Cokima Platform Privacy Policy

Formulated by: Kugima Technology (Shenzhen) Co., Ltd.

Effective Date: It will take effect 7 days after the expiration of the publicity period (the specific publicity date is subject to the announcement within the App)

I. Scope of Application of Privacy Policy

1. This policy applies to all services we provide to you through the Cokima App, including but not limited to core functions such as navigation services, dashcam connection, community interaction, and information inquiry, as well as third-party SDKs and services integrated for service provision (see Chapter 6 for details).
2. This policy does not apply to platforms or services independently operated by third parties, or third-party websites accessed through our platform. The handling of your personal information by third parties is subject to their own privacy policies, and we bear no responsibility.
3. The term "personal information" as used in this policy refers to information that is recorded electronically or in other ways and can, either alone or in combination with other information, identify a specific natural person or reflect their activities. "Sensitive personal information" refers to information that, once disclosed or illegally provided, may endanger personal and property safety, or cause infringement of personal dignity (such as mobile phone numbers, device identifiers, WiFi information, etc.).

II. Personal Information We May Collect

We adhere to the principle of "lawfulness, fairness, and necessity", and only collect personal information required to achieve our service objectives, specifically including:

2.1 Information You Actively Provide

• Account registration information: You need to provide your mobile phone number (sensitive personal information) to complete registration and login, which is used to identify your membership status on the platform. You can voluntarily provide non-essential information such as a nickname, avatar, and gender, but not providing it will not affect the use of basic services.
• Function usage-related information: When using community functions to post content or change avatars, the pictures, videos, and other content provided with your authorization; when contacting customer service, the problem description, contact information, and other information actively provided for handling inquiries or complaints.

2.2 Information we automatically collect

• Device Information: To ensure stable service and troubleshooting, we automatically collect your mobile device model, operating system version, device identification code (IMEI/Android ID), MAC address, SIM serial number, IMSI, device serial number, and basic information of the dash cam (including dash cam ID). The aforementioned information is used for device authentication and analysis of abnormal issues.
• Network and location-related information:
  • IP address: used for assigning servers nearby to improve access speed;
  • Location information: Collected with your authorization, used to prevent fraud and ensure information security (only used in necessary scenarios);
  • WiFi information: including the currently connected Wi-Fi BSSID, SSID, and a list of nearby Wi-Fi networks. This information is solely used to identify the hotspot of the recorder device and establish communication between the APP and the recorder. All information is processed locally and is not uploaded to the cloud or any third party.
  • To allocate servers nearby and improve overall user usage and access speed, we will collect your IP address.
  • To achieve the service objectives of "Cokima", the personal information collected by "Cokima" through technical means is limited to your mobile phone ID, WiFi MAC and WiFi scan results, mobile phone MAC and WiFi scan results, SIM serial number Android_ID、IMSI、 Device serial number, basic information of the dash cam (we use phone ID, MAC address, WiFi scan results, SIM serial number, etc.) Android_ID、IMSI、 The device serial number and the ID of the recorder are necessary information to distinguish between problem analysis and feedback after abnormal application software, as well as recorder authentication and usage time.
  • Explanation of MAC sensitive information: We obtain the MAC address and WiFi scan results of the mobile phone in order to uniquely distinguish the mobile phone information, collect APP problem logs, and better analyze and modify specific mobile phone environments to provide users with a better experience;
  • Wi Fi information acquisition instructions: In order to achieve communication between the APP and the recorder device, the APP needs to obtain the current connected Wi Fi information and a list of available Wi Fi in the surrounding area. The specific instructions are as follows:
  • The BSSID and SSID of the current connection: The APP will obtain the BSSID (Basic Service Set Identifier) and SSID (Service Set Identifier) of the current Wi Fi connection to identify whether the current connection is a hotspot for the recorder device. If identified as a recorder device, the APP can directly establish a communication connection.
  • Scan the surrounding Wi Fi list: The APP will scan the Wi Fi network information in the surrounding area to determine if there are saved or paired Wi Fi information of the recorder device, in order to achieve quick identification and automatic connection, improve device connection efficiency and user experience.
  • Privacy protection statement: All Wi Fi information is only used for the identification and connection of the recorder device, and does not involve the specific location information of the user, nor will it be used to track or collect the user's personal data. When collecting relevant network information, the APP strictly complies with relevant laws and regulations as well as the platform's privacy policy to ensure user privacy and security. The obtained BSSID and SSID information will not be uploaded to the cloud or third-party services, and will only be used locally to determine and establish communication connections.
  • Information usage responsibility: We promise to only temporarily access necessary Wi Fi information when users use the recorder function, and all information processing is completed locally on the user's device. We will not disclose, sell, or misuse any information related to Wi Fi networks to ensure the security and transparency of user data usage.
  • To monitor Cokima error anomalies and optimize and upgrade the platform, we will collect information on abnormal operation of application software.
  • To achieve operational fault reporting, analysis, and resolution of the issues you encounter during the process, we will collect your device information (MAC address), browsing and operation records
  • In order to prevent fraud and protect your information security during use, we will collect your device location information.
  • Retrieve the list of installed applications: We retrieve the list of installed applications to enable users to list all the applications on their phone that provide sharing functions when choosing to share videos and photos, in order to achieve a better sharing experience.
  • Read or delete phone storage files/collect SD card data: We need to obtain the storage permission of the phone and read the data of the SD card, so as to save the pictures and videos obtained from recorders and other devices to the corresponding file storage path of the phone, allowing users to view the corresponding data in the corresponding storage path; Simultaneously provide users with the ability to delete these saved files within the app.
  • Obtain the running status: We will obtain information about the currently running process to determine whether the APP is running in the foreground, so that when the APP switches to the background, corresponding device processing business can be carried out.
  • In order to achieve effective communication between the APP and the recorder, the APP will first retrieve the BSSID and SSID of the currently connected WiFi network. The core purpose of this step is to identify and locate the recorder device. By obtaining the BSSID and SSID, the APP can detect devices in the current environment and determine whether they are recorders. Once the target device is confirmed to be a recorder, the APP can immediately establish a direct communication link with it.
• Usage and operation information:
  • Software operation exception information and fault error logs, used for monitoring errors and optimizing the platform;
  • Browse history, operation records, list of installed apps (used to list available apps for sharing function), current running process information (to determine the foreground/background status of the app)
  • Storage-related information: Upon your authorization, we will read/delete files stored on your phone and collect data from your SD card to store images/videos transmitted by the recorder and provide file management functionality.

2.3 Sensor Information Types

• 2.3.1 Used to automatically adjust the interface display effect based on the ambient brightness, optimizing the reading/usage experience;
• 2.3.2 Purpose and method of use:
• The use of the above sensor information is necessary to achieve the core functions of the app that you actively use, and will not exceed the scope of your authorization;
• Sensor data is only temporarily read when you use the corresponding function, and will not be uploaded to the server, nor will it be used for user profiling, targeted push, or other purposes unrelated to the core function;
• You can disable the permission authorization for the corresponding sensor at any time through the device system settings. After disabling, the app will not be able to rely on the sensor to implement related functions, but it will not affect the use of other basic services.
• Sensor information will not be individually recognized as your personal identification information, nor will it be associated with your account, phone number, or other identifiable information;
• Sensor data is only temporarily processed on local devices and will not be permanently stored, shared, transferred, or disclosed to third parties.
• 2.3.3 Collection and Use of Accelerometer Information
• This application will request access to your device's accelerometer, solely for the purpose of implementing the following essential features.
• Device orientation recognition and screen orientation adaptation (such as automatic landscape/portrait switching);
• We will not collect your personal identity information, location information, or movement trajectory through the accelerometer, nor will we use this sensor data for advertising tracking, third-party sharing, or any scenarios beyond the aforementioned purposes. You can disable the app's access to the accelerometer in the device's system settings at any time. After disabling, related functions will be unavailable, but it will not affect the operation of the app's basic functions.
• 2.3.4 This application will only collect user information and device permissions necessary for the implementation of services. All information collection activities comply with laws, regulations, and the review requirements of application stores. We will strictly protect your personal information and will not collect, use, or provide your personal information to third parties without your consent. You can manage relevant permissions and withdraw your consent at any time within the application or in system settings.

2.4 Information provided by third parties

• Relevant information about you shared by third parties when using our services;
• When you use third-party services through the platform, the third party will provide your information based on service requirements (subject to your separate consent, see Chapter 6 for details).

2.5 Permission Application and Usage Instructions

III. How do we use your personal information?

1. Provide core services: Implement basic functions such as navigation, recorder connection, account management, community interaction, file storage and sharing;
2. Optimizing service experience: Based on device information and usage records, optimize product adaptability, fix operational faults, and enhance service stability and operational convenience;
3. Security Guarantee: Identify abnormal behaviors through device information, location information, and operation logs to prevent risks such as account theft and fraud, and protect your account and information security;
4. Service notifications: We will push essential information such as service updates, function optimization tips, and account security reminders to you (non-essential notifications can be disabled through the app settings);
5. Third-party service support: Upon your consent, we may share necessary information with third parties who provide SDKs or supporting services to achieve corresponding functions (see Chapter 6 for details).
6. Compliance requirements: Comply with laws, regulations, and supervisory provisions, and cooperate with judicial and administrative authorities in responding to their legitimate requests for information inquiry.

Restrictions on the Use of Sensitive Personal Information: The processing of sensitive personal information, such as mobile phone numbers, location information, and WiFi information, requires your separate consent. It is only used for the purposes explicitly stated and not for scenarios unrelated to the service.

IV. Storage and Protection of Personal Information

4.1 Storage period

• Account information: From the date of account registration to 15 working days after account cancellation (to handle any outstanding issues related to cancellation);
• Location information, WiFi information, and usage logs: 6 months from the date of generation (anonymized upon expiration);
• Customer service records and fault logs: 1 year from the date of completion of handling (for after-sales traceability and problem review)
• Information required to be retained by laws and regulations: implemented in accordance with relevant regulations (e.g., web logs are retained for no less than 6 months).

4.2 Storage Region

All personal information we collect within the territory of the People's Republic of China is stored on domestic servers and is not transferred overseas. In cases where cross-border transmission is necessary, we will strictly adhere to the provisions of the Personal Information Protection Law, completing legal procedures such as security assessments and obtaining informed consent.

4.3 Safety protection measures

• Technical level: Adopting technologies such as HTTPS encrypted transmission, data desensitization, hierarchical permission management, firewalls, and intrusion detection to prevent information leakage, tampering, and loss;
• Management level: Establish a personal information security management system, clarify the division of responsibilities, restrict employees' information access permissions, and conduct regular security training and audits;
• Emergency response mechanism: Develop an emergency response plan for data breaches. In the event of an information leak, affected users will be notified within 24 hours through registered phone numbers, APP pop-ups, etc., remedial measures will be taken, and reports will be made to regulatory authorities.

V. Your rights to personal information

According to the Personal Information Protection Law of the People's Republic of China, you enjoy the following rights, which can be exercised through designated means:

1. Right to Know: You have the right to access and copy your personal information and the processing rules. The path is: APP "Me" - "Account" - "Personal Information" - "Privacy Management", or contact customer service to apply;
2. Correction right: If you find your personal information to be inaccurate or incomplete, you can submit a correction request through the aforementioned path, and we will verify and handle it within 15 working days;
3. Right to deletion: You may request the deletion of your personal information if:
   • We collect or use information in violation of the agreement;
   • The path for you to log out of your account is: APP "Me" - "Account" - "Personal Information" - "Log Out of Account";
   • Other situations where deletion is legally permitted.
   After account cancellation, we will promptly delete all your personal information (including account, community content, messages, etc.). Once the information is deleted, it cannot be restored. Please exercise caution when proceeding;
4. Withdrawal of consent: You can disable non-essential permissions such as camera, recording, and location through the app settings (disabling these permissions may affect the use of corresponding functions);
5. Right to restriction of processing: In accordance with legal circumstances, you may request restriction of personal information processing by contacting customer service and submitting an application;
6. Data transfer right: You can request to transfer your personal information to a designated processor. Please contact customer service to submit your application, and we will provide a secure transfer method.

Exercise of Rights Instructions: To ensure information security, your identity needs to be verified when exercising the aforementioned rights; we will process and respond within 15 working days after receiving the application, and in complex cases, this period may be extended by another 15 working days.

VI. Sharing, Transfer, and Public Disclosure of Personal Information

6.1 Sharing

We do not share your personal information with third parties. We only share it in the following necessary scenarios, and the scope of sharing is minimized:

• Service provisioning requirements: When entrusting a third party to provide services such as recorder adaptation, map services, and payment services, a confidentiality agreement must be signed with the third party, requiring them to process information only according to our instructions and not for any other purposes;
• Security and compliance requirements: Provide information to public security organs and regulatory authorities for the prevention of illegal activities and cooperation with law enforcement investigations;
• Other scenarios where you separately agree: Sharing with third parties as agreed, subject to your explicit authorization.

6.2 Description of Third-party SDK

To achieve specific functions, the platform has integrated third-party SDKs. The personal information collected by the SDKs and the privacy policy are as follows: Click to read more details. (For a detailed list, see "Settings" - "Privacy Management" - "Third-party SDK Description" in the app):

• SDK name and provider: will be listed item by item;
• Type of information collected: Only the necessary information required for functionality (such as device information, WiFi information, etc.)
• Privacy Policy Link: Provides an official third-party privacy policy inquiry portal;
• You can disable the authorization for the corresponding SDK through the app settings (which may result in the inability to use related functions).

6.3 Transfer and Public Disclosure

• Transfer: We do not transfer your personal information. If transfer is necessary, we will obtain your separate written consent and require the transferee to comply with this policy, as well as laws and regulations;
• Public disclosure: Public disclosure is only allowed in scenarios where you actively request it or where it is required by laws and regulations, and desensitization will be applied.

VII. Privacy Protection for Minors

1. If you are a minor under the age of 18, you should read this policy in the presence of your legal guardian and use the service only after obtaining your guardian's explicit consent;
2. We do not actively collect sensitive personal information from minors. If collection is necessary for service purposes, separate consent from the guardian must be obtained;
3. Guardians have the right to access, copy, correct, and delete the personal information of minors. They can submit an application through customer service channels (proof of guardianship is required).

VIII. Updates to Privacy Policy

1. We reserve the right to update this Privacy Policy based on business development, amendments to laws and regulations, and other circumstances. Once updated, the new policy will be announced through various means such as pop-up windows on the APP, bulletin boards, and text messages sent to registered mobile phone numbers. The updated policy will take effect automatically 7 days after the announcement period ends.
2. Your continued use of the service is deemed as acceptance of the updated policy. If you do not agree, you should immediately stop using the service;
3. The privacy policies of historical versions will be retained in the APP for no less than 30 days for your reference.

IX. Contact Us

If you have any questions about this Privacy Policy, need to exercise your personal information rights, provide feedback, or report any violations, you can contact us through the following methods:

X. Dispute Resolution

1. The interpretation and application of this Privacy Policy shall be governed by the laws of the People's Republic of China (excluding conflict of laws rules);
2. Any dispute arising from this policy shall be resolved through friendly negotiation between the parties. If the negotiation fails, either party shall have the right to bring a lawsuit to the people's court with jurisdiction over the location of Kugima Technology (Shenzhen) Co., Ltd. (Shenzhen City).