ARCTIC LEOPARD PRIVACY POLICY

LAST UPDATED: SEPTEMBER 16, 2026

1. Introduction & Data Controller

This Privacy Policy (“Policy”) explains how Arctic Leopard Electric Technology Co., Ltd. and its global subsidiaries (“Arctic Leopard”, “Controller”, “we”, “us”, or “our”) collect, process, and protect your Personal Data when you visit or interact with our Digital Properties (including our official website, companion mobile apps, digital cockpit portals, online store, or customer service channels), purchase our electric off-road vehicles and hardware, or attend our official test rides and events.

The Data Controller is Arctic Leopard Electric Technology Co., Ltd. or the regional subsidiary named in the legal notice/imprint of the specific Digital Property you access. We strictly adhere to applicable data privacy standards worldwide, including the General Data Protection Regulation (GDPR) for European users. Under no circumstances do we sell your personal information.

2. Categories of Data We Collect

2.1 Account & Profile Registration

To access specific features in the Arctic Leopard App (such as custom motor mapping, keyless NFC pairing, and diagnostic logs), you must register a user account. We collect:

• Contact details (name, email address, country/region, and phone number);
• Authentication credentials (secure hashed passwords);
• Vehicle Identification Number (VIN) and pairing security tokens.

Legal Basis: Performance of a contract or preliminary steps taken at your request (Art. 6(1)(b) GDPR).

2.2 Website Navigation & Server Logs

When accessing our websites, standard technical data is collected and stored in server log files to maintain network security and optimal rendering:

• Browser type, software version, and operating system;
• Geographic region/country of access;
• Date, time stamp, and duration of the session;
• Anonymized IP address, entry/exit pages, and referring URLs.

Legal Basis: Legitimate interest in website security, stability, and anonymous traffic analytics (Art. 6(1)(f) GDPR).

2.3 Connected E-Moto Telemetry & Ride Data

Vehicles paired with the Arctic Leopard App or integrated Telemetry Control Unit (TCU) transmit operational and engineering metrics, including:

• Battery & BMS Metrics: Pack voltage, state of charge (SoC), cell temperature, and charge cycle counts;
• Powertrain Performance: Motor RPM, MCU current, regenerative braking rates, and throttle position;
• System Health: Error logs, controller thermal readings, and firmware versions;
• Ride Analytics: Odometer readings, trip duration, average speed, and optional GPS track telemetry (only when enabled by the rider).

Legal Basis: Performance of digital connected services (Art. 6(1)(b) GDPR) and explicit rider consent for location-based features (Art. 6(1)(a) GDPR).

3. How We Use Your Data

We process your Personal Data exclusively for specified, legitimate operational purposes:

4. Data Sharing & International Transfers

We share Personal Data only when strictly necessary and legally compliant:

• Authorized Distributors & Dealers: For local vehicle delivery, maintenance, parts replacement, and technical warranty handling;
• Technology & Cloud Infrastructure Providers: Trusted cloud hosts, app store platforms (Apple App Store, Google Play), and encrypted telemetry servers under strict data processing agreements;
• Statutory Authorities: Where required by law, regulatory mandates, or safety recalls.

Where personal data is transferred across international borders, Arctic Leopard implements Standard Contractual Clauses (SCCs) and high-level encryption standards to guarantee an equivalent level of protection.

5. Data Retention & Security Measures

We retain your data only for as long as your account remains active or as needed to provide warranty and support services. Account deletion or unpairing your vehicle initiates the deletion or irreversible anonymization of your associated usage data, except where statutory retention periods apply.

We deploy industry-standard technical and organizational security protocols, including AES-256 telemetry encryption, TLS connections, access-controlled data centers, and multi-layer authentication to prevent unauthorized disclosure or loss.

6. Your Privacy Rights

Depending on your jurisdiction, you maintain comprehensive legal rights regarding your personal records:

• Right of Access & Portability: Obtain confirmation and an exportable copy of the personal data we hold about you;
• Right to Rectification: Request correction of inaccurate or incomplete profile information;
• Right to Erasure (“Right to be Forgotten”): Request deletion of your user account and linked vehicle logs;
• Right to Restrict or Object: Restrict processing or object to data handling based on legitimate interests;
• Right to Withdraw Consent: Revoke previously granted permissions (e.g., location tracking) at any time directly through the app settings.

Data Privacy Office & Contact

To exercise your rights or submit questions regarding this Privacy Policy, please contact our data compliance department: