Privacy Statement

Version update date:	Version effective date:
[ 7th MAY 2025 ]	[ 17th APR 2024 ]

Omoda & Jaecoo UK Limited (“O&J”, “we” or “us”) is committed to protecting your personal information and respecting your privacy. This Privacy Policy gives you information about how O&J collects and uses your personal data through your use of this website, including any data you may provide when you registered with us or sign up to our newsletter or purchase a product or service.

Omoda & Jaecoo UK Limited is the controller and responsible for your personal data (collectively referred to as “O&J“, “we“, “us” or “our” in this privacy statement)

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO or us using the information set out in (Paragraph 9).

This Privacy Statement does not apply to:

The processing of personal data when you use our vehicle;
Your use of third-party services in our website. The data processing of these services is subject to their individual privacy policies, which we strongly advise you to read carefully;
Your use of mobile apps provided by O&J;
Our employee personal data or candidate recruiting practices.

In this Privacy Statement, we will explain to you:

1. What personal data we collect and how do we use it?
2. What third-party services do we use?
3. With whom will we share this data?
4. How do we transfer your data outside your region?
5. What rights do you have in relation to your personal data?
6. How long do we retain your data?
7. How do we protect your data?
8. Privacy of children
9. How can you contact us and make a request？
10. How will we update this Privacy Statement?

1. What personal data we collect and how do we use it?

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you during the following circumstances and to make our products and services as effective as possible, and to protect our IT systems from attacks and other illegal activities.

We process your personal data based on one or more of the following legal grounds: your explicit consent, the necessity to perform a contract, compliance with legal obligations, or our legitimate interests, which will be clearly communicated to you at the time your information is collected. We will not store, process, or share your data with parties beyond those specified unless we have a valid legal basis to do so.

O&J has a legitimate interest in processing personal data to deliver and improve our products and services. This includes responding to customer enquiries, handling issues or complaints, and conducting analysis to better tailor our offerings to meet customer needs.

We rely on legitimate interests as our legal basis for processing your personal data when you act on behalf of a business or other corporate entity. This includes using your information to send you marketing communications related to our services.

To communicate with you:

Data Processing Purpose	Type of Personal Data Collected	Legal Basis for Processing
To fulfil requests or service appointments you make to us, including test drives, after-sale service and event appointments (via our website appointment page, email or our call centre)	Your contact information, including your first name, your last name, phone number, and email address (note: we may contact you to confirm your booking or request) Recordings and transcripts of calls and communications between us	Performance of a contract with you or necessary in order to take steps at your request prior to entering into a contract Where you have provided your consent for recordings [For business-to-business sales and marketing support activities directed at corporate subscribers, recordings and transcripts of calls and communications is carried out on the basis of our legitimate interests, including for quality assurance and training purposes, unless you object to such processing.]
To respond to any feedback, requests, questions, or complaints you may have regarding our products and services (in person, online, telephone, email, our call centre, etc.)	Your contact information, including your first name, your last name, your phone number, and your email address. Communication and interactions information, including your request details. Recordings and transcripts of calls and communications between us.	Performance of a contract with you or necessary in order to take steps at your request prior to entering into a contract Necessary for our legitimate interests: to administer customers inquiries and requests, to improve customer service quality and customer satisfaction Where you have provided your consent for recordings
To participate in surveys or our offline event about your experience with our products and services	Account information Your contact information, including your name, email address Survey or feedback details	Necessary for our legitimate interests: to understand, analyse and improve customer experience
Sign up for marketing communications or stay informed with our lasted news	Your basic information, including your first name, your last name, phone number, email address	Where you have provided your consent.

To realize our product functions and services, and to understand and improve our products and services:

Data Processing Purpose

Type of Personal Data Collected

Legal Basis for Processing

To find a dealer near you

Your contact information, including your postal code and precise location.

Where you have provided your consent.

To understand and analyse website UI behaviour and usage, so as to improve our services

Analytics data (aggregated data on UI behaviour, usage and analytics of website.

Necessary for our legitimate interests: to understand, analyse and improve customer experience

Where you have provided your consent (website cookies)

To ensure information security:

Data Processing Purpose

Type of Personal Data Collected

Legal Basis for Processing

To detect and defend against unauthorized access to data, and to enhance information security

Device information

Network activity information

Necessary for our legitimate interests: to protect the confidentiality, integrity, and availability of IT systems

To upload crash logs for troubleshooting

Relevant crash logs

Where you have provided your consent

Other circumstances

Data Processing Purpose

Type of Personal Data Collected

Legal Basis for Processing

To demonstrate compliance with regulatory requirements

Contact information

Order information

Vehicle information

Necessary to comply with a legal obligation

O&J has a legitimate interest in processing personal data to provide products or services to our customers which include responding to queries, issues or complaints as well as conducting analysis to tailor our products and offering to our customers.

2. What third-party services do we use?

In order to provide you with better service, we may entrust a cooperative third party to process your personal data. We are not responsible for the collection or use of personal data by third party services, and we recommend that you read the applicable terms and conditions (and any relevant privacy statements/policy/notice) carefully before using such services and make your own choice after ensuring that you fully understand the rules governing process of your personal data. If you have any questions about the process of your personal data by a specific third party, please contact that third party directly. The table below provides information on the third parties we might engage for the processing of your personal data, if any:

Third-Party Service	Purpose and Use	Link to Third-Party’s Privacy Policy
Cookie Bot by usercentrics	Purpose: Cookiebot is used to manage cookie consent and compliance with data protection regulations, including GDPR. It collects data on user preferences and consents related to cookies and tracking technologies. Data Collected: Cookiebot may collect information such as the user’s consent status, cookie preferences, and interactions with consent banners or pop-ups. Usage: This data helps us ensure that we only place cookies on your device that you have explicitly consented to. Cookiebot’s compliance tools help us provide transparency about the cookies we use and enable you to manage your cookie preferences.	Privacy Policy (Cookiebot)
Google Analytics	Purpose: Google Analytics is used to track and analyse user behaviour on our website. This includes collecting data on page views, session duration, bounce rates, traffic sources, and user interactions. Data Collected: Google Analytics collects information such as IP addresses, device information, browser type, location data, and usage patterns. Usage: The data collected helps us understand how users interact with our website, assess the performance of our content and features, and make improvements to enhance the user experience. The data may also be used for reporting and analysis.	Google Privacy Policy Marketing Platform Privacy Policy
Mapbox	Purpose: Mapbox is used to provide interactive maps and location services on our website. It may collect data on user interactions with the maps and location-based features. Data Collected: Mapbox may collect data such as IP addresses, location data, device information, and interactions with maps. Usage: This data helps us offer accurate and relevant location-based content and features.	Mapbox Privacy Policy
Google Maps API	Purpose: Google Maps API is used to integrate Google Maps and related services into our website. It may collect data on user interactions with the maps and location-based services. Data Collected: Google Maps API may collect data such as IP addresses, location data, and user interactions with maps and other map-related features. Usage: The data collected is used to provide users with map and location-based services, such as showing their current location or finding nearby places of interest. The data may also be used for reporting and analysis to improve the services.	Google Developer Google Developer (map)
Driftrock	Purpose: Driftrock is used to process and manage customer leads and enquiries securely. Data collected: First Name, Last Name, Email, Phone Number, Postcode, Model of interest, opt-in permissions and test drive interest. Use: Driftrock validates leads and sends customer leads/enquiries to their nearest OMODA & JAECOO retailer based on the postcode entered on the contact forms, or direct to the brand’s customer service team.	Driftrock Privacy Policy

3. With whom will we share this data?

3.1 Affiliates and subsidiaries

3.1

To assist, operate, enhance, and fulfil services on our behalf based on our legitimate interests to outsource certain operations, we share personal data with our affiliates and subsidiaries.

3.2 Services providers and business partners as data processors:

3.2

We share data with our services providers and partners to maintain our business operations, our relationship with you, and provide you with our services:

Categories of providers	Legal Basis for Processing
Authorised retailer(s) (and its sub-processors)	Personal data is transferred to authorised retailer(s) for the purpose of communication and administration of the handover of cars (if applicable).
Marketing and advertising suppliers	To assist, operate and fulfil services with marketing services or with digital advertising.
Cloud service providers	To enhance vehicle function and provide cloud service.
Authorised product partners and service providers	Personal data is transferred to authorised product partners and service providers for the purpose of communication and administration of supporting products and services (if applicable).

3.3 Law enforcement and government authorities

3.3

To fulfil our legal obligations, we may be required to disclose information in response to subpoenas, court orders, or lawful requests from government authorities conducting investigations. This includes compliance with law enforcement requirements, regulatory inquiries, and the verification or enforcement of our policies and procedures. We may also disclose information in emergency situations to prevent or halt potentially illegal, unethical, or legally actionable activities. When we receive a request for personal data from a law enforcement authority, we assess the necessity and proportionality of the requested information.

4. How do we transfer your data outside your region?

In principle, the personal data we collect is stored in the countries of your place of residence or within the UK, your data will be stored at our data centre located in the UK.

We, as an international company, share your personal data with group companies, subcontractors, and business partners worldwide. Specifically, we transfer personal data for IT-support, hosting services, maintenance, and customer service.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us at privacy@omodaauto.co.uk

5. What rights do you have in relation to your personal data?

5.2 Right to access your personal data

5.2

You have the right to request information about the personal data we hold regarding you. Upon request, we will provide you with a copy of your personal data.

5.3 Right to rectification

5.3

You may request from us the rectification of incorrect or incomplete personal data concerning you. We make reasonable efforts to keep personal data in our possession or control, which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.

5.4 Right to restriction

5.4

You may request from us the restriction of processing of your personal data, if:

You contest the accuracy of your personal data, for the period we need to verify the accuracy;
The processing is unlawful, and you request the restriction of processing rather than erasure of your personal data;
We no longer need your personal data for the processing purpose, but you require them for the establishment, exercise, or defence of legal claims; or
You object to the processing while we verify whether our legitimate grounds override yours.

5.5 Right to portability

5.5

You have the right to receive your personal data provided to us and, where technically feasible, request its transfer to another organization. This right applies if we process your personal data through automated means, based on your consent or for the performance of a contract you are a party to. Your personal data must have been provided by you, and this right should not adversely affect the rights and freedoms of others. You can receive your personal data in a structured, commonly used, and machine-readable format. The transmission of your personal data to another organization is subject to technical feasibility.

5.6 Right to erasure

5.6

You have the right to request that we delete the personal data we process about you. We must comply with this request unless the processing of your personal data is necessary for:

Compliance with a legal obligation requiring processing by laws to which we are subject;
Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes; or
The establishment, exercise, or defence of legal claims.

5.7 Right to object

5.7

You have the right to object, at any time, to the processing of your personal data based on our legitimate interests or the legitimate interests of a third party, provided that the processing is not based on your consent. If you exercise this right, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if the processing is necessary for legal claims. If you object to the processing, please let us know if you also wish for your personal data to be erased.

5.8 Right to be informed

5.8

You have the right to be informed about the collection and use of your personal data. We have prepared this Statement for this purpose, and you will be informed of any changes to this Statement.

5.9 Right to lodge a complaint

5.9

You have the right to lodge a complaint with your local data protection supervisory authority. However, we would appreciate it if you first contact us to try to solve your issue – you can find our contact details in Section 9.

6. How long do we retain your data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Once the data is no longer necessary for these purposes, we either delete it or retain it in an anonymized form. In determining the appropriate retention period, we take into account various criteria, including the type of services requested by or provided to you, the nature of our relationship with you, the potential impact on the services we provide to you if we delete certain data about you, and the retention periods mandated by law.

7. How do we protect your data?

We strive to maintain high security standards and have implemented robust technical and organizational measures to protect your data, in accordance with the current, general state of technology. We ensure that your personal data is adequately secured against loss, falsification or unauthorized access. However, please note that the transmission of information via the internet is not completely secure. While we do our best to protect your personal data, we cannot guarantee 100% security of your data transmitted to us.

Once we have received your personal data, we use strict procedures and security features to prevent unauthorized access. In the unfortunate event of a personal data incident, we will report it and take remedial measures in accordance with the requirements of the law and regulatory authorities.

We take the security and privacy of your data seriously. To ensure the highest standards of data protection, all personal data collected through our services is stored in a secure data storage centre located in LONDON, UK. This location adheres to the stringent data protection regulations set by the UK General Data Protection Regulation (UK GDPR) and The Data Protection Act (DPA) (hereinafter referred to as applicable law).

8. Privacy of children

We do not knowingly collect or use any personal data from children (as defined by applicable law) without prior, verifiable consent which is given or authorized by the holder of parental responsibility over the child. We do not knowingly allow children to order our vehicles, communicate with us, or use any of our online services.

If you become aware that a child has provided us with personal data, please contact us (privacy@omodaauto.co.uk). We will take all reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where necessary to protect the safety of the child or others as required by law.

9. How can you contact us and make a request？

If you have any questions about the processing of your personal data, we recommend reading through this Privacy Statement first.

To make a query, raise a concern, or exercise your data subject rights, please feel free to contact us via: E-mail Address: privacy@omodaauto.co.uk

We take your privacy seriously and aim to respond to you within one month or within the timeline specified by the relevant local privacy protection law, after confirming your identity. If you believe that we have not adequately addressed your complaints or concerns, you have the right to lodge a complaint with a competent data protection authority.

10. How will we update this Privacy Statement?

We may update this Privacy Statement, for example, to reflect changes in our business operations and measures for protecting personal information. If we make changes to this Privacy Statement, we will notify you. Where changes to this Privacy Statement significantly impact the nature of our data processing or have a substantial effect on you, we will provide sufficient advance notice, allowing you the opportunity to exercise any applicable rights.

Privacy Statement

1. What personal data we collect and how do we use it?

2. What third-party services do we use?

3. With whom will we share this data?

3.1 Affiliates and subsidiaries

3.2 Services providers and business partners as data processors:

3.3 Law enforcement and government authorities

4. How do we transfer your data outside your region?

5. What rights do you have in relation to your personal data?

5.1 Right to withdraw consent

5.2 Right to access your personal data

5.3 Right to rectification

5.4 Right to restriction

5.5 Right to portability

5.6 Right to erasure

5.7 Right to object

5.8 Right to be informed

5.9 Right to lodge a complaint

6. How long do we retain your data?

7. How do we protect your data?

8. Privacy of children

9. How can you contact us and make a request？

10. How will we update this Privacy Statement?