Current as of 25 May 2022

Privacy Policy

This policy applies to the ECARX group of companies. The website is operated by an entity within the ECARX group ("ECARX").

If you contact us using the email addresses on our website, your information will be received by ECARX Limited, a company registered in England and Wales ("ECARX Limited")

ECARX respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how ECARX collects and processes your personal data through your use of this website, including any data you may provide through this website when you make an enquiry or application for funding.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

ECARX is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We are 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 us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us by email at contact@ecarxgroup.com.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes email address, mail address and telephone numbers.
  • Financial Data includes bank account, financial accounts and salary information.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless these are disclosed to us by you as being relevant to a particular grant enquiry or application. Nor do we collect any information about criminal convictions and offences unless these are disclosed to us by you.

Where we need to collect personal data by law or otherwise and you fail to provide that data when requested, we may not be able provide you with funding. In this case, we may be unable to progress matters further.

How is your personal data collected?

We use different methods to collect data from and about you including through direct interactions.

You may give us your Identity, Contact and Financial Data by corresponding with us by email or otherwise. This includes personal data you provide when you:

  • request information to be sent to you; and
  • give us feedback or contact us.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To respond to any communications you have sent us.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

If you contact us by email at contact@ecarxgroup.com, media@ecarxgroup.com or ir@ecarxgroup.com, it will be received by our group company, ECARX Limited. If you are making an investor relations enquiry, your email may be shared with our investor relation advisors, Teneo Strategy Limited, Teneo China Limited and Teneo Strategy LLC ("Teneo"). We have in place appropriate safeguards to share your personal information with Teneo and where appropriate, anonymise any personal data that is shared with them.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To enter into an agreement with you

  • Identity
  • Contact

Performance of a contract with you

To manage our relationship with you which will include:

  • Notifying you about changes to our terms or privacy policy
  • Responding to communications
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Performance of a contract with you
  • Investor relations
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how applicants use our services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity
  • Contact
  • Technical
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation

International transfers

We may share your personal data within the ECARX group which includes companies in different jurisdictions. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

Notwithstanding the above, where appropriate, we anonymise your personal data once it has been received before sharing it with any group companies or third parties.

Data retention

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. As a matter of policy, we do not retain information on our systems for more than six years, but 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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you may have rights under data protection laws in relation to your personal data including to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.