As the processor of your personal information, ENEOS (Shanghai) Corporation (“ENEOS”) respects your privacy and undertakes to comply with this Policy. This Policy explains how, as a company engaged in the provision of energy trading management and related services, we handle personal data provided to us by you, by the company that employs you or for which you are traveling on business (“Company”), or by a third party, when providing you with our products and services.
This Policy sets out what personal data we collect from you, how we collect and use such data, with whom such data may be shared, and the choices you have regarding our use of your personal data. This Policy also describes the measures we take to safeguard the security of your personal data and provides our contact details.
This Policy applies to ENEOS’s energy trading and related services, as well as branded services that may be offered to you, including services provided through ENEOS’s websites and applications that display or link to this Policy (collectively referred to as the “Services”). Where our products/services or those of our affiliates make use of our products/services without a separate personal information protection policy in place, such products/services shall also be subject to this Policy. Where our products/services or those of our affiliates have a separate personal information protection policy in place, that separate policy shall take precedence; however, for any matters not addressed in such separate policy but covered by this Policy, the provisions of this Policy shall apply.
Before using our products/services, you must carefully read and fully understand this Policy, especially the provisions in bold font, which you should pay particular attention to as they relate to the rights you enjoy concerning the processing of your personal data. As a user of our Services, you understand and agree that we will process your personal information in accordance with this Policy. Please begin using our products/services only after confirming that you fully understand and agree. If you or your guardian (if you are a minor) do not agree to any part of this Policy, you will not be able to use certain of our products/services. If you have any questions, comments, or suggestions regarding the contents of this Policy, you may contact us using the contact details provided in Article 9 of this Policy.
Our practices regarding the use of personal data may vary according to the country in which we operate, in order to reflect local legal requirements. ENEOS complies with the applicable data protection laws of the jurisdictions in which it operates when processing personal data.
This policy is a translation of the original Chinese version (https://www.eneos.com.cn/PrivacyPolicy.html) and, in the event of any inconsistency or conflict with the Chinese version, the Chinese version shall prevail.
Part I — Definitions
1. We / Us: Refers to ENEOS (Shanghai) Corporation.
2. Affiliates: All companies under ENEOS and their subsidiaries.
3. User / You: Any natural person who accesses or uses the products/services we provide, including both registered and unregistered users.
4. Personal Information: Any kind of information, recorded electronically or by other means, that is related to an identified or identifiable natural person.
5. Sensitive Personal Information: Personal information which, if leaked, illegally provided, or misused, may endanger personal or property safety, and is highly likely to result in damage to an individual’s reputation, physical or mental health, or discriminatory treatment. Sensitive personal information referred to in this Policy includes information such as biometric data, religious beliefs, specific identities, medical and health information, financial accounts, location tracking, as well as the personal information of minors under the age of fourteen.
6. Deletion of Personal Information: The act of removing personal information from the systems involved in the performance of routine business functions, such that it remains in a state where it cannot be retrieved or accessed.
7. Children: Minors under the age of fourteen.
8. Minors: Natural persons under the age of eighteen. A minor who is over sixteen years of age and whose primary means of livelihood is derived from his or her own labor shall be deemed to have full capacity for civil conduct.
Part II — Personal Information Protection Policy
This Policy is designed to help you understand the following:
1. How we collect and use your personal information
2. How we use cookies and similar technologies
3. How we share, transfer, entrust processing, and disclose your personal information
4. How we store and cross-border transfer your personal information
5. How we protect the security of your personal information
6. How we protect minors’ personal information
7. How you exercise your personal information rights
8. Amendments to this Policy and notifications
9. How to contact us
1. How We Collect and Use Your Personal Information
During your use of our products or services, ENEOS may collect, use, store, and disclose personal information. Personal information refers to any information that can identify you or be linked to you. As an energy trader or user of our services, you may be requested to provide certain personal information in the following circumstances:
・ To provide you with the basic functionalities of our products/services, you need to authorize us to collect and use the necessary information. If you refuse to provide such necessary information, you will be unable to properly use our products/services.
・ To provide additional features of our products/services, you may choose to authorize us to collect and use relevant information. If you refuse, you may not be able to use those additional features or achieve the intended effects, but this will not affect your use of the basic functions of our products/services.
Please note that due to the wide variety of products and services we offer, we will collect and use your personal information in accordance with the principles of reasonableness, legitimacy, and necessity based on the specific products/services you choose to use. Beyond this, you understand and agree that, for the purpose of providing better products and services, we may introduce new or optimized features from time to time, which may increase or change the purposes, scope, and methods of collecting and using personal information. In such cases, we will separately notify you via updates to this Policy, pop-ups, or in-app messages regarding the purposes, scope, and methods of collecting and using such information, and provide you the option to consent or not. We will only collect and use such information after obtaining your explicit consent. If you have any questions, comments, or suggestions during this process, you may contact us using the information provided in Section 9 of this Policy.
When you book or purchase products or services, you may be required to provide the user’s name, gender, nationality, TAS number, identification details, date of birth, phone number, and email address. The foregoing information is considered sensitive information, and refusal to provide it may result in inability to complete the booking or purchase.
To provide you with customer services, we may communicate with you through various multimedia channels (such as email, mail, telephone, or the ENEOS website or applications), requiring you to provide contact addresses, email addresses, phone numbers, ENEOS account information, etc. Refusal to provide such information may make it impossible to provide the above services.
To recommend products/services you might be interested in, we may send you newsletters, marketing emails, other information or materials, or display personalized advertisements. If necessary, we will obtain your consent before sending such marketing messages or displaying personalized advertisements. You may disable such commercial information pushes by using the settings under Section 7 (“How You Exercise Your Personal Information Rights”) subsection (4) “Limit Automated Decision-Making.” Disabling these will not affect your use of ENEOS’s basic functions.
During your use of our products/services, we may collect and use your browsing history, search records, geographic location, device information, and other information authorized by you when accessing or using our websites and clients. This is to perform comprehensive statistics, understand your preferences, and thereby recommend personalized products/services tailored to your needs to enhance your user experience. You may learn about our website and app usage, and enjoy customized experiences through interactive or personalized elements we provide on our services, and content recommendations based on your interests (for more details, see the sections below regarding how ENEOS handles “Do Not Track” requests and the use of “Cookies” and similar technologies).
We may also process your personal information to fulfill requests you or your company submit (such as reports, inquiries, booking requests based on energy trading, or other requests related to your personal data). Automated decision-making may be used to process certain requests to help provide faster and more reliable services to you and/or your company (e.g., forwarding your request to the appropriate department or sending automatic replies). Important decisions will always be reviewed by ENEOS personnel.
We may conduct surveys (e.g., for energy traders or customer satisfaction), and review the quality and performance of our services to achieve customer satisfaction.
To fulfill our obligations and to reasonably protect the rights of you, us, or others (such as billing and collections, fraud prevention, legal compliance, and responding to legal actions or requests from law enforcement or other third parties), we may process your personal information.
To more accurately identify, prevent attacks, and protect your account security (including forming risk control tags/profiles/models, determining whether IP/devices are blacklisted, whether a device is real or an emulator, whether risky software/apps are installed, etc.), after your consent to this Privacy Policy, we will automatically collect device or software information during your use of our products, such as your IP address, model/version/storage capacity and device identifiers of your mobile device (e.g., IDFA, IMEI, IMSI, OAID, Android ID, OPENUDID, GUID, hardware serial number), SIM card information, installed/uninstalled app lists, process information, device MAC address, network type/status, Wi-Fi connection info (e.g., SSID, BSSID, status/list/MAC), sensor information, MEID (for CDMA phones), and browser or device configuration information used to access our services.
To provide you with personalized products/services and enhance your user experience, you may use additional functions of our apps by enabling relevant permissions on your mobile device operating system. If you do not enable or provide such permissions, you can still complete bookings and related services. Please note that such permissions may vary depending on your mobile OS. Enabling any permissions signifies your authorization for us to collect and use the related personal information to provide the corresponding services. If you disable any permissions, you revoke such authorization, and we will no longer collect or use related personal information under those permissions or provide the related services. However, your decision to disable permissions will not affect information collection and use based on prior authorization. You can check the list of device permissions ENEOS may request and use by accessing the ENEOS device permission list.
ENEOS offers online applications (mobile and web versions) available from various app stores. We may track information about your app usage (e.g., anonymous daily visitor counts, daily requests to specific features, interest tracking, who posts content, countries accessing apps and services). We use such statistics exclusively to measure activity and improve or adjust services for your benefit. We may also use Google Analytics or other analytics tools and methods to compile anonymous user statistics as described in our Cookie Policy (https://www.eneos.com.cn/). ENEOS uses these statistics to analyze activities, improve services, communicate survey results to your company and other ENEOS clients or potential clients, and enhance products. Such statistics do not contain personal data and cannot be used to collect personal data. Under the terms of app usage, some of your information (which may include your email address, travel data, and other voluntarily provided information) may be shared with third parties according to this Policy. Please note that once you leave the ENEOS website or apps and visit other websites, including virtual assistants or other apps, the privacy policies of those sites or apps apply.
Special Notes on Collection and Use of Your Personal Information
If you submit personal data of others related to the services (e.g., booking on behalf of another person or providing emergency contact information), you represent that you have obtained their consent and notified them that we will process such personal information in accordance with this Policy. If such information involves children’s personal data, you must first obtain consent from the child’s guardian. Except in cases where authorized consent exceptions apply (see “1. How We Collect and Use Your Personal Information”), we will obtain your separate consent for processing sensitive personal information in certain scenarios as required by laws, regulations, and national standards. The specific method of obtaining consent will be displayed on the corresponding function pages.
If we intend to use information for purposes not stated in this Policy, or use information collected for specific purposes for other purposes, we will re-obtain your consent.
When you access various parts of our services, including communicating with us via email or other channels, we collect personal data directly from you; from other sources such as your company or third parties who may send your personal data to us on your or your company’s behalf; and from websites and applications accessible through or by means of our services and company, including third-party vendors (such as airlines, hotels, payment card providers) and our affiliated ENEOS companies, subsidiaries, joint ventures, partners, subcontractors, and agents. This includes personal data automatically collected through our websites and applications, such as via cookies and similar technologies. We require third parties to disclose your personal information source and confirm the legal compliance of those sources before collection. If our purpose for collecting and using your information exceeds the authorized scope obtained by the third party, we will either obtain your consent ourselves or require the third party to do so before further processing your personal information.
Our services may contain links to third-party websites. Some of these websites may allow you to purchase products/services, register to receive materials, or receive updates on new products and services. In many cases, you may be asked to provide contact information such as your name, address, email address, phone number, and credit/debit card information. If you use such third-party websites and/or provide your personal data and information, their privacy policies and terms of service apply. We encourage you to carefully read such policies before submitting personal data. ENEOS disclaims and expressly refuses any and all liability arising from the actions, privacy policies, or terms and content of such websites.
Exceptions to the Requirement of Authorized Consent
You acknowledge and understand that, under applicable laws and regulations, in the following circumstances, we may collect and use your personal information without obtaining your authorized consent:
(1) To perform ENEOS’s statutory duties or legal obligations;
(2) Relating to national security or defense security;
(3) Relating to public safety, public health, or major public interests;
(4) Relating to criminal investigation, prosecution, trial, and execution of judgments;
(5) Necessary for the conclusion or performance of a contract to which you are a party;
(6) In emergency situations to protect your or another person’s life, health, or property safety;
(7) Where the personal information is voluntarily disclosed by the data subject to the public or otherwise legally disclosed;
(8) Where the personal information is collected from publicly disclosed sources, such as lawful news reports or government information disclosure;
(9) For public interest activities such as news reporting or public opinion supervision within reasonable scope; necessary to maintain the safe and stable operation of the provided products or services, such as discovering and handling faults;
(10) For academic research institutions conducting statistics or academic research for public interest, and the personal information contained in the results is de-identified when disclosed externally;
(11) Other circumstances as prescribed by laws, regulations, and national standards.
Please note that, pursuant to applicable law, if we apply technical and other necessary measures to process personal information such that the data recipient cannot re-identify specific individuals or restore the data, use of such processed data does not require additional notification or consent from you.
II. How We Use Cookies and Similar Technologies
(1) Cookies
To provide you with a more convenient and smooth access experience, when you visit ENEOS or use the services we offer, we may use "cookies" to automatically collect information. This helps you avoid repeatedly entering registration information, optimizes ad selection and interaction, and assists in assessing the security status of your account. You may choose to refuse cookies in your browser (please refer to the "Cookies" link below), but this may limit your ability to receive some or all of our services, and some features may not function properly. Where required by applicable laws, ENEOS will obtain your consent before using cookies to collect information. For more information about cookies and how ENEOS uses cookies on its website, please visit (https://www.eneos.com.cn/).
III. How We Share, Transfer, Entrust Processing, and Publicly Disclose Your Personal Information
1. Sharing and Providing
Principles of Processing
We may share your order information, account information, device information, and location information with partners and other third parties to ensure the smooth provision of services to you. However, we will only share your personal information for lawful, legitimate, necessary, specific, honest, and clear purposes, and only the personal information necessary to provide the service will be shared. We will assess the legality, legitimacy, and necessity of the third parties collecting your personal information, and require them to process your personal information within the scope of your authorized consent, adopting necessary information management measures and technical means to prevent leakage, damage, loss, or tampering of your personal information. Third parties are not authorized to use your shared personal information for any other purposes. If they intend to change the purpose or method of processing your personal information, they must re-obtain your authorization and consent.
Separate Consent
Unless an exception to obtaining authorization and consent applies (see Section I, "How We Collect and Use Your Personal Information"), we will, in accordance with laws, regulations, and national standards, separately obtain your explicit consent for sharing and providing personal information in scenarios beyond those described above. Regardless of whether separate consent is required, we will clearly inform you in a reasonable manner of the specific third-party suppliers providing the related products/services, as well as the purpose, method, and type of processing of your personal information. For example, when you are about to order certain ENEOS products/services, we may notify you explicitly via the order filling or confirmation page and, when necessary, obtain your separate consent to authorize ENEOS to provide your personal information to suppliers or service providers. Please refer to the specific product/service order page for the exact form of separate consent.
Our partners include the following types (including entities inside and outside China):
(1) Third-party service providers to complete energy trade arrangements, bookings, and service fulfillment (such as Global Distribution Systems, GDS), including but not limited to airlines, trains, car rental and other ground transportation companies, destination management companies, and other related energy trade suppliers; industry reporting agencies; equipment and technology providers such as online booking tool providers, conference registration software providers (including on-site and mobile event management solutions), audiovisual companies; visa and passport service providers; credit card companies and payment collection and processing companies.
(2) Financial institutions and third-party payment agencies: When you book orders, apply for refunds, or purchase insurance, we share specific order information with financial institutions or third-party payment agencies. When deemed necessary for fraud detection and prevention, we may share additional necessary information with relevant financial institutions, such as IP addresses. Before you use such services, we will notify you through page prompts, interactive procedures, or online agreements about personal information sharing rules and obtain your consent.
(3) Business partners: We may collaborate with partners to provide products or services and share relevant personal information with them for purposes including express delivery, communication services, customer service, marketing, advertising, technical services, identity verification, and consulting services. For example, to provide service information or commercial information push notifications, we may provide your mobile phone number and intended message content to SMS service providers. You can disable commercial information push notifications under "VII. How You Exercise Your Personal Information Rights" section (4) Restriction of Automated Decisions). After disabling, we will no longer send commercial information tailored to your personal characteristics.
(4) Affiliates: We may share your relevant personal information with our affiliates to provide you with energy trade-related or other products or services. Affiliates will adopt protection measures no less strict than those in this policy.
(5) Your company: For energy trade reporting, auditing, tracking, and other necessary purposes, including personnel designated by your company to whom we send or provide personal information. Third-party service providers designated by you or your company to whom we send personal information.
(6) Other companies supporting ENEOS’s business and auxiliary services (such as fulfillment, surveys, storage, statistical analysis, technology, development, credit checks, if applicable).
(7) Data integration companies used by ENEOS or your company to create reports and related statistics for benchmarking or other related purposes, including but not limited to cumulative statistics that may include data obtained from your company for common business purposes within our industry and services, without directly or indirectly identifying you or your company.
(8) Other third parties deemed reasonably necessary under applicable laws, including those outside your country of residence, to: (i) comply with laws, regulations, government or legal requests and procedures; (ii) identify, contact, or prosecute persons who may violate our terms of use or policies or enforce these terms and policies otherwise; (iii) properly operate services; or (iv) protect ENEOS and its service targets, including seeking existing remedies or limiting potential harm (e.g., exchanging information with other companies and organizations to prevent fraud and reduce risk).
Please note that for fraud prevention and detection by business partners and affiliates, we may prudently provide necessary personal information after strict internal security assessment and approval and by signing agreements limiting the use of such information.
2. Information Transfer
We will not transfer your personal information to any company, organization, or individual except in the following situations:
(1) With your explicit prior consent or authorization;
(2) As required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requests;
(3) In cases of mergers, splits, acquisitions, asset transfers, or similar transactions, if personal information transfer is involved, we will notify you of the receiving company or organization's name and contact information before the transfer, and require the new holder of your personal information to continue to be bound by this policy and fulfill the personal information processing obligations originally borne by us. Otherwise, we will require the company or organization to obtain your authorization and consent again.
3. Entrusted Processing
To improve processing efficiency, reduce costs, or enhance accuracy, we may entrust affiliated companies or external professional service providers to process your personal information. We will sign entrusted processing agreements and require the entrusted parties to process personal information according to these agreements, this policy, and any other relevant confidentiality and security measures. Upon termination, invalidation, or cancellation of the entrusted relationship, we will require the entrusted parties to return or delete your personal information (including original information, copies, or summaries obtained during entrusted processing) without retention. Without your authorization, we prohibit entrusted parties from subcontracting your personal information processing to others.
4. Public Disclosure
We will only publicly disclose your personal information under the following circumstances:
(1) Based on your request and with your separate consent, disclose personal information as you specify and through your approved disclosure methods;
(2) When required by laws, regulations, or mandatory administrative or judicial enforcement, we may disclose your personal information according to the requested types and disclosure methods. Upon receiving such disclosure requests, we will require the corresponding legal documents, such as subpoenas or investigation letters.
IV. How We Store Your Personal Information
1. Storage Location
As a multinational group company, ENEOS follows its group-wide personal information and data management requirements. Generally, ENEOS stores personal data on servers it manages internally or jointly with third-party storage providers.
2. Cross-Border Transfer
ENEOS is a global company providing energy trade-related services. Therefore, transferring your personal information internationally is necessary to provide services. When sharing or disclosing personal data to others, including related companies, affiliates, subsidiaries, joint ventures, partners, subcontractors, and agents providing services or maintaining facilities, your personal data may be transferred to other countries. We will comply with applicable personal information protection laws and implement sufficient safeguards (such as model clauses and data protection agreements) for international transfers. If you have any questions or want more information about international transfers or security measures, please contact us according to this policy.
If your personal information storage location is transferred from within China to outside China, we will strictly comply with legal requirements.
Scenarios requiring cross-border transfer of your personal information include:
(1) Obtaining your explicit authorization;
(2) Marketing scenarios involving overseas service providers;
(3) Your voluntary cross-border transactions via ENEOS;
(4) Legal and regulatory requirements.
Unless exceptions apply (see Section I), for cross-border transfers outside the above scenarios, we will reasonably obtain your separate consent according to laws and national standards. Regardless of whether separate consent is required, we will clearly inform you of the domestic and overseas service providers involved in the product/service, and their purpose, method, and type of personal information processing. For example, when ordering some overseas products/services, we will inform you on order filling or confirmation pages and obtain your separate consent when necessary for ENEOS to provide your personal information to overseas suppliers. Please refer to the specific product/service order page for the consent form.
We will comply with laws, administrative regulations, and national cyberspace authorities’ rules (such as security assessments, personal information protection certification, and signing standard contracts with overseas recipients) and require overseas entities to keep your personal information confidential and fulfill corresponding protection obligations.
3. Storage Period
Unless laws require or permit a longer retention period, ENEOS will keep personal data for the shortest period needed to achieve the purposes outlined in this policy. When deciding how long to retain personal data, we consider the necessity for service provision, applicable laws and regulations (including data security and personal information protection laws), and legal obligations. We may retain records for investigating or defending potential legal claims. When personal data is no longer needed, it will be deleted or anonymized for analysis purposes.
However, in the following cases, we may adjust retention periods to comply with legal requirements:
(1) To comply with applicable laws and regulations;
(2) To comply with court rulings, decisions, or other legal procedures;
(3) To comply with requests from government agencies or authorized organizations;
(4) To protect social public interest, and reasonably protect personal and property safety or other legitimate rights of ENEOS users, ENEOS, our affiliates, other users, or employees.
4. Ceasing Operations
If we cease operation of ENEOS products or services, we will promptly stop collecting your personal information, notify you of the cessation individually or by announcement, and delete or anonymize the personal information held.
V. How We Protect the Security of Your Personal Information
ENEOS will comply with the requirements of the Data Security Law of the People's Republic of China and relevant laws and regulations, using appropriate technical and organizational security measures to protect personal data in its networks and systems from unauthorized access, disclosure, destruction, and alteration. We regularly review our data collection, storage, processing, and security measures to ensure that we only collect, store, and process personal data necessary to provide our services and fulfill contractual obligations. While we make every effort to protect the integrity and security of our networks and systems, we cannot guarantee or warrant that our security measures will prevent illegal or unauthorized activities related to your personal data. When using our services, you should be aware that data transmission over the Internet cannot be guaranteed to be completely secure. Despite our efforts to protect your personal data, we cannot guarantee that any data or information you transmit to us via the Internet is entirely safe, and you do so at your own risk.
To protect your personal data, we kindly ask you not to send credit card information or other similar sensitive personal data, including special categories of personal data, to us via email. We also encourage you to safeguard your passwords and not disclose them to anyone else. If you share a computer with others, you should log out of the website or service before leaving to prevent subsequent users from accessing your passwords and personal data. If you believe your password or any personal data has been misused during the use of ENEOS services and applications, please notify us immediately. Please note that we will never ask you to disclose your password or credit card information through unsolicited phone calls or emails.
VI. How We Protect the Personal Information of Minors
ENEOS does not actively collect personal data from children. Individuals under the age of 18 should not use our services to submit their personal data.
ENEOS does not actively and directly collect personal information from minors. Where personal information of minors is collected with the consent of guardians, we only use, share, transfer, or disclose such information as permitted by laws and regulations, with guardian consent, or when necessary to protect the minors.
As a guardian, after logging into the ENEOS app, you can query, correct, and delete information related to minors. If it is proven that a minor has registered for and used our services without guardian consent, the guardian may contact ENEOS customer service, and we will delete the relevant minor's personal information promptly after verification.
For personal information of children under the age of 14, we adhere to the principles of legitimacy and necessity, informed consent, clear purpose, security protection, and lawful use, in accordance with the "Regulations on the Protection of Personal Information of Children on the Internet" and other relevant laws and regulations, for the collection, storage, use, transfer, disclosure, and other processing of children's personal information. When you, as a guardian, choose to use ENEOS’s relevant energy trade services on behalf of the child under your care, we may need to collect personal information of the child from you to fulfill those services. If you do not provide this information, you will not be able to enjoy the relevant services we offer. Additionally, when using evaluation functions, you may voluntarily provide children's personal information; please be aware of this and choose carefully. As a guardian, you should properly fulfill your supervisory duties to protect the security of children's personal information.
If you have any opinions, suggestions, or complaints regarding children's personal information, please contact us; detailed contact information can be found in Section IX “How to Contact Us” of this policy.
VII. How You Exercise Your Personal Information Rights
You have the following rights regarding your personal information:
1. Access, Correction, Supplementation, and Deletion of Personal Information
After logging into the ENEOS website or app, you may access, correct, supplement, and delete your personal information yourself.
Additionally, in the following cases, you may contact us through the contact details provided in Section IX of this policy to request deletion of personal information, and we will respond promptly:
(1) If our processing of personal information violates laws or regulations;
(2) If we collect or use your personal information without your explicit consent;
(3) If our processing seriously breaches our agreement with you;
(4) If you no longer use our products or services, or you actively cancel your account;
(5) If we permanently cease to provide you with products or services.
After you or we assist in deleting relevant information, due to applicable legal requirements or technical reasons, we may not immediately delete such information from backup systems. We will securely store your personal information isolated from any further processing until it can be deleted or anonymized during backup updates.
2. Change the Scope of Your Consent or Withdraw Consent
You may change the scope of your consent for us to continue collecting personal information or withdraw your consent by deleting your personal information, disabling device functions, etc. You may also withdraw all consent by canceling your account. However, please note that each service feature requires some basic personal information to function (see Section I “How We Collect and Use Your Personal Information” of this policy). Once you withdraw consent, we cannot continue providing the related services. Due to the special nature of some products and relevant laws, if the service you use is not yet completed (e.g., travel products/services not yet finished, or financial products with outstanding debts), you may not be able to withdraw consent before the service ends. For ongoing processing of your personal information, after you take the above actions, we will cease processing such information, but these actions will not affect prior processing based on your consent.
3. Cancel Your Account
You may cancel your account by calling customer service and completing verification. After cancellation, all information in your ENEOS account will be cleared. We will no longer collect, use, or share personal information related to the canceled account, but previously collected information will be retained according to regulatory requirements and may be accessible to authorities during the legally required retention period.
4. Restrict Automated Decisions
ENEOS uses automated decision-making to push information and commercial marketing to you. We provide options that are not based on your personal characteristics or offer convenient ways to opt out.
5. Transfer of Personal Information
If you wish to transfer your personal information to a designated personal information processor, you may contact us through Section IX of this policy. After identity verification and review per national cyberspace administration requirements, we will provide a means to transfer your personal information unless otherwise stipulated by laws or this policy.
6. Responding to Your Requests
If you cannot access, correct, supplement, or delete your personal information via the above methods, or need to access, correct, supplement, or delete other personal information generated when using our products/services, or wish to transfer your personal information, or believe we have violated laws or agreements related to your personal information, you may contact us via Section IX of this policy.
For security, we may require a written request or identification documents and will respond promptly after verifying your identity. We generally do not charge fees for reasonable requests, but may charge for repeated or excessive requests. We may refuse unreasonable or technically difficult requests, requests that risk others’ rights, or impractical requests (e.g., involving backup servers).
We cannot respond to requests in the following cases as required by law:
(1) Related to ENEOS’s compliance with legal obligations;
(2) Related to national security or defense;
(3) Related to public safety, public health, or major public interests;
(4) Related to criminal investigation, prosecution, trial, and enforcement;
(5) Where there is evidence of malicious intent or abuse of rights by you;
(6) To protect significant rights (life, property, etc.) where obtaining your consent is difficult;
(7) Where responding to your request would cause serious harm to you or others’ legal rights;
(8) Related to trade secrets.
VIII. Policy Revisions and Notifications
ENEOS reserves the right to revise, modify, or amend this policy at any time by any means. When changes are made, we will update the “Last Updated” date at the top of this policy and the changes will take effect after public notice. We encourage you to regularly check for updates. We will not reduce your rights under this policy without your explicit consent.
IX. How to Contact Us
If you have any questions, comments, or suggestions related to this policy, you may contact our Personal Information Protection Officer:
Recipient: ENEOS (Shanghai) Corporation
Address: Unit 06, 7th Floor, Tower I, Jinhongqiao International Center, No. 523 Loushanguan Road, Changning District, Shanghai
Email: privacy@eneos.com
ENEOS will respond to your requests via the email address used for the request, the phone number registered with us, or other suitable methods. Depending on your request, we may work with you and/or your company to review and respond. We commit to cooperating fairly to resolve any complaints or concerns you have about our use of your personal information. However, if you believe we have failed to assist, you may have the right to complain to your country’s data protection authority (if applicable).
X. APP Permission Requests Related to Personal Privacy and Purpose Explanation
1. Read and Write External Storage
Permission purpose: Select images to upload
Permission codes: WRITE_EXTERNAL_STORAGE, READ_EXTERNAL_STORAGE
(1) Camera
Permission purpose: For photo taking and uploading, acquiring image data
Permission code: CAMERA
(2) Calendar
Permission purpose: To set calendar reminders
Permission codes: READ_CALENDAR, WRITE_CALENDAR
2．Third-Party SDK Code Contains Corresponding Permission Strings
To ensure the implementation of ENEOS Travel-related functions and the safe and stable operation of the application, ENEOS may integrate development kits (SDKs) provided by third-party software for relevant purposes.
ENEOS strictly monitors the security of software toolkits (SDKs) used by partners to collect information, in order to protect data security.
The third-party SDKs integrated by ENEOS are listed in the directory.
Please note that due to version upgrades, policy adjustments, or other reasons, the types of data processing by third-party SDKs may change. Please refer to their official publicly disclosed statements for the latest information.
(1) Baidu Maps SDK
Function: Provides location and map display services to users
Permissions: Access GPS information, access network information
Data collected: Device information, network information, GPS information
Privacy policy link: https://map.baidu.com/zt/client/privacy/index.html
(2) Tencent Browser Service
Function: Enhances browsing capabilities and optimizes the mobile webview
Permissions: View network status, access network information
Data collected: Location, network connection status, clipboard
Privacy policy link: https://x5.tencent.com/docs/privacy.html
ENEOS will respond to your requests through the email address used for the request, the phone number you registered with us, other phone numbers archived for you, or any other appropriate method. Depending on your request, we may review it with you and/or your company to help address and respond accordingly. We are committed to working with you to fairly resolve any complaints or concerns you may have about our use of your personal information. However, if you believe we have not assisted you in resolving your complaints or concerns, you may have the right to file a complaint with the data protection authority in your country (if such an authority exists).
If you are an employee of one of our company’s dealers, personal information related to your job performance, including your name, company name and position, and contact details, may be provided to us during business communications for business contact and management purposes, and may be shared with our parent company and affiliated companies.
Regarding dealer employee personal information related to job performance, we will share it with our overseas parent company, ENEOS Corporation, and it may be transferred to Japan, the United States, and Singapore.