Last updated: 10 December 2024
This policy describes how SMART MOBILITY INTERNATIONAL COMMERCIAL AGENCIES L.L.C (also referred to as “ Avatr ”, “ we ” or “ us ”) will make use of your data when you use the AVATR App (hereafter referred to as the “ App ”) provided by us online ( “ Services ” ) .
The AVATR App offers a variety of functionalities, each involving different types of personal data processing. Depending on your market and subscription type, these functionalities include : User account, Vehicle binding, Remote vehicle status checking, Remote vehicle control, Bluetooth Key, and App Analytics .
It also describes your data protection rights, including the right to object to some of the processing which Avatr carries out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
This privacy policy only applies to the Services and is in addition to any other privacy policy or notice that may apply to your interactions with Avatr.
To comply with regional laws and regulations, we may apply different privacy policies for different regions. Please note that this privacy policy is intended for United Arab Emirates user s . Once the Services we provide are extended, we will update this policy and obtain your consent.
We use your personal data for the purposes and the legal bases set out below.
Where we process your personal data to fulfil a legitimate interest, then we have carried out a balancing test to consider whether our interests are overridden by your interests and rights.
Where we collect your personal data to perform a contract with you, or where we have to collect personal data by law, the provision of this data is mandatory and we will not be able to provide Services to you without this information. In all other cases, the provision of any requested personal data is optional, but not providing information may affect your ability to use the Services or use particular aspects of the Services if the information is needed for those purposes.
2.1 User account
To enable you to become our user and to provide you with the subsequent registered user login, password retrieval, and account deactivation features, we collect your email address , v erification code, and login password when you register. After logging in for the first time, you have the option to use your phone number and login password as the login method in your personal settings.
Additionally, if you wish to authorize other users to use your vehicle, we will also collect the authorized users ’ email address es , the validity period of their accounts, and the vehicle control permissions.
2.2 Vehicle binding
For your convenience in using our Services, you can link your vehicle information with the App. To further identify your vehicle’s uniqueness, we collect your user ID, email address, verification code as well as your vehicle’s VIN , name, and binding status .
2.3 Remote vehicle status checking
To provide you with the latest status of your vehicle, we will collect the vehicle status per your request, which includes your vehicle’s VIN and control car security code , vehicle binding related information, gear status, in- vehicle temperature, air conditioning settings, air quality information, temperature control information , steering wheel heating , door status , vehicle unlock / lock status , window status , seat ventilation settings , seat temperature condition information , vehicle speed, total electric mileage, remaining range, battery remaining capacity, battery voltage, battery current, battery temperature, battery usage management information, battery charging history, charging status information , charging reservation information .
2.4 Remote vehicle control
To provide you with convenient vehicle services and troubleshoot vehicle malfunctions through vehicle data, you can remotely control your vehicle. When using this feature, we collect your vehicle’s VIN and control car security code, vehicle status information, car light status, horn status, door status, vehicle unlock / lock status , window status, vehicle door open/close status, charging setting, air conditioning settings, seat ventilation settings , steering wheel heating status , temperature control information, seat temperature condition information .
To facilitate Bluetooth k ey feature, we will collect your u ser ID , vehicle’s VIN, door status, window status, vehicle door open/close status, car light status, horn status, vehicle’s location information , mobile device unique identification code, mobile Bluetooth MAC address, and mobile operation log information . If you link your phone to the vehicle’s location automatically (enhanced feature), we will also collect your mobile GPS information.
To enhance your experience of the App and our Services, we will collect your email address, mobile phone number (optional), detailed description of the submitted problem , time of problem occurrence (optional), pictures or videos (optional), vehicle’s VIN , vehicle version number, mobile phone model, app version number, and mobile phone system version .
We will also collect some cached data , including vehicle list data cache, vehicle (default vehicle) all status/data cache (all vehicle data), digital key data cache, and account information.
If you have given us your consent, we process the data mentioned above based on your consent otherwise our legitimate interests (to analyse the effectiveness of our products to improve them).
We may share your personal data as described in Section 2 with affiliates, processors and third-parties as follows.
3.1 Our affiliates
We will share your personal data with our affiliates for the purposes of helping us to provide the vehicle and the Services to you.
3.2 Authorities
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Personal data that we collect from you will be stored in local data centres. H owever , it may be transferred to a destination outside your country in certain circumstances. Where these locations do not provide an adequate level of data protection, we ensure appropriate safeguards are in place to protect the transfer of your personal data to these countries in accordance with applicable laws in your jurisdiction.
You have specific legal rights relating to the personal data we process about you. The rights may differ depending on which jurisdiction you are in and the nature of the processing. Generally, your rights concern the possibility to:
As mentioned, these rights are not absolute and in some cases data protection law limits their application. Should this be the case for a request you make to us, we will always explain why we cannot fulfil your request.
We will consider all the above requests and provide our response within a reasonable period (and in any event within any time required by applicable law). Please note however that under certain circumstances the above rights may be restricted. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
5.2 Right to lodge a complaint
You also have the right to lodge a complaint with your local data protection authority if you believe we have not complied with applicable data protection laws. The relevant local authority differs depending on your country of residence.
We retain your personal data we collect for as long we continue to make the Service available to you, for as long as it is required to fulfil the purposes of the processing of personal data, or as required by law .
If you withdraw consent for our processing of personal data where we have asked for your consent, then we make sure your personal data is not available shortly after receiving the request (to allow us to implement your requests) .
We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
The data controller for your personal data is SMART MOBILITY INTERNATIONAL COMMERCIAL AGENCIES L.L.C .
If you have questions about this Privacy Policy or wish to contact us for any reason in relation to our personal data processing, please contact us at avatr@smartmobilityint.com .
I, the data subject: ___________ (full name), main identification document: ___________________ (type, series, number, date of issue, issuing authority), registered address: __________________________ , represented by the representative of the data subject (to be filled out with the consent of the representative of the data subject) _____________________ (full name), main identification document: ________________________________________ (name, series, number, date of issue, issuing authority), registered address: ___________________________, _______________________ (details of the power of attorney or other document confirming the representative ’ s authority), in accordance with Federal Decree-Law No.45 of 2021 on Personal Data Protection , hereby give specific, substantial, informed, conscious, and explicit consent to the following parties for the processing of my personal data.
Purposes are as follows:
This consent form authorizes the processing of the following list of personal data [1] :
I authorize the automated and non-automated processing of my personal data, including:
Dealers, Distributors, Manufacturers, and their authorized personnel and contractors shall undertake to maintain confidentiality and ensure that their authorized personnel and contractors keep confidential the information provided under this consent form.
This consent form is valid for the entire period of the App use, but not less than 5 (five) years. The data subject has the right to withdraw this consent form by sending a written notice revoking the consent to process personal data to any party that granted the consent form, or by selecting the appropriate menu item in the App .
Date: ______________
Name: _____________
Signature: __________