Data transparency is the foundation of user trust. Users have full autonomous control over the data generated through their use of our products. We process data with compliance as our baseline and security as our cornerstone, ensuring that the value of data ultimately returns to enhance the user experience.

Since September 12, 2025, Regulation (EU) 2023/2854 (the "Data Act") has been in effect. This legislation grants users of connected products and related services the legal right to access data generated through their use and to choose to share such data with third parties.

In accordance with the transparency requirements set out in Article 3, paragraphs (2) and (3) of the Data Act, SERES, as the manufacturer of connected vehicles and provider of related services, hereby provides this complete information statement regarding the scope of data generated by connected products and related services, users' legal rights, and the procedures for data access.

1. Introduction

1.1 Data Holder:

The data holder is SERES International Electric Vehicle Co., Ltd. ("SERES" or "we"), a legal entity established under the laws of the People's Republic of China, with its registered address at No. 5-9, Wuyunhu Road, Shapingba District, Chongqing.

For matters related to the Data Act, you may contact us through the following channels:

  • Email address: info@global-seres.com
  • Correspondence address: Burgemeester Stramanweg 102A, Building London, 1101AA AMSTERDAM, The Netherlands

1.2 Connected Products and Related Services:

Unless otherwise specified, all SERES connected vehicles sold within the EU are considered "connected products" as defined in Article 2, paragraph (5) of the Data Act: i.e., physical products capable of acquiring, generating, or collecting data concerning their use or environment, and able to transmit such data via electronic communications, physical connections, or built-in functionalities.

In connection with these connected products, we also provide related services, such as remote vehicle control services via the SERES-International APP, which allow users to manage their vehicles remotely.

1.3 Non-Applicable Scenarios:

Third-party applications and their corresponding services used within your vehicle are independently operated and provided by separate third-party service providers. The personal data and vehicle-related data required to enable these functionalities will be collected, processed, and stored by those third-party service providers. Such data processing activities are governed by the privacy policies and terms of service published by those third parties and are not covered by this statement.

2. Data Involved in Products and Related Services

The types of data generated, collection frequencies, and data volumes may vary depending on factors such as vehicle model, hardware configuration, sales region, and user settings. For detailed information regarding all data types, generation frequencies, file formats, and estimated data volumes, please refer to the Data Dictionary.

3. Data Retention Rules

All data from connected products and related services is stored in data centers located in Dublin, Ireland, or Frankfurt, Germany.

We store and use relevant data only to the extent lawful and necessary, until the corresponding purposes are fulfilled:

  • Provision of Products and Supporting Services: To deliver vehicle features, connected services, mobile applications, and all other supporting services in accordance with our agreement, and to provide ongoing operational support and maintenance.
  • Diagnostics, Maintenance, and After-Sales Services: To perform vehicle diagnostics, repairs, maintenance, quality control, and to handle warranty and after-sales requests.
  • Safety and System Integrity: To monitor and ensure the safe operation and system integrity of vehicles, systems, and services.
  • Product and Service Optimization and Development: To optimize existing products and services through data analysis and to research and develop new products and services.
  • Data Aggregation and Derivative Use: To aggregate, anonymize, and derive data for statistical analysis and legitimate business purposes. When providing aggregated/derived data externally, we ensure that it cannot be used to reverse-engineer your original vehicle information.
  • Fulfillment of Legal Obligations: To respond to judicial requests, comply with applicable laws, regulations, and regulatory requirements.

When the purposes for data usage have been fulfilled, the aforementioned data will be deleted or anonymized.

4. Your Rights

Under the EU Data Act, you have the following legal rights regarding data generated by connected products and related services:

4.1 Right to Access and Retrieve Data

You have the right to request, free of charge, access to and retrieval of product data and service data generated during your use of the vehicle and supporting services. We will provide you with the corresponding data without undue delay, in a structured, commonly used, and machine-readable format.

4.2 Right to Data Portability and Sharing

You have the right to designate a third-party recipient and request that we transmit the relevant data directly to that recipient.

4.3 Right to Deletion

You have the right to request the deletion of relevant data stored by us, provided there is no mandatory legal retention obligation.

4.4 Channels for Exercising Rights

You may submit requests through the contact channels provided in this information statement.

4.5 Limitations on Rights

The above rights are not absolute. Data containing trade secrets, aggregated data, or deeply processed derivative data may be subject to access restrictions. If your request cannot be fulfilled, in whole or in part, we will provide you with a complete explanation.

4.6 Complaints and Redress

If you have concerns regarding our compliance with obligations under Chapter 2 of the Data Act, you may file a complaint with the competent supervisory authority established pursuant to Article 37 of the Data Act. We also welcome you to contact us first to address any questions and seek resolution collaboratively.

5. Service Conditions and Quality Standards for Access and Transmission

All user requests submitted under the Data Act will be processed free of charge, without imposing any fees on the user. For direct transmission of data to third parties, we will charge the third party a reasonable service fee in accordance with the law.

We will continuously ensure the availability of data interfaces and request channels. Should temporary service interruptions occur due to force majeure events such as system maintenance or technological upgrades, we will make every effort to provide advance notice.

If the dataset you request is not held by us or falls outside the scope of legally accessible data, we will inform you of this fact in a timely manner and provide the reasons.

6. Validity and Termination

6.1 Automatic Termination Conditions

Under the following circumstances, we will be unable to continue providing subsequent data collection and related services. Data already generated will continue to be processed in accordance with the retention rules set out in this statement:

  • The connected vehicle is damaged or suffers an irreparable failure that renders it incapable of generating data.
  • You no longer own the vehicle or have lost the legal right to use the vehicle and supporting services.

6.2 User-Initiated Termination

You may terminate subsequent data collection and related services at any time by deactivating your supporting service account or disabling the vehicle's connectivity functions. Data already generated will continue to be processed in accordance with the retention rules set out in this statement.

7. Trade Secret Statement

We retain the trade secret rights inherent in product data and supporting service data. Data containing core technical parameters, algorithmic logic, or underlying vehicle control logic constitutes trade secrets. Data containing trade secrets may be subject to access restrictions, and we will implement specialized technical and administrative measures to protect them.

8. Revision Rules

We reserve the right to revise this statement at any time. In the event of material changes, we will notify you by updating the statement at https://www.global-seres.com/data-law-statement. We recommend that you review this document periodically to stay informed of the latest information.

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