenStreetMap, Here, Google, Mapbox, or ArcGIS maps, as the location services is an essential function of this application. Thelocation informationreturned by these maps and collected by us will be timely displayed on the application; we shall not use it for any other purpose.

1.7 To help us better understand the operation status of our application, we may call up the third-party service Google Analysis to record relevant information. We shall not combine the information in the analysis software with any personal information provided by you in our application.

1.8 When you use the push function of the platform, we may use third-party push services (such as JPush and Amazon) to provide you such push services, so you can receivedevice alarm notificationsfaster.

1.9 When you use the share function, the system may complete the sharing via the third-party sharing tool you selected, which makes sharing trips to your friends more convenient.

You understand that the functions and services we offered are always updating and evolving. If a function or service that is not specified in the description above collects your personal information, we will use webpage tips, interactive procedures, website bulletins, or other methods to notify you of the information, scope, and purpose of such a collection.

2. How we use cookie and other technologies

Cookie is a mechanism that supports a server (or script) to store information to and retrieve information on a client. When you use some functions, we may send one or multiple cookies or anonymous identifiers to your device. When you interact with these functions, we allow the sending of cookies or anonymous identifiers to the server. A cookie normally contains some randomly-generated characters. By using cookie technology, this application can understand your behavior of use or help you know the security status of your account. Cookies can also help us to do statistics about traffic and analyze the effectiveness of the page design.

We will not use cookies for any purposes other than these stated in this Privacy Policy. You can manage or delete cookies according to your preferences.

3. Storage of information

We strictly abide by laws and regulations and the agreement with users and use the information we collect for the following purposes. If we use your personal information for purposes other than these stated below, we will explain to you again and ask for your consent.

The personal information this application collects is transmitted over the internet to our system server in an encrypted manner. The security level of our equipment room management, server management, network management, and this application is relatively high. We retain your information only for the period necessary for the purposes stated in this Privacy Policy and for the period stipulated by laws, regulations, and supervision. We will not share the above information with any third party or use them for any purposes other than stated unless you choose to or under the requirements of relevant laws and regulations.

3.1 Information storage location

We may, in accordance with laws and regulations and based on actual requirements, store your personal information we collect on our cloud server which is hosted in Germany, United States and Hong Kong China.

3.2 Information retention period

Generally, we may retain your personal information only for the period necessary for the purposes stated.

When our product or services stops operating, we shall notify you via a push notification or bulletin or in any other way, delete or anonymize your personal information within a reasonable period, and stops collecting your personal information immediately.

4. Information security

We strive to guarantee the security of our users’ personal information to prevent the information from being lost, used illegally, or accessed or disclosed without authorization.

We will use all types of security precautions at a reasonable security level to protect your personal information. For example, we may use encryption technologies (such as SSL) to protect your personal information.

We will enhance the security capability of our software installed on your device by constantly improving the technologies to prevent the disclosure of your personal information. For example, we may encrypt part of the information locally for secure transmission.

We have established a dedicated management system, procedure, and organization to guarantee the security of information. For example, we strictly control the persons that are allowed to access the information and these persons are required to observe confidentiality obligations.

If any security incident such as personal information disclosure occurs, we will take the contingency plan to stop the incident from expanding and notify you via a push notification, bulletin, or in any other way.

5. How we use your personal information

To ensure the security of the services and help us to better understand the operation status of our application, we may record relevant information such as the frequency you use an application, crash data, overall use statistics, performance data, and the source of the application. We will not combine the information in the analysis software with any personal information provided by you in our application.

If we use your personal information for purposes other than stated or outside the direct or reasonable associated scope, we will ask for your explicit consent prior to use.

6. Sharing your information

We will notdisclose any personal information we collect. If under any circumstance we have to disclose such information, we will notify you of the purpose of this disclosure, the type of information to be disclosed, and the sensitive information that may involve, and ask for your explicit consent.

In addition, in accordance with relevant laws, regulations, and national standards, we maydiscloseyour information without your prior consent in the following circumstances:

1) Relate directly to national security or national defense;

2) Relate directly to public safety, public health, or major public interest;

3) Relate directly to crime investigation, lawsuits, judgment, etc.

4) For the purpose of safeguarding major legitimate rights and interests such as the life or property of the subject of the personal information or another person while it is hard to have the consent of the person themselves;

5) Personal information that the subject of the personal information voluntarily shares to the public;

6) Personal information collected from information disclosed legally, such as from news reports or information published by the government;

7) Other circumstances stipulated by laws and regulations.

7. Your rights

During your use of this application, to ensure that you can access, modify, and delete your personal information conveniently and to guarantee your rights to withdraw your consent to use your personal information and to log off your account, we offer you corresponding operation settings in our product design.

To query, modify, or delete your personal information, go toProfile>Personal info.

The personal data our tracking units shall collect are phone numbers only. These are the center numbers configured by users to receive SMS commands. When a tracking unit accesses the network, you can delete this phone number by sending an SMS command or by using a mobile app. In addition to that, you can press and hold the power button on the tracking unit for 10 seconds to restore it to factory settings, in which way this phone number will also be deleted.

8. About Telemetry Data

The telemetry data we shall collect are device logs. The logs contain the firmware version information, cloud server address, GNSS signal values, and working modes of devices.

The logs are automatically uploaded to the platform by the devices and stored on an upgrade server. These logs that has retained for more than 3 months shall be deleted. People who have permission to view these logs are from our after-sales service team or research and development team.

If a fault occurs on a device, our after-sales service team will check the logs to obtain basic information about the device and provide resolutions to our customers accordingly in the first place.

9. Protection of minors

The protection of the personal information of minors is important to us. In accordance with relevant laws and regulations, if you are under age 14, you must have the written consent of your parent or legal guardian before using this application. If you are the legal guardian of a minor, when you have any questions about the personal information of the minor you are guarding, you can contact us via the contact information in section 10.

10. Changes to this policy

We change this Privacy Policy from time to time. When terms in this Privacy Policy change, we will present to you the instructions after change with pop-ups when you log in or update your version. Please be noted that we will collect, use, and store your personal information in accordance with the new Privacy Policy only when you click on theI Agreebutton in the pop-up. You can view the Privacy Policy inProfile>Settings>About us.

11. Contact Information

If you have any suggestions on this application, please contact us viaProfile>Feedback. We will review the feedback as soon as possible and reply to the feedback in fifteen (15) days after we have verified your identity.

We have established a dedicated personal data protection department (or a personal data protection specialist), you can contact the department (specialist) via: privacy@jimilab.com

Contact address: 3-4/F, Block A, Building #7, Shenzhen International Innovation Valley, Dashi 1nd Road, Nanshan District, Shenzhen, Guangdong, China