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 here [insert hyperlink].
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:
It would be helpful to start by explaining some key terms used in this notice:
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"We", "us", "our" |
The ECARX group of companies |
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"Personal data" |
Any information relating to an identified or identifiable individual |
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"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 |
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"Data subject" |
The identified or identifiable individual to whom personal data relates. |
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):
For more specific details, please visit the respective vehicle brand website.
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.
We collect most of this personal data directly from you — in person, by telephone, text or email, through use of vehicle software made by us and/or via our website. However, we may also collect information:
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
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, (iv) a driver or an owner using a vehicle that operates with our technology and (v) an employment candidate:
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What we use your personal data for |
Our reasons |
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To manage our relationship with you |
To respond to communications For investor relations |
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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 |
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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 |
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Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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What we use your personal data for |
Our reasons |
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Providing products and services to you |
To perform a contract with you or to take steps before entering into a contract |
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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 |
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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 |
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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 |
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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 |
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What we use your personal data for |
Our reasons |
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Procuring products and services from you |
To perform a contract with you or to take steps before entering into a contract |
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To manage our relationship with you |
To obtain the benefit of or enter into a contract with you |
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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 |
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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 |
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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 |
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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 |
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What we use your personal data for |
Our reasons |
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Providing products and services to you |
To perform a contract with you or to take steps before entering into a contract |
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Providing products and services to vehicle manufacturers |
To enhance the quality and availability of our products and manufacturers |
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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 |
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Enhance safety for drivers and owners of vehicles |
Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. to make sure our technology is performing effectively |
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What we use your personal data for |
Our reasons |
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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 |
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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 |
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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 |
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 routinely share personal data with:
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:
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:
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.
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’).
Personal data related to vehicle drivers and owners will be processed outside China and in the region where that person is based.
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’.
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.
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:
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
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.
You may have the following rights in respect of your personal data:
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Access |
The right to be provided with a copy of your personal data |
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Rectification |
The right to require us to correct any mistakes in your personal data |
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Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data — in certain situations |
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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 |
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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 |
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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 |
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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 |
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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
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.
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.
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.
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.
This policy is prepared in accordance with the laws of England and Wales and shall be governed and construed accordingly.
