鹿小柒 Privacy Policy

Last Updated: July 29, 2026

Welcome to the 鹿小柒 App!

This Privacy Policy applies to the 鹿小柒 mobile application (the "App"), listed on Google Play under the app name 鹿小柒, published under the developer name Luhong Technology, and operated by LuHong Technology (Shenzhen) Co., Ltd., together with its parent companies, subsidiaries, and affiliated entities (collectively, "we," "us," or "our"). We take 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 questions about this Policy or wish to exercise your privacy rights, contact our privacy team at service@luhongkj.com. Additional developer and contact information appears in Section 9 below.

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 the United States 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 DataUseLegal BasesRecipients
When you choose to sign up or log in using email, we collect:
Email address, password, user ID, and country/region.When you choose Google
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. Alibaba Cloud and Google LLC (when you choose Google Sign-In)
Sign-In, we receive:Google account identifier, name, email address, profile picture, and authentication token. country or region to enhance service efficiency.
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. Alibaba Cloud
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. Alibaba Cloud
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 are necessary to provide warranty services for you. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
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. Alibaba Cloud
When you Log Out, we collect:• User ID To log out. We collect these data with your consent. Alibaba Cloud
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. Alibaba Cloud
When you use the Delete Your Account feature, we process your user ID and information necessary to verify and complete the deletion request. To verify your identity and permanently delete your account and associated data. Necessary to perform our contract with you and comply with applicable legal obligations. Alibaba Cloud
When push notifications are enabled, Firebase Cloud Messaging may process: installation or registration token, application ID and package name, IP address, device and operating-system information, and message-delivery data. To deliver service and security notifications and maintain reliable message delivery. Necessary to provide requested notification functions and for service security and reliability, where permitted by law. Google LLC (Firebase Cloud Messaging)

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.

FeatureData 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
GeofencingType and range of the fence
Transport ModeClick behavior
LanguageLanguage Settings
AboutVersion 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 applicable law requires us to retain certain personal data, we will delete or anonymize that data after the statutory retention period expires.

Additionally, the 鹿小柒 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 ProviderPurpose
Alibaba CloudCloud hosting, storage, backup, security, and service delivery
Google Sign-InUser authentication and account security
Google Maps PlatformMaps, geocoding, location display, nearby dealer search, and navigation
Firebase Cloud Messaging (FCM)Push-notification delivery and delivery reliability

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

Your personal data may be stored and processed in countries or regions where we or our service providers operate, including through Alibaba Cloud infrastructure. The applicable hosting location may depend on the service deployment and your region. Where personal data is transferred across borders, we use safeguards required by applicable law, which may include contractual protections, access controls, encryption, and transfer assessments.

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:

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.

9 Google Play Disclosures and Developer Contact

This section supplements the disclosures above and is intended to clearly identify the App and its developer for users who obtain 鹿小柒 through Google Play.

Google Play app name: 鹿小柒

Google Play developer name: Luhong Technology

Legal entity and operator: LuHong Technology (Shenzhen) Co., Ltd.

Registered business address: Room 503A, Building 2, COFCO Chuangzhi Factory Area, Zone 67, Xingdong Community, Xin'an Subdistrict, Bao'an District, Shenzhen 518000, China (CN)

Privacy contact email: service@luhongkj.com

Developer website: https://www.luhongkj.com/

9.1 Account Deletion

If you created an account in the App, you may request permanent account deletion using the Delete Your Account feature in the App's account settings. You may contact us at service@luhongkj.com if you need assistance with the deletion process. Account deactivation or logout is not treated as account deletion.

After we verify a deletion request, we will delete or irreversibly anonymize the personal data associated with the account, including profile and ride records, except data that must be retained for legal compliance, security, fraud prevention, dispute resolution, or the establishment or defense of legal claims. Data retained for these limited reasons will not be used for other purposes and will be deleted when the applicable retention requirement ends. Residual copies in encrypted backups will be removed according to our regular backup-rotation schedule.

9.2 Location and Background Location

With your permission, the App may access precise location data to display your location and your bike's location, navigate to your bike or a nearby dealer, create a GPS ride track, calculate ride statistics, and enable user-requested trip sharing. When you start Auto Record, Go Record, navigation, or another continuous ride-recording feature, the App may continue accessing location in the background while the feature remains active, including when the App is minimized, the screen is off, or the App is not actively in use. Background location is not collected unless the relevant feature and permission are enabled.

Before requesting location permission, the App will display a prominent in-app disclosure explaining the data collected, the feature that requires it, whether collection continues in the background, and whether the data is transmitted or shared. The Android system permission request will be shown only after this disclosure. You may deny or withdraw location permission in Android Settings; location-dependent features may then be unavailable.

9.3 Sale, Advertising, and Automated Decision-Making

We do not sell personal or sensitive user data. We do not use precise location, ride routes, health and fitness information, account credentials, photographs, videos, or bike identifiers for targeted advertising or cross-context behavioral advertising. We do not use personal data to make solely automated decisions that produce legal or similarly significant effects concerning you.

9.4 Third-Party Services

The App uses the service providers listed below for cloud hosting, Google Sign-In, maps and navigation, and push notifications. Each provider may process only the data necessary for its stated function and is required to protect that data under applicable contractual and legal obligations. This list is intended to match the services included in the released App and the disclosures in Google Play's Data safety form:

Cloud hosting provider: Alibaba Cloud, provided by Alibaba Cloud Computing Co., Ltd. Data processed on our behalf may include account and profile information, device and application information, IP address, server and access logs, approximate location derived from IP address, user-generated content, and other information submitted to or generated through 鹿小柒, to the extent necessary to host the application, store and back up data, operate databases and network infrastructure, maintain security, troubleshoot faults, and provide reliable services. Alibaba Cloud Legal Statement and Privacy Policy: https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202107091605_49213.html.

Authentication provider: Google Sign-In, provided by Google LLC. If you choose to sign in with Google, data processed may include your Google account identifier, name, email address, profile picture, and authentication token. Purpose: to authenticate your identity, create or link your 鹿小柒 account, enable secure sign-in, and prevent unauthorized access. We do not receive your Google account password. Google Privacy Policy:https://policies.google.com/privacy.

Map, geocoding, and navigation provider: Google LLC (Google Maps Platform). Data processed: precise or approximate location, latitude and longitude, destination or search queries, IP address, device information, and usage information, as necessary to display maps, geocode locations, find nearby dealers, and provide navigation. Google Privacy Policy: https://policies.google.com/privacy.

Push notification provider: Firebase Cloud Messaging (FCM), provided by Google LLC. Data processed may include Firebase installation or registration tokens, application ID and package name, IP address, device and operating-system information, and technical or operational message-delivery data. Purpose: to route and deliver service and security notifications and maintain the security and reliability of message delivery. Firebase Privacy and Security: https://firebase.google.com/support/privacy/.

9.5 Retention Criteria

We retain account and profile information while your account is active; ride, route, community, and bike data until you delete the relevant record or account, subject to available product controls; customer-support information for as long as needed to resolve the request and meet legal obligations; and security and diagnostic logs only for the limited period needed for security, troubleshooting, and fraud prevention. When information is no longer needed, we delete or irreversibly anonymize it. We periodically review retained data and restrict access according to job responsibilities.

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), and supplements this 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:

The sensitive personal information we collect includes:

Account login credentials (in combination with passwords): We collect your account login credentials to provide account-based services, such as social interaction. These credentials are protected during transmission and storage. We do not sell this data or share it for advertising purposes.

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

ScenariosUse
When you enter the Location pageTo 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 TripTo share your riding records
When you use Dealer serviceTo 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.

Ride and fitness data: We collect ride-related data, including riding routes, riding time, elevation gain, riding speed, and estimated calories consumed, solely to record and display ride activities and enable user-requested sharing features. We do not use these data for advertising or disclose them to health and fitness service providers.

The 鹿小柒 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, protect, and process your personal data, please refer to the following sections of this Privacy Policy:

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

Canada

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

We have collected personal information from the following categories:

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, protect, and process your personal information, please refer to the following sections of this Privacy Policy:

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