Privacy Policy

ECARX Privacy Notice

We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us in the event you have a complaint.

This privacy notice does not cover data subjects that are resident in China. A separate privacy notice is available for China.

We collect, use and are responsible for certain personal data about (i) visitors to our website, (ii) our customers, (iii) our suppliers and partners, (iv) drivers and owners using vehicles that operate with our technology and (v) employment candidates subject to applicable laws, in relation to operations globally.

This privacy notice applies to the group of entities including ECARX Ltd, a company registered in England and Wales (“ECARX UK“), ECARX Americas Inc. (California), ECARX Sweden AB, ECARX GmbH (Germany) and ECARX Technology Limited (Hong Kong) which from time-to-time control, are controlled by or are under common control with ECARX (Hubei) Tech Co., Ltd. (China) as well as minority-owned companies (collectively the “ECARX group of companies”). “control’’ means the beneficial ownership of more than 50% of the issued share capital or votes or the legal power to direct or cause the direction of the general management of the entity in question.

The website is operated by ECARX UK. The privacy notice applies to all processing of personal data by the ECARX group of companies.

Depending on your commercial relationship with us and which company within the ECARX group of companies that you are supplying information to, the controller of your personal data will be different. Please contact us to request further details. We are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact (see ‘How to contact us’ below).

This Privacy Notice is set out as follows:

Key Terms
Personal data we collect about you
How your personal data is collected
How and why, we use your personal data
Who we share your personal data with
Where your personal data is held
How long your personal data will be kept
Transferring your personal data out of the UK and EEA
Your rights
Keeping your personal data secure
How to complain
Changes to this privacy notice
How to contact us
Governing law

1. Key terms

It would be helpful to start by explaining some key terms used in this notice:

“We”, “us”, “our”	The ECARX group of companies
“Personal data”	Any information relating to an identified or identifiable individual
“Special category personal data”	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation
“Data subject”	The identified or identifiable individual to whom personal data relates.

2. Personal data we collect about you

The personal data we collect use, store and transfer about you depends on our relationship, e.g. if you are a visitor to our website, a customer, a supplier or an employment candidate. We may collect and use the following personal data about you depending on our relationship with you (each as applicable on a case-by-case basis):

a. All (any website visitor)

your name and contact information, including personal email address and telephone number
location data, if you choose to give this to us
information about how you use our website, IT, communication and other systems
retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
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

b. Customers

your work contact details (i.e. place of work, work landline and mobile phone numbers, work email address)
your billing information, transaction and payment card information, bank account, financial accounts and other relevant information
information to enable us to undertake credit or other financial checks on you
your contact history and transaction history

c. Suppliers and partners

your work contact details (i.e. place of work, work landline and mobile phone numbers, work email address)
your billing information, transaction and payment card information, bank account, financial accounts and other relevant information
information to enable us to undertake credit or other financial checks on you
your contact history and transaction history

d. Employment candidates

your name and contact information, including personal email address and telephone number
education details
your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information
information regarding your fitness for work
information to check and verify your identity, e.g. your date of birth and residential address
your emergency contacts (i.e. name, relationship and home and mobile phone numbers)
your gender, if you choose to give this to us
your marital status, if you choose to give this to us
your professional interests
your professional online presence, e.g. LinkedIn profile
any other information that you provide to us in connection with your job application

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from being able to engage with you.

3. How your personal data is collected

We collect most of this personal data directly from you — in person, by telephone, text or email, and/or via our website. However, we may also collect information:

from within the ECARX group of companies
from publicly accessible sources
from a third party with your consent, e.g. your bank
from cookies on our website—for more information on our use of cookies, please see our cookie policy
via our IT systems, e.g. our computer networks and connections and communications systems, email and instant messaging systems

4. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We carry out assessments when relying on legitimate interests to balance our interests against your own.

The table below explains what we use your personal data for and why for the various purposes which may apply if you are (i) a visitor to our website, (ii) a customer, (iii) a supplier, and (iv) an employment candidate:

a. All (any website visitor)

What we use your personal data for	Our reasons
To manage our relationship with you	To respond to communications For investor relations
Preventing and detecting fraud against you or us	For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: — to comply with our legal and regulatory obligations — in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests, i.e. to make sure we are following our own internal procedures
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests, i.e. to be as efficient as we can for your benefit
Statistical analysis to help us manage our business, e.g. in relation to website usage, our financial performance, customer base or other efficiency measures	Depending on the circumstances: — where you have given consent — For our legitimate interests, i.e. to be as efficient as we can for your benefit
Preventing unauthorised access and modifications to systems	Depending on the circumstances: — for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us — to comply with our legal and regulatory obligations
Marketing our services to: — existing and former customers — third parties who have previously expressed an interest in our services — third parties with whom we have had no previous dealings	For our legitimate interests, i.e. to promote our business to existing and former customers
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: — to comply with our legal and regulatory obligations — in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

b. Customers

What we use your personal data for	Our reasons
Providing products and services to you	To perform a contract with you or to take steps before entering into a contract
To manage our relationship with you	To perform or enter into a contract with you To notify you about changes to our terms or our privacy notice
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by regulators	Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests
Updating and enhancing customer records	Depending on the circumstances: — to perform our contract with you or to take steps at your request before entering into a contract — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products or services
Ensuring safe working practices	Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

c. Suppliers and partners

What we use your personal data for	Our reasons
Procuring products and services from you	To perform a contract with you or to take steps before entering into a contract
To manage our relationship with you	To obtain the benefit of or enter into a contract with you
Conducting checks to identify our suppliers and partners and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by regulators	Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests
Ensuring the confidentiality of commercially sensitive information relevant provided to suppliers and partners	Depending on the circumstances: — for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information — to comply with our legal and regulatory obligations
Updating and enhancing supplier records	Depending on the circumstances: — to enable to performance of a contract with you or to take steps before entering into a contract — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. making sure that we can keep in touch with our suppliers and partners about services, orders and products being procured
Ensuring safe working practices, staff administration and assessments	Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. to make sure we are following our own internal supplier procedures

d. Employment candidates

What we use your personal data for	Our reasons
To manage our relationship with you	To potentially engage you as an employee or contractor To take steps prior to entering into a contract with you or to perform the contract
Gathering information required to process your job application for a defined role or a speculative position	To assess, review and administer your qualifications and expertise to work with us
Ensuring safe working practices, staff administration and assessments	Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. to make sure we are following our own internal procedures so the recruitment process works as efficiently as possible

How and why we use your personal data — Special category personal data

We do not generally collect any special category personal date 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 matter, such as taking into account your medical or other needs in the case of a potential employee. Nor do we collect any information about criminal convictions and offences unless these are disclosed to us by you.

In the limited circumstances where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g:

we have your explicit consent (and where you have voluntarily provided such information to us)
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
the processing is necessary to establish, exercise or defend legal claims

5. Who we share your personal data with

We take various steps to protect your personal data where we need to share it with others.

We routinely share personal data with:

companies within the ECARX group of companies
third parties we use to help deliver our products and services to you
other third parties we use to help us run our business, e.g. marketing agencies, consultants or website hosts
credit reference agencies
our insurers and brokers
our banks
investor relations

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

our external accountants and auditors, e.g. in relation to the preparation and audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency — usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
We do not “sell” your personal information as currently defined under the California Consumer Protection Act to any third parties.

Marketing

We may use your personal data to send you updates (including by email, telephone or post) about our products and services.

We have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You do, however, have the right to ‘opt in’ and ‘opt out’ of receiving marketing communications at any time by:

contacting us (see ‘How to contact us’ below); or
using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share it with other organisations outside the ECARX group of companies for marketing purposes.

6. Where your personal data is held

Personal data may be held on servers in the United Kingdom, European Union, United States of America and China and at our offices and those of our group companies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

7. How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available on request.

If you are an employment candidate and are unsuccessful, after notifying you that you were unsuccessful in your application, we will only hold your details for a further period of 90 days following your last interaction with the careers page.

In general and in line with usual limitation periods, if we are no longer providing or procuring goods or services to or from you, or our relationship has otherwise ended, we will usually delete or anonymise your account data after 7 years.

8. Transferring your personal data out of the UK and EEA

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

our service providers located outside the UK and the EEA; and
our group companies located outside the UK and the EEA;

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

there is an adequacy decision
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available) legally approved standard data protection clauses.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy notice’ below.

9. Your rights

You may have the following rights in respect of your personal data:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data — in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: — at any time to your personal data being processed for direct marketing (including profiling) — in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consent	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consent by contacting us (see ‘How to contact us’ below) Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

If you would like to exercise any of those rights, please email us — see below: ‘How to contact us’; and

provide enough information to identify yourself (e.g. your full name, address and customer or supplier reference number) and any additional identity information we may reasonably request from you
let us know what right you want to exercise and the information to which your request relates.

10. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

11. How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. For example, the UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113. A list of EEA data protection supervisory authorities and their contact details see here.

Please contact us if you would like further information.

12. Changes to this privacy notice

This privacy notice was published on 15 November 2023 and last updated on 7 February 2024.

We reserve the tight to change this privacy notice as our discretion from time to time — when we do we will inform you via our website or other means of contact such as email.

13. How to contact us

You may contact us by email at privacy@ecarxgroup.com. All communications will be received by ECARX UK. The controller’s contact details in respect of contact requests are provided below:

ECARX Limited, a company registered in England and Wales with company number 13538817 whose registered office is at Second Floor South, International House, 1 St. Katharine’s Way, London, England, E1W 1UN.

Other controller’s contact details in the ECARX group of companies may be requested by email at privacy@ecarxgroup.com.

14. Governing law

This policy is prepared in accordance with the laws of England and Wales and shall be governed and construed accordingly.