Thunder Software Technology Co., Ltd. and its affiliates (hereinafter collectively referred to as "we" or "us" or "ThunderSoft®"), this policy applies only to the webpage services of Thunder Software Technology Co., Ltd.
(hereinafter collectively referred to as "we" or "us" or "ThunderSoft") is a company with its registered office at ThunderSoft Building, Building 3, No.9 Qinghua Dong Road, Haidian District, Beijing, China. We take the protection of your personal information and privacy very seriously.
This Privacy Policy is designed to help you understand what data we collect, why we collect it, what we do with it and how we protect it.
1. This Privacy Policy will explain to you in turn the scope of personal information we may collect (some functions may require the collection of sensitive personal information), the purpose of collection, the manner of collection, and the possible consequences of refusing to provide personal information. We will strictly follow the principles of legality, legitimacy and necessity in collecting and using user information.
2. This Privacy Policy will explain to you how we keep personal information secure, how we store personal information and how we handle personal information of minors.
3. You may access, correct, or delete your personal information through the channels listed in this Privacy Policy, and you may also exercise your rights and interests through customer service calls.
4. We will use or share your personal information strictly in accordance with the scenarios described in this Privacy Policy, and if we go beyond the scope described in this Privacy Policy, we will inform you again and obtain your express consent.
5. You agree that we may use your information in the following ways:
Personal information refers to all kinds of information recorded electronically or by other means that can identify the personal identity of a natural person, either alone or in combination with other information, and in the privacy policy of this platform includes: basic information (name, date of birth, gender, ethnicity, nationality, family relationship, residential address, personal telephone number, e-mail address, etc.); personal identification information (identity card, driver's license, passport, etc.); personal biometric information (personal genes, fingerprints, voiceprints, iris, facial features); photos; voice; video; Internet identity (personal information subject account, IP address, personal digital certificate, etc.); personal education and work information (personal occupation, position, work unit, education, degree, education experience, work experience, etc.); personal property information (bank account number, deposit information, real estate information, credit records, credit information, transaction and consumption records); personal communication information (communication records and content, SMS, MMS, e-mail content); personal Internet access records (webpage browsing records, software usage records, click records, etc.); personal common device information (hardware serial number, device MAC address, software (APP) list, unique device identification code, Bluetooth MAC address, Wifi MAC address, etc.); personal location information (including whereabouts, precise positioning information, latitude and longitude, etc.).
Personal sensitive information refers to personal information that may jeopardize the safety of persons and property once leaked, illegally provided or misused, and is highly likely to lead to damage to personal reputation, physical and mental health or discriminatory treatment, etc. In the privacy policy of this platform, it includes: personal identification information (ID card, driver's license, passport, etc.); personal biometric information (personal genes, fingerprints, voiceprints, iris, facial features); personal property information (bank account number, deposit information, real estate information, credit records, credit information, transaction and consumption records), other information (system account number, IP address, e-mail address and passwords related to the foregoing, marital history, whereabouts, web browsing records).
Anonymized information, i.e., information that is technically processed to make the subject of the personal information unidentifiable and cannot be recovered after processing, is not personal information after anonymization. Other information that does not identify a specific natural person or reflect the activities of a specific natural person is not personal information.
The following table is a reference to the source of personal information and a description of its categorization:
| Basis | Definition | Categories of personal information | Examples of personal information |
|---|---|---|---|
| GDPR | Personal data: means any data relating to an identified or identifiable natural person (data subject); Identifiable natural person refers to a natural person who can be directly or indirectly identified, especially through identifiers such as name, ID number, location data, network identifier, or through specific physical, psychological, genetic, mental state, economic, cultural, social and other personal attributes. | Identity information | Last name, first name, identification number, etc. |
| GDPR | Address information | Residence, destination, etc. | |
| GDPR | Online logo | IP, device information, etc. | |
| GDPR | Identification Code | Equipment identification code, VIN, license plate number, etc. | |
| GDPR | One or more physical, physiological, genetic, spiritual, economic, cultural or social identities held by a natural person | ||
| EDPB Car Networking Guide | Most data associated with connected vehicles is considered personal data, as long as it can be linked to one or more identifiable individuals. Including: technical data on vehicle movement, location data, biometric data, business and transaction data, usage behavior data, data related to driving style, and other personal data processed in or exchanged with the vehicle. | Vehicle Motion Technical Data | Speed, instantaneous speed, driving distance, etc. |
| EDPB Guide | Vehicle condition data | Engine coolant temperature, engine speed, tire pressure | |
| EDPB Guide | User usage behavior data | Personal data generated by the vehicle, driving habits, location, etc. | |
| EDPB Guide | Transaction data | Identification information of the data subject, data relating to the transaction, data relating to the payment method | |
| EDPB Guide | Location data | Historical navigation records, time of navigation, home address, company address, frequently-visited address, etc. | |
| EDPB Guide | Biometric data | Fingerprint, face, voiceprint, etc. In accordance with the GDPR and relevant domestic law. | |
| EDPB Guide | Crime data | Data indicating criminal offences or violations (e.g., vehicle crossing a white line, speed data combined with location data). Subject to Article 10 of the GDPR. |
We collect and use your personal information for the following business functions and purposes as described in this Privacy Policy. Product and business functions are categorized into basic and extended functions, and we will explain to you in detail the personal information collected by each function, the method of collection, the purpose of collection, and the method of use.
When we provide services, we may collect the following personal information related to you: voice information, address book information (contact name and cell phone number), location information, etc. Please note that the specific information may vary depending on the products/services we provide.
You should note that the above personal information is provided by you voluntarily. You have the right to refuse to provide it, but you may not be able to use the corresponding services.
(1) Scope of information
When you use the voice dialog function, we will collect your self-recorded voice information and convert it to text in the cloud. At the same time, we will collect the text information after the transcription and display it to you, so that you can understand what voice interactions have been carried out and control the relevant facilities in the car (including but not limited to the car phone, windows and air conditioning) according to your voice commands. The voice information you enter will only be used to provide you with the current voice interaction function or for call-out analysis when dealing with troubleshooting, and will not be used for any other purposes.
(2) Scope of authority to call
When you use the voice conversation function, we need to call your microphone permission to get your voice information. This is the system permission necessary for this function; if you refuse, you will not be able to use the voice recognition function.
(1) Scope of information
When you choose to use the voice dialing function, connect your phone to the car via Bluetooth, and after you authorize us, your phone's address book information (contact name and cell phone number) will be synchronized and saved locally in the car and in the cloud. The contact name is collected for customized audio recognition to match the recognized text with the contact name, and the cell phone number is collected for voice interaction commands to make a call based on the cell phone number.
(2) Scope of authority to call
When you use the voice dialing function, we need to call your microphone privilege to get your voice information, as well as the Bluetooth privilege of your cell phone and car, and the address book privilege to connect your cell phone and car and get your address book information.
(1) Scope of information
When you actively turn on the positioning of your device, when you use the function related to geographic location, with your authorization, we will obtain the vehicle location information transmitted to us by the system, so that we can provide you with accurate navigation, weather and geographically related food recommendations and other services based on your location.
(2) Scope of authority to call
When you use the geolocation-related recommendation function, we need to call your location permission to obtain your location information.
(1) The following table details the permissions, corresponding functions, and purposes:
| System access | Corresponding Business Functions | Purpose of invocation privilege | When to request permission |
|---|---|---|---|
| Microphone | Voice assistant service (with voice wake-up, voice dialog, Ai Smart Hangout, voice dialing) | For voice input | When the corresponding function is turned on |
| Contacts | Voice dialing | Quickly and accurately enter a contact's name when typing by voice; when using the phone, find a contact you can call, show the name and cell phone number of the other end contact | After connecting your phone via Bluetooth |
| Location | Geographic location related recommendations | Provides accurate navigation, weather and location-related recommendations and more | When using location-related services |
| SD Card | Local identification, initialization of applications | Write custom wake word resources and other resource files, initialize the application | Software startup |
| Bluetooth | Voice dialing | Users connect their cell phones via Bluetooth | When connecting a cell phone via Bluetooth |
(2) When the product is in the non-wake state, the product will automatically and continuously collect the voice information of your interactions in the car, in order to automatically activate the voice interaction function of the product after detecting the wake-up word. The voice information collected in the non-wake-up state will not be stored or uploaded to the cloud.
(3) The personal information we collect will only be used for the purposes stated in this section.
Extended business functions are provided to give you better products or services. These extended functions will collect and use your personal information; if you do not provide or refuse to authorize the use of such personal information, we may not be able to provide the corresponding services. However, it will not affect your use of the core basic functions.
In the following cases, the collection and use of personal information does not require your prior authorized consent:
ThunderSoft may call some of your device permissions. You can choose to disable some or all of the permissions in the settings of your device, so as to refuse the collection of personal information. The way of displaying and turning off the privileges may vary in different devices.
| Device authority | Corresponding business functions | Purpose of invoking permissions | |
|---|---|---|---|
| Network permissions for data | Data network | Voice networking | AI voice function needs to collect the words spoken by the customer in the microphone and send them to the voice service function in the backend of ThunderSoft to realize the logic of voice wake-up, voice recognition, voice understanding, voice conversation processing, etc. |
| Network permissions for data | Data network | Log data | Upload the system log data of this vehicle to ThunderSoft's background for system failure analysis & product improvement |
| System access | Corresponding business functions | Purpose of invoking permissions | |
|---|---|---|---|
| Permission to upload data to ThunderSoft Back Office | Data upload | Voice data collection | AI voice function needs to collect the words spoken by the customer in the microphone and send them to the voice service function in the backend of ThunderSoft to realize the logic of voice wake-up, voice recognition, voice understanding, voice conversation processing, etc. |
| Permission to upload data to ThunderSoft Back Office | Data upload | Log data collection | Upload the system log data of this vehicle to ThunderSoft's background for system failure analysis & product improvement |
We will strictly ensure that cookie technology is used safely and does not adversely affect you.
Like most webpages and mobile applications, we collect certain information and save it in log files. Such information may include Internet Policy (IP) addresses, Internet Service Providers (ISPs), operating systems, date/time stamps, and/or clickstream data. We do not link automatically collected data to other information we collect about you.
During visits to the webpage, we may use analytics software to better understand how the webpage is being accessed. We do not link the information stored within the analytics software to any personal information you submit within the webpage.
As some of our services will be provided by authorized partners, ThunderSoft may provide your personal information to partner third parties. We will only share your personal information for lawful, legitimate, necessary, specific and explicit purposes.
Before sharing the information, we will review the data security capability of the third party, sign a strict data security or confidentiality agreement with them, and require them to take relevant confidentiality and security measures.
Partner information:
| Company identification | Services provided | Shared information |
|---|---|---|
| Microsoft Ireland Operations Limited, known as "Azure Cloud" | Online speech recognition and understanding services in English, German, French, Spanish, Italian, Norwegian, Dutch, Polish, Swedish | Raw user audio data |
We will not transfer your personal information to companies, organizations, and individuals other than ThunderSoft and its affiliates, except in the following cases:
We will not publicly disclose your personal information except with your express consent or as required by law.
Exceptions that do not require consent:
Your personal data will be stored within the European Union. In the case of cross-border transfer, we will clearly inform you of the purpose and separately obtain your authorized consent.
2.1 We will continue to store users' personal information during the period of their use of ThunderSoft's products/services.
2.2 When you apply for deletion of your personal information or cancellation of your account, we will retain your existing personal information in accordance with the minimum period of retention required by laws and regulations. When your personal information exceeds the retention period, we will anonymize it.
ThunderSoft will take appropriate industry standard security measures and technical means to store and protect your personal information.
3.1 Technical security measures:
3.2 Other security measures:
3.3 Security incident handling:
ThunderSoft respects your concern for your personal information and provides you with the means to manage it.
1.1 You can contact ThunderSoft to inquire about the information, and we will respond within 15 working days.
1.2 When you need to update or correct your personal information, you can contact ThunderSoft or send an e-mail. We will respond within 15 working days.
2.1 You can withdraw your authorization by turning off the corresponding device privileges (including location, contacts, photos, microphone, camera, notifications, etc.).
You can also change your authorization consent by contacting ThunderSoft customer service or sending an email.
When you withdraw your consent, we will no longer process the corresponding personal information. Withdrawal does not affect the processing prior to withdrawal.
You may request the deletion of your personal information by contacting us through the contact information listed in Section XII. Applicable cases:
If we terminate our services or operations, we will provide you with at least thirty (30) business days' notice and delete or anonymize your personal information upon termination.
You may request to cancel your account by contacting us at the contact information listed in Section XII. After cancellation, we will store your personal information for the period agreed upon in this policy, after which we will anonymize it.
We will respond within 15 working days. If you are not satisfied, you can also file a complaint through the European Union's personal information supervisory authority, or file a lawsuit in a court of competent jurisdiction.
We may deny requests that are unnecessarily repetitive, require excessive technical means, pose a risk to the legal rights of others, or are highly impractical.
Exceptions where we may not comply:
ThunderSoft emphasizes the protection of minors' information. Our products, websites and services are primarily intended for adults. Minors should not create their own user accounts without parental or guardian consent.
If we become aware that personal information of minors has been collected without prior verifiable guardian consent, we will seek to delete the relevant data as soon as possible.
In principle, personal data collected and generated within the European Union will be stored within the European Union. In case of cross-border transfer, we will ask for your authorized consent separately.
This policy applies to the laws of the place of service provision (EU) and the People's Republic of China.
In case of any dispute, both parties shall negotiate and settle it amicably; if unable to resolve through negotiation, both parties agree that the dispute shall be submitted to a court of competent jurisdiction where ThunderSoft is domiciled.
This policy will be revised from time to time in accordance with adjustments or updates to the business model. We will not reduce your rights under this Privacy Policy without your express consent. We will notify you of changes by means of a push notification. In the event of material changes, we will notify users in a more informative manner.
Significant changes include, but are not limited to:
We will keep an older version of this policy on file for your review. This privacy policy is valid during the operation or provision of the use of the website.
If you have any questions, comments or suggestions regarding this Privacy Policy, or regarding the collection, use, sharing, access, deletion, or correction of your personal information, you can contact us in the following ways:
Customer service e-mail: compliance_data@thundersoft.com
Special Note: ThunderSoft Technology reminds you that if your feedback involves your personal information, especially your sensitive information, please do not disclose it directly on the phone or in the mail. We will communicate with you further under the circumstance of ensuring the security of your personal information.
In some cases, in order to protect security, we may require you to provide a written request or otherwise prove your identity. We will respond to your request within 15 business days of receiving your feedback and verifying your identity.