SENTYEH Privacy Policy

Last Updated: September 1, 2025

Guangzhou Jingtu Technology Co., Ltd. (hereinafter referred to as "we" or "Jingtu Technology") fully understands the importance of personal information to you. We will protect your personal information and privacy security in accordance with the provisions of laws and regulations. This Privacy Policy aims to explain to you how we collect, use, store, share and protect your personal information, and how you can access, update, control and protect such information.

I. How We Collect and Use Your Personal Information

1. We will collect your personal information in the following ways:

• Account Registration Information:When you register an account, we require you to provide information such as your mobile phone number, email address, username and password.
• Device Information:When you use this App, we will automatically collect your device information, includingdevice model, operating system version, device unique identifier (such as SN, ANDROID ID, IMEI, MAC address), Bluetooth version, etc..
• Riding Data:When you use the electronic shifting function, we will collect your riding data, including shifting records, riding mileage, speed, cadence, power and other riding parameters.
• Location Information:With your authorization, we will collect your location information to record riding tracks and provide location-based services.This information is considered sensitive personal information, and we will strictly protect it.
• Log Information:When you use this App, we will automatically collect certain log information, including usage, IP address, access time, error reports, etc.

2. We collect your personal information for the following purposes:

• Account Registration Information:For registration, login, account identification and security authentication.
• Device Information:To identify and configure your device, ensure normal communication with the SENTYEH electronic shifting system, and conduct device compatibility testing.
• Riding Data:To record and analyze your riding data, and provide you with personalized riding data analysis and riding suggestions.
• Location Information:To record your riding tracks and provide location-based services (such as route recommendations, group ride invitations, etc.).
• Log Information:To maintain the stability and security of this App, and to comply with applicable laws, regulations and regulatory requirements.

3. How We Collect Your Personal Information:

• Account Registration Information:Actively entered on the login interface: mobile phone number, email address, username and password
• Device Information:Automatically collect device model, operating system version, device identifier, Bluetooth version, etc.
• Riding Data:Actively input through the functions of SENTYEH electronic shifters and their peripheral devices (shifters, controllers, etc.).
• Location Information:Automatically collect your location information with your authorization.We only collect location information in the foreground when you use the riding record function. We will not continuously collect location information in the background.
• Log Information:Automatically collect usage, IP address, access time, error reports, etc.

4. Explanation on Silent/Background Collection

II. How We Use Cookies and Permissions Applied for During App Operation

To ensure the normal operation of this App, we will store small data files called Cookies on your device. Cookies usually contain identifiers, site names, and some numbers and characters. We will not use Cookies for any purpose other than those described in this Privacy Policy. You have the right to accept or refuse Cookies, but if you choose to refuse, it may affect your use of some functions of this App.

To ensure the normal operation of this App, we will apply for the following permissions on your device:

We will not obtain or record any personal information or permissions unrelated to the above functions.

III. Use of Third-Party SDKs

To ensure the stable operation and function realization of this App, we may access software development kits (SDKs) provided by third parties. We will conduct strict security testing on SDKs and require them to process your personal information in accordance with this Privacy Policy and other relevant confidentiality and security measures.

IV. How We Share, Transfer and Publicly Disclose Your Personal Information

1. Sharing

We will not share your personal information with any company, organization or individual other than Jingtu Technology, except in the following circumstances:

• With your explicit consent or authorization;
• In accordance with applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements;
• Sharing with our affiliates, but only for the purposes and within the scope specified in this Privacy Policy;
• Sharing with authorized partners to provide you with better services. We will sign strict confidentiality agreements with our partners, requiring them to process your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

2. Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

• With your explicit consent or authorization;
• In the event of a merger, acquisition, asset transfer or similar transaction, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require such company or organization to seek your authorization and consent again.

3. Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

• With your explicit consent or authorization;
• In accordance with applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements.

V. How We Protect and Store Your Personal Information

1. Information Protection

We have used security protection measures that comply with industry standards to protect the personal information you provide, to prevent data from being accessed, publicly disclosed, used, modified, damaged or lost without authorization. We will take all reasonably practicable measures to protect your personal information, including but not limited to:

• Using encryption technology to ensure the confidentiality of data transmission and storage;
• Providing multiple security functions to protect your account security;
• Conducting regular security assessments and vulnerability scanning of the system;
• Establishing a comprehensive access control mechanism to ensure that only authorized personnel can access personal information;
• Providing data security and privacy protection training to employees.

2. Information Storage

We will retain your personal information for the period necessary for the purposes described in this Privacy Policy and within the time limits required by laws and regulations. After the above period, we will delete or anonymize your personal information. Your personal information will be stored within the territory of the People's Republic of China. Without your consent, we will not transfer your personal information outside the country.

VI. Your Rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights over your personal information:

• Right of Access:You have the right to access your personal information, unless otherwise provided by laws and regulations;
• Right to Rectification:When you find that the personal information we process about you is incorrect, you have the right to request us to make corrections;
• Right to Erasure:In the following circumstances, you have the right to request us to delete your personal information:
  • Our processing of personal information violates laws and regulations;
  • We collect and use your personal information without your consent;
  • Our processing of personal information violates the agreement with you;
  • You no longer use our products or services, or you have canceled your account.
• Right to Withdraw Consent:You have the right to withdraw your consent at any time;
• Right to Account Deletion:You have the right to cancel your account at any time.

VII. Protection of Minors

We attach great importance to the protection of minors' personal information. If you are a minor under the age of 18, you should obtain prior written consent from your parent or legal guardian before using this App. We protect minors' personal information in accordance with the relevant provisions of national laws and regulations.

VIII. Updates to This Privacy Policy

We may revise this Privacy Policy from time to time. When the terms of this Privacy Policy are changed, we will show you the revised Privacy Policy in the form of push notifications and pop-up windows when you log in and update the version. Please note that we will only collect, use and store your personal information in accordance with the updated Privacy Policy after you click the agree button in the pop-up window.

IX. Contact Us

We will reply as soon as possible after receiving your feedback. If you are not satisfied with our reply, especially if you believe that our processing of personal information has harmed your legitimate rights and interests, you can also file a complaint or report to regulatory authorities such as cyberspace, telecommunications, public security, and industry and commerce.