LOCWITH Privacy Policy

Last Updated: April 20, 2026

Welcome to the LOCWITH App!

Ride LOCWITH Inc., along with its parent companies, subsidiaries, and affiliated entities (collectively referred to as "LOCWITH," "we," "us," or "our"), takes your privacy seriously!

This Privacy Policy ("the Policy") is designed to explain how we, as the data controller, and the processors we engage (e.g., cloud service providers), collect, use, and process your personal data---both currently and in the future---as well as to inform you of your legal rights regarding your personal data.

If you have any questions regarding anything in the Policy or intend to exercise any rights as a data subject, please contact service@luhongkj.com

If you are located in the European Economic Area (EEA), the provisions in the main body of this Privacy Policy shall apply to you.

For users residing in USA or Canada, please also consult the jurisdiction-specific addendum corresponding to your region. In the event of any conflict between these special provisions and the main policy text, the regional addendum shall prevail.

For individuals from all other countries/regions, we will provide protections in accordance with applicable local laws.

1 How We Collect and Process Your Personal Data

In this section, we will explain the types of personal data we collect and use, how we use it, the legal basis for such use, and the recipients to whom we will disclose your personal data.

While you are not legally required to provide personal data to us, certain personal data is necessary for us to provide our products and services. Without these data, we may not be able to deliver our products and services to you.

Personal Data	Use	Legal Bases	Recipients
When you choose to Sign up/Log in via email, we collect:• Email address, password, User ID, country third-party accounts, we collect:• Google: Google UID, email address, profile picture, country	To create a user account, verify your identity, and facilitate account management---such as by providing region-specific services based on your country or region to enhance service efficiency.	Necessary to perform our contract with you.	Cloud Service Providers, our website, the third-party platform you have chosen (such as Google)
When you forget your password and Reset Your Password, or proactively Change Your Password, we collect:• Email address, your new password	To verify your identity to help you change the password.	Necessary to perform our contract with you.	Cloud Service Providers
When you use Bike Pairing function to pair your bike, we collect:• User ID, QR code of your bike	To pair your bike.	Necessary to perform our contract with you.	Cloud Service Providers
When you fill Bike Registration (optional) to register your bike, we collect:• User ID, email address, address, serial number, purchase date and channel	To provide warranty services based on bike information.	We collect these data with your consent, and these data is necessary to provide warranty services for you.	Cloud Service Providers
When you enter the Garage page to personalize your bike such as bike name and picture, and change your bike in your garage, we collect:• User ID, bike ID, bike name and picture	To personalize your bike and manage your bikes.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike page and check Positioning and Riding Data, we collect:• Bike ID, max speed, average speed, total Calorie, total CO2 reduced	To display the latest updated positioning and riding data.	We collect these data with your consent.	Cloud Service Providers
When you enter the Location page, we collect:• The Location of your bike, and time	To display the latest updated location of you and your bike, and navigate to your bike.	We collect these data with your consent.	Cloud Service Providers
When you click the Operational Slot, we collect:• Operational Slot ID, click behavior	To display the content of the operational slot you have clicked on.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike page and use Diagnostics service, we collect:• Bike ID, diagnostics items, description of diagnostics steps, voice description and diagnostics results	To diagnose your bike.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike page and use Help service, we collect:• The content you entered in the search box	To search for the contents of the instruction manual and related bike information.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike Settings page and use the Update Firmware function, we collect:• Type and version of the firmware of your bike	To confirm whether there is an updatable new version of the firmware.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike Settings page and use the Backup and Restore function, we collect:• Bike ID, bike setting data	To back up your bike setting information and restore it.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike Settings page and use the IoT Service function, we collect:• Bike ID, user ID, equipment ID, network setup short link and ICCID.	To activate and subscribe to IoT services, and display IoT status.	We collect these data with your consent.	Cloud Service Providers
When you enter the Ebike Settings page and use the About My Bike service, we collect:• Bike model, serial number (SN), the date of your purchase, SN and version of the devices on your bike	To display the basic information of your bike.	We collect these data with your consent.	Cloud Service Providers
When you use the Bike Error Notification service, we collect:• Bike ID, error message, timestamp	To notify you when your bike encounters a malfunction.	We collect these data with your consent.	Cloud Service Providers
When you use the Auto Record and Go Record function, we collect:• Mileage, date, calorie and duration of ride	To record and display your cycling data.	We collect these data with your consent.	Cloud Service Providers
After completing a Go ride, you will enter the Ride Summary Page, we collect:• Start time, maximum speed, average speed, distance, riding duration, maximum altitude, elevation gain, gps track	To display a comprehensive summary of your ride.	We collect these data with your consent.	Cloud Service Providers
When you use the Ranking function, we collect:• User ID, nickname, profile picture, mileage, date	To calculate and display your ranking.	We collect these data with your consent.	Cloud Service Providers
When you use the Go function, we collect:• Longitude (six decimal places), latitude (six decimal places), time, bike ID, User ID	To track your location and generate track record.	We collect these data with your consent.	Cloud Service Providers
When you Share the Trip after riding, we collect:• Longitude (six decimal places), latitude (six decimal places), time, bike ID, User ID	To share your riding records.	We collect these data with your consent.	Cloud Service Providers
When you Share Moments on Discover page, we collect:• User ID, content you create (including text, picture and video), hashtag, location	To share content on the Discover community.	We collect these data with your consent.	Cloud Service Providers
When you Read, Like, Comment, Delete and Search a post on Discover page, we collect:• User ID, post ID, browsing, like comment and delete behavior, content of your comment and search	To read, like, comment, delete and search on the Discover community.	We collect these data with your consent.	Cloud Service Providers
When you click Location of a post on Discover page, we collect:• Longitude and latitude of the post	To display the location of this post on the map.	We collect these data with your consent.	Cloud Service Providers
When you Like, Reply, Delete comments of posts, we collect:• User ID, post ID, comment ID, like, comment and delete behavior, content of your comment	To like, reply and delete comments of posts.	We collect these data with your consent.	Cloud Service Providers
When you Follow users on Discover page, we collect:• User ID of you and the users you followed	To follow users you are interested in.	We collect these data with your consent.	Cloud Service Providers
When check Messages on Discover page, we collect:• User ID, post ID, interaction type, interaction content	To display your community interaction messages (including like, comment and reply to your comments).	We collect these data with your consent.	Cloud Service Providers
When you check Following and Followers on Me page, we collect:• User ID, profile picture, nickname, following status	To check your following and follower list.	We collect these data with your consent.	Cloud Service Providers
When you Update your personal data, we collect:• Profile picture, nickname, gender, date of birth, country/region, zipcode	To update your personal data.	We collect these data with your consent.	Cloud Service Providers
When you Log Out, we collect:• User ID	To log out.	We collect these data with your consent.	Cloud Service Providers
When you Change Password, we collect:• User ID, old password, new password	To verify the old password and update it to the new one.	We collect these data with your consent.	Cloud Service Providers
When you Delete Your Account, we collect:• User ID	To delete your account based on your ID.	We collect these data with your consent.	Cloud Service Providers

The following table lists the categories of personal data collected by the App that are stored exclusively on your device. These data are not transmitted to or stored on any cloud servers and remain under your sole control unless you choose to share or back them up manually.

Feature	Data Type
Connection Status	Bike ID, bluetooth connection status, IoT connection status, the latest update time of bike status.
Key Data (such as power, light and lock) and Operations	The on/off status of the power, lock, and lights, as well as the battery level.
Battery	Bike ID, state of health(SoH), charge circles, voltage, current and Battery Lock.
Assistance Level	The assistance level you switched and modified.
Location	The Location of your App.
Ebike Settings	Battery lock, screen brightness, auto power off (min), assistance level, speed and metric, alarm, hill assist, auto shift, crank calibration, derailleur, lock when powered off, security verification - verify interval, security verification - lost mode, unusual activity detection and bike password
Geofencing	Type and range of the fence
Transport Mode	Click behavior
Language	Language Settings
About	Version of your App

Please note: When your bike is not connected to the App, ride data is stored locally on the bike itself. Once the bike connects to the App and the IoT network is activated, the data is uploaded via Bluetooth or IoT services to the App or directly to our servers. After uploading, the data is processed in accordance with this Privacy Policy. Until this upload occurs, no ride data is shared with us or any third party.

2 How We Store Your Personal Data

We manage your data carefully to ensure that we only keep what is necessary. To protect your privacy, we routinely delete logs and retain only the data needed to provide the services you have requested, as detailed in the Policy.

We retain your data for as long as necessary for the purposes outlined in this Policy, and where applicable, in accordance with your consent. Once these purposes are fulfilled or if you submit a deletion request to our Data Protection Officer via email to service@luhongkj.com or terminate your account, whichever occurs first, we will either delete your data or anonymize it. However, Where we are required by applicable laws to retain certain personal data, We will either delete such data after the statutory retention period has expired or anonymize it.

Additionally, the LOCWITH App is not intended for children. If you are under 16, do not use or provide any information on this App. If you believe we might have any information from or about your child, please contact us at service@luhongkj.com to delete the data of your child.

3 How We Disclose Your Personal Data

We may transfer your personal data outside of your location as necessary to provide our services.

We disclose your personal data with:

• Third Party Service Recipients: Only when necessary will we share your personal data with third parties. For your reference, we have provided a table below outlining how your data is shared with third-party service providers.

Third Party Recipients	For What?
Cloud Service Providers	Hosting and delivering our services
Authentication Service Providers	User verification and account security
Health and Fitness Service Providers	Recording and sharing your route from different Apps

• Corporate Group Companies Companies within our corporate group process your personal data solely for the purpose of providing service to you. All such group companies may only use your personal data in accordance with this Policy.
• Legal and Regulatory Bodies We may be legally obligated to disclose your data to authorities under certain circumstances. For instance, when complying with legal demands such as subpoenas or search warrants, we might not be able to notify you in advance or obtain your consent for such disclosures.
• Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer your personal data to the our professional advisors such as attorneys or accountants ("Outside Professionals"), other advisors, potential transactional partners, or other third-parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Please note: Your cycling distance and rank are automatically displayed on our Ranking, which is visible to every user of the App worldwide. In addition, if you choose to share your ride data, including routes, locations, or activity details, on our Discover community or other public platforms, you may disclose sensitive personal data. Please share carefully and be mindful.

4 How We Protect Your Personal Data

We implement technical and organizational security measures, including encryption technology, to protect your information. Access to our systems and technology is strictly limited by comprehensive information security policies.

We maintain a formal incident management process to ensure the swift identification, response, and resolution of any security incidents. Our process is designed to minimize impact and keep you informed without delay.

5 Where Will Your Personal Data Be Processed

For users located in Europe, your personal data is stored in the data center located in Germany. For users in Canada and the United States, your data is stored in the data center located in the United States. However, due to the global distribution of our operations and support teams, this data may be accessed by authorized personnel from various regions. We implement appropriate safeguards to ensure the protection of your data, including Standard Contractual Clauses (SCCs) and Transfer Impact Assessments (TIAs). This remote access is governed by strict purpose limitation (only for specified service operations) and is subject to robust access controls, audit logging, and other technical and organizational measures to ensure that your personal data remains protected to standards equivalent to those of the EU.

If you would like to learn more about the safeguards we have implemented to protect personal data accessed remotely by our employees, you may contact us at service@luhongkj.com.

6 Your Rights

If you reside in the European Economic Area (EEA), you have the following rights:

• To confirm if we have your data, see what we hold, and get details like why we use it, who we share it with, where we got it (if not from you), how long we keep it, whether we use it for automated decision-making, including profiling, and more.
• To fix or complete your data.
• To delete your data -- for instance, when you close your account, withdraw consent, or we have used it unlawfully.
• To request to pause using your data (but keep it) if you dispute its accuracy, question our right to use it, or object to processing.
• To receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format. Additionally, you are entitled to transmit this personal data to another entity without any hindrance from us.
• To withdraw your consent at any time.
• To lodge a complaint with a data protection supervisory authority. https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
• To exercise your rights above, you can email us at service@luhongkj.com. Please specify which right(s) you wish to exercise and your intended action. For security, we may ask for identity verification or clarifying your request details to prevent unauthorized data access. We will respond within legal timelines.

7 Updates

We will inform you of any changes via general announcements on our services or by sending you a notification when you log in to or update the App. If the update includes terms that significantly impact your rights, we will seek your consent once more.

8 Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Policy, this English version shall prevail.

SUPPLEMENTAL TERMS -- JURISDICTION-SPECIFIC

Some jurisdictions' laws contain additional terms for users of the App, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Policy above.

USA

If you are a U.S. resident, we process your personal information in accordance with applicable U.S. state privacy laws. This section contains information required by U.S. state privacy laws, such as the California Consumer Privacy Act (CCPA), which supplements our privacy policy.

For this appendix, "Personal Information" refers to any information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked (directly or indirectly) to a specific consumer or household, as well as any other information defined as personal data under the California Consumer Privacy Act (CCPA) and other U.S. state data privacy laws.

In the preceding twelve months since this notice was last updated, we have collected personal information from the following categories:

• Identifiers.
• Information that identifies or is capable of being associated with you.
• Commercial information.
• Internet or other electronic network activity information.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Sensitive personal information.

The sensitive personal information we collect includes:

Account log-in credentials (in combination with passwords) We collect your account log-in credentials to provide you with account-based services (e.g., social interaction). These credentials are encrypted during transmission and storage. We do not sell or share this data with any third parties.

Precise geolocation We collect your precise geolocation data in these scenarios and for these following purposes:

Scenarios	Use
When you enter the Location page	To display the latest updated location of you and your bike, and navigate to your bike.
When you use the click "Go"	To track your location and generate track record.
When you Share Your Trip	To share your riding records
When you use Dealer service	To calculate and display the location of the nearest bike dealer.

This data is used exclusively for device connectivity and will not be used for any other purposes, including but not limited to advertising, analytics, or third-party sharing.

Health data We collect your health data (including your riding route, riding time, elevation increase, riding speed and calories consumed) We collect and use sensitive data solely to record and display your ride activities and to enable social sharing features. These data will not be used for any other purposes, including but not limited to advertising, analytics, or third-party sharing.

The LOCWITH App is not intended for children under 16 years of age. If you are under 16, do not use or provide any information on this App. If you believe we might have any information from or about a child under 16, please contact us at service@luhongkj.com.

If you would like to learn more about how we store, disclose and protect your personal data, and where will your personal data be processed, please refer to the following section of this Privacy Policy:

• "How We Store Your Personal Data";
• "How We Disclose Your Personal Data";
• "How We Protect Your Personal Data";
• "Where Will Your Personal Data Be Processed";

Under the CCPA and other U.S. state data privacy laws, you may exercise the following rights:

• The right to request a copy of the personal information that we have collected about you in the prior 12 months.
• The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.
• The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
• The right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
• The right to correct inaccurate personal information that we maintain about you.
• The right to limit the use and disclosure of sensitive personal information.
• The right to opt-out of both the sale and sharing of personal information, including for cross-context behavioral advertising
• An authorized agent can submit an access or deletion request on your behalf by sending a written authorization, signed by you, to us via email at service@luhongkj.com. However, we may still require you to directly verify your identity and confirm that you provided the authorized agent with permission to submit the request.

Canada

In accordance with Canadian Personal Information Protection and Electronic Documents Act (the "PIPEDA") and applicable Canadian provincial privacy acts, we adopts this Canada Privacy Addendum.

We have collected personal information from the following categories:

• Identifiers.
• Information that identifies or is capable of being associated with you.
• Internet or other electronic network activity information.
• Geolocation data.
• Sensory Data (Such as audio, electronic, or similar information)
• Sensitive type of personal information.

We only collect, use and disclose personal information with your express or implied consent, except in limited circumstances such as authorized by applicable law. Sensitive types of personal information---such as precise geolocation data---are collected solely with your express consent. For Bluetooth and location permissions, we inform you via pop-up notifications and obtain your consent. You can disable these permissions anytime by going to Settings > Device Permissions. This information is used exclusively for the purposes outlined at the time of collection, and is not shared with third-party service providers without your prior consent. To ensure the security of your data, we implement robust technical measures, including encryption during transmission, to protect your information from unauthorized access or disclosure.

If you would like to learn more about how we store, disclose and protect your personal data, and where will your personal information be processed, please refer to the following section of this Privacy Policy:

• "How We Store Your Personal Data";
• "How We Disclose Your Personal Data";
• "How We Protect Your Personal Data";
• "Where Will Your Personal Data Be Processed";

Under the PIPEDA and applicable Canadian provincial privacy acts, you may exercise the following rights:

• The right to be informed about our policies and practices regarding the collection, use, and disclosure of their personal information.
• The right to request access to the personal information that us holds about you.
• The right to request a rectification if your personal information held by us is inaccurate or incomplete.
• The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
• The right to withdraw their consent for the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions.
• An authorized agent can submit an access or rectification request on your behalf by sending a written authorization, signed by you, to us via email at service@luhongkj.com. However, we may still require you to directly verify your identity and confirm that you provided the authorized agent with permission to submit the request.