This Privacy Policy takes effect from 1 August 2026.
ESAVVO INTERNATIONAL LIMITED (hereinafter referred to as "we", "us", "our" or "ESAVVO") understands and values the importance of your personal information and privacy, and will make every effort to protect the security of your personal information and privacy.
We will explain through this ESAVVO Privacy Policy (hereinafter referred to as "this Privacy Policy" or "this Policy") how we collect, use, store, share and transfer your information when you visit our websites, use our products and services, as well as the ways we provide for you to access, update, delete and protect such information.
Please read and fully understand all the contents of this Privacy Policy carefully, especially the clauses relating to exemption and limitation of liability, and clauses on the collection, use, sharing and transfer of personal information.
This Privacy Policy applies to all situations where you browse our websites, use our products, use our services and interact with us, including but not limited to:
We will process your personal information in accordance with the provisions of this Privacy Policy. Once you start using our services or provide your personal information to us, it means that you have fully understood and agreed to this Privacy Policy. Our websites and/or products and/or services include some core functions, which include the functions necessary for web browsing, account registration and login, device activation, and functions necessary for security. We may collect, store and use information related to you in order to realise the above functions. If you do not provide the relevant information, you will not be able to enjoy the services we provide.
By providing personal information to us or using our services, you indicate that you understand and agree to all the provisions set out in this Privacy Policy, including but not limited to: agreeing that we collect your personal information in accordance with this Privacy Policy and use, store and share such personal information in the manner described in this Privacy Policy. If you have any questions about this Privacy Policy, you may contact us through the contact information set out in this Privacy Policy.
Please be aware that our websites and services may contain links to applications or websites that are independently provided by third parties. Such services are provided or operated by third parties, and your use of third-party services and the information you provide to third parties will be subject to the user agreements and privacy provisions of such third parties, not to this Privacy Policy. We assume no legal liability for the content or security of other websites or applications to which we link, or whether they have taken adequate privacy protection measures. We recommend that when you link to other applications or websites, you carefully read the user agreements, privacy policies or statements of those applications or websites, and then decide for yourself whether to agree to such privacy policies or statements and whether to use such third-party services.
This Privacy Policy mainly includes the following contents:
"Personal information" means all kinds of information relating to an identified or identifiable natural person, recorded electronically or by other means, but does not include anonymised information. "Sensitive personal information" means personal information that, once leaked or illegally used, may easily infringe upon the dignity of a natural person or harm personal or property safety, including biometric information, religious beliefs, specific identities, medical health, financial accounts, location tracking, as well as personal information of minors under the age of 16.
1.1 ESAVVO collects personal information only to the minimum extent necessary to provide services. We collect, through our websites, the personal information needed to provide services only in the following business functions and scenarios described in this Privacy Policy:
1.2 To implement certain functions of the software, we may embed third-party SDKs in the software. We will carefully evaluate the purposes for which third parties use shared information, comprehensively assess the security capabilities of these third parties, and require them to comply with cooperative legal agreements. We will conduct strict security monitoring of software development kits (SDKs), application programming interfaces (APIs) and H5 that obtain information from third parties to protect data security. Additionally, sharing your personal information with our third parties will be subject to your authorisation and consent, unless the shared information has been de-identified and the third party cannot re-identify the natural person to whom such information relates. If the third party's use of the information goes beyond the scope of the original authorised consent, they will need to obtain your consent again. If there is any future information about such third-party SDKs, we will update the table below:
| Serial No. | Third-party SDK Name | Purpose of Information Collection | Usage Scenario | Types of Personal Information | Third-party SDK Company and Website |
|---|---|---|---|---|---|
| 1 | OpenStreet | Provide navigation and location services | Cycling navigation, outdoor sports navigation, route books | Device information [including device identification information (Android ID, IDFA, IDFV), system information (OS version, device brand and model, device configuration) and application information (app name)], location information, network type [e.g., mobile network, Wi-Fi] | OpenStreet open platform |
| 2 | Agora | Audio collection, voice chat | Voice dialogue during cycling | Microphone | Agora API Center |
1.3 You may choose not to provide certain information. However, this may limit your ability to use some of our services. When we ask you to provide certain information, we will endeavour to help you accurately understand the relevant restrictions so as to help you decide whether to provide such information. For further information, please feel free to contact our customer service department via the contact details provided in this Privacy Policy, or directly communicate with the staff responsible for personal information protection.
You acknowledge and agree that if you choose to register a unified ESAVVO account when using services such as ESAVVO official websites and ESAVVO official App, the personal information of that same ESAVVO account (including order information, payment information, etc.) will be synchronised across the above services. You may also modify the relevant personal information in the settings interface of the specific service.
Device activation: When you activate your device through our websites, you need to provide the serial number (SN) of the product you purchased.
Location information: When you use the activity and AI sports functions through our App, we will obtain your location information only with your consent. If you do not agree to obtain location information, some functions will not be available.
Use of after-sales service and customer service: When you use after-sales service and customer service, we may collect the following information: user information - your name and contact information; device information - the serial number (SN) of the product you purchased; and other information - order number and valid proof of purchase.
1.4 Methods of collecting personal information. When we collect personal information, we generally notify you in advance and seek your consent. We may collect personal information through the following means:
1.5 You fully acknowledge and agree that, in accordance with relevant regulations and standards, we may collect and use personal information without your consent in the following circumstances:
1.6 We will only collect and use your personal information within the scope and purposes set out in this Privacy Policy. When we intend to use your personal information for other purposes not covered in this Policy, we will notify you in advance and obtain your prior consent through an affirmative action by you.
We are committed to earning and maintaining your trust. We will not share your personal information with other companies, organisations or individuals for their commercial purposes, except in the following cases:
We will not transfer your personal information to any company, organisation or individual, except in the following cases:
We will only publicly disclose your personal information in the following cases, and with security protection measures that comply with industry standards:
In the following circumstances, sharing, transferring and publicly disclosing personal information does not require your authorisation or consent:
After collecting personal information, if our technical resources permit or if mandatory laws and regulations so require, we will carry out de-identification processing and adopt technical and managerial measures to store the information that can be used to restore identification of individuals separately from the de-identified information, and strengthen access and usage permission management. When we store sensitive personal information, we will adopt encryption and other security measures. For particularly sensitive personal information, we will take enhanced protection measures.
4.1 After collecting personal information, if our technical resources permit or if mandatory laws and regulations so require, we will carry out de-identification processing and adopt technical and managerial measures to store the information that can be used to restore identification of individuals separately from the de-identified information, and strengthen access and usage permission management. When we store sensitive personal information, we will adopt encryption and other security measures. For particularly sensitive personal information, we will take enhanced protection measures.
4.2 We retain your personal information only for the period necessary for the purposes set out in this Policy and for the minimum period required by laws, regulations and regulatory requirements. After the above period expires, we will immediately destroy the collected and stored personal information. For personal information stored in program file formats, we will use technical tools that prevent information recovery for destruction. Personal information printed on paper documents, printed media or any other files will be destroyed by shredding or directly incinerated. Where laws and regulations have other mandatory requirements, we will process the information in accordance with those mandatory requirements.
4.3 Generally, ESAVVO will delete the collected and stored personal information after the purposes of collection and use have been achieved. If laws and regulations require that personal information be retained, the personal information will be stored and managed separately from other information, and will not be used for any other purpose except for performing mandatory legal obligations.
4.4 Photos and videos generated by users when using ESAVVO products are stored in the product and the user's mobile device, and will not be uploaded to the network without the user's permission.
5.1 We are committed to protecting your personal information to the best of our ability. We will protect your personal information with appropriate security measures to prevent it from being leaked or damaged due to hacker attacks, computer viruses or other incidents, and to prevent it from being used, accessed, altered or disclosed without your permission. In addition, ESAVVO limits the number of staff responsible for processing personal information to a minimum, and conducts regular training to ensure they comply with their confidentiality obligations regarding your personal information.
5.2 The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. We strongly recommend that you use secure methods and complex passwords to help us ensure the security of your account. In the unfortunate event of a personal information security incident, we will, in accordance with legal requirements, promptly inform you of: the basic circumstances and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and mitigate risks on your own, and remedial measures for you. At the same time, we will promptly inform you of the incident by email, letter, telephone, push notification, etc. Where it is difficult to inform each data subject individually, we will take reasonable and effective measures to publish a public notice. We will also proactively report the handling of the personal information security incident to the regulatory authorities in accordance with regulatory requirements.
5.3 ESAVVO products purchased by users are bound to the user account through the device ID. When a device is lost, all information in the device will be locked. If any other account is found to bind the device, all personal information stored in the device will be deleted, so that the user's personal information will not be disclosed.
6.1 A cookie is a small text file that a website stores on your computer. Cookies are widely used for the operation of this website, or to help ESAVVO operate this website in a more efficient manner and to transfer information to the website owner. Cookies can be used to store content such as identifiers and user preferences. Where browser preferences allow, websites may install cookies in the browser you use.
6.2 When you visit our websites, ESAVVO, its service providers or other third parties may place cookies in your web browser to facilitate your use of our websites. When you visit the ESAVVO websites, the following types of cookies may be used:
6.3 Most browsers are set to accept cookies by default. However, you can delete or refuse cookies in your browser settings. Please note that such actions may affect the availability and functionality of ESAVVO websites.
6.4 For more information on controlling cookies, please check your browser or device settings to learn how to control or refuse cookies.
7.1 If you wish to access, update, delete, withdraw your consent, or correct your personal information, please write to us or send an email to the email address provided below.
Responsible department: [ESAVVO User Privacy Protection Team]
Email: [esavvo@esavvo.com]
We will process your request within 72 hours.
You have the right to request access to and/or correction of any personal information about you that we hold. When you update your personal information, we will verify your identity before processing your request. Once we have sufficient information to process your request to access or correct your personal information, we will respond to your request within the time period prescribed by applicable law.
We usually provide these services free of charge, but reserve the right to charge a reasonable fee for your data access requests.
If you believe that we have processed your personal information in violation of laws, administrative regulations or our agreement with you, you may contact us through the contact information below and request the deletion of the relevant personal information. We will inform you of the relevant handling results after verification. If you are an enterprise end-user, you may submit a request to your enterprise administrator to delete your personal information.
For more details about the personal information associated with your ESAVVO account, you can access and change it by logging into your account through your device.
You may withdraw your consent previously granted for specific purposes, including the collection, use and/or disclosure of your personal information in our possession or control, by submitting a request. Depending on the specific service you use, you may contact us through the contact information in this clause to carry out the relevant operations. We will process your request within a reasonable time after you make the request, and will thereafter no longer collect, use and/or disclose your personal information in accordance with your request.
Depending on the scope of your withdrawal of consent, you may not be able to continue to enjoy ESAVVO's products or services. However, your withdrawal of consent or authorisation will not affect the validity of the personal information processing activities we carried out based on your prior consent.
In the following circumstances, we will not be able to respond to your request:
8.1 We strictly comply with local regulations regarding the protection of children's personal information, including but not limited to COPPA, GDPR and other agreements.
8.2 Our services are intended for users aged 16 or above. Except as required by applicable law, we do not knowingly collect personal information from anyone under the age of 16. If you are a minor (i.e., a "child"), please do not register or use our services. If we have evidence that we collected personal information of a child without prior age verification, we will take steps to delete such information as soon as possible upon becoming aware and verifying the situation.
8.3 For cases where we collect personal information of minors with the consent of their guardians, we will only use or publicly disclose such information as permitted by law, with the explicit consent of the guardian, or as necessary to protect the minor.
8.4 If we discover that we have collected personal information of a minor without verifiable prior parental consent, we will take steps to delete the relevant data as soon as possible.
9.1 You may cancel your ESAVVO account through the following path: "ESAVVO - Settings - Account Centre - Cancel Account".
9.2 After you cancel your ESAVVO account, we will stop providing all ESAVVO products and/or services to you, and will process your personal information by anonymisation or delete the personal information related to your account in accordance with applicable laws and regulations, except where laws, regulations or regulatory authorities require a longer storage period for user information.
10.1 As our business develops, in order to provide you with better services, or to reflect changes in relevant laws or services, this Privacy Policy may also be updated. If this Privacy Policy is amended (whether by addition and/or revision), we will publish the effective date and specific updates on our websites. Once the revised Privacy Policy is published, it will replace the previous Privacy Policy. Please review it periodically.
10.2 If this Privacy Policy undergoes material changes, we will also provide more prominent notices, such as pop-up windows when you log into our websites, or SMS reminders. Material changes to this Privacy Policy may include significant changes to the purposes of processing personal information, the types of personal information processed, the manner in which personal information is used, and your rights regarding personal information or the way you exercise those rights.
10.3 After the Privacy Policy is amended, if you continue to use our services, it means that you agree to be bound by the revised Privacy Policy. The statements in this Privacy Policy, as well as the right to amend, update and the final right of interpretation, belong to us.
11.1 If you have any inquiries, complaints, feedback or other matters concerning the protection of personal information arising from the use of this website, please contact our customer service department through the following means, and directly communicate with the staff responsible for personal information protection. Contact details: [esavvo@esavvo.com]
11.2 Generally, we will reply within fifteen (15) days. If you are not satisfied with our reply, especially if our processing of personal information has harmed your legitimate rights and interests, you may also seek a solution by filing a lawsuit in the court of competent jurisdiction where ESAVVO is located.