Privacy policy

Effective Date: June 1, 2026

1. Introduction

This Privacy Policy applies to all official websites operated by Suzhou Brightway Intelligent Technology Co.,Ltd ("we", "us", or "our") within the European Economic Area (EEA), Switzerland, the United Kingdom, Italy, and Spain (collectively referred to as "the Sites").

We respect and protect the personal data privacy of all users who visit our Sites and purchase our products. This policy explains how we collect, use, store, share, and protect your personal data, as well as the rights you have under the General Data Protection Regulation (GDPR) and local data protection laws in your country.

2. Data Controller Information

Data Controller: Suzhou Brightway Intelligent Technology Co.,Ltd

Registered Address: Room 101, Building 6, No. 2888, Wuzhong Avenue, Yuexi Street, Wuzhong Economic Development Zone, Suzhou

Contact Email: privacy@navee.tech

If you have any questions, comments, or requests regarding this Privacy Policy, please contact us using the above method.

3. Personal Data We Collect

We only collect personal data that is necessary for the purposes described in this policy. We may collect the following types of information:

3.1 Information You Provide Voluntarily

Account Information: Full name, email address, phone number, shipping address, billing address, account password
Order Information: Products purchased, order number, payment details, delivery preferences, gift message information
Customer Service Information: Content of communications with us, including inquiries, feedback, complaints, warranty claims, and product support requests
Marketing Information: Preferences for receiving marketing communications and product updates
App-Related Information: Information you provide when registering for or using the NAVEE App, including username, profile information, and device pairing data
Other Information: Any other information you voluntarily provide when filling out forms, participating in surveys, contests, or promotions

3.2 Automatically Collected Information

When you visit our Sites or use our App, we automatically collect certain technical information:

Device Information: IP address, browser type and version, operating system, device identifier, screen resolution, language settings
Usage Information: Pages visited, time spent on pages, links clicked, search queries, referral URLs, exit pages
Transaction Information: Details about your browsing and purchasing behavior on our Sites
App Usage Data: Riding statistics, battery level, speed data, and location information (if you enable location services)

3.3 Information Obtained from Third Parties

We may receive your personal data from the following third parties:

Payment Processors: PayPal, Stripe, credit card companies, Klarna
Logistics Providers: DHL, UPS, FedEx, and local delivery partners
Analytics Providers: Google Analytics, Hotjar
Marketing Service Providers: Meta (Facebook/Instagram), Google Ads, TikTok Ads
Social Media Platforms: If you choose to log in using your social media account
Fraud Prevention Services: Providers that help us detect and prevent fraudulent transactions

4. Purposes and Legal Bases for Processing Personal Data

We process your personal data in accordance with the legal bases specified in the GDPR, as detailed below:

Processing Purpose	Legal Basis (GDPR Article 6(1))
Processing and fulfilling your orders, including payment processing, product delivery, and after-sales service	(b) Performance of a contract
Responding to your inquiries, questions, and complaints, and providing customer support	(b) Performance of a contract; (f) Legitimate interests
Sending you transactional emails such as order confirmations, shipping notifications, and account updates	(b) Performance of a contract
Sending you marketing communications, product updates, and promotional information with your explicit consent	(a) Consent
Improving our websites, products, and services through data analysis and market research	(f) Legitimate interests
Detecting, preventing, and addressing fraud, security breaches, and illegal activities	(f) Legitimate interests; (c) Compliance with legal obligations
Complying with applicable laws, regulations, and court orders	(c) Compliance with legal obligations
Protecting the legitimate rights and interests of ourselves, our users, and the public	(f) Legitimate interests
Providing features and functionality of the NAVEE App, including ride tracking and anti-theft protection	(b) Performance of a contract; (a) Consent (for location services)

Our legitimate interests include:

Ensuring the security and proper operation of our business
Improving the quality of our products and services
Understanding user preferences and providing personalized experiences
Preventing fraud and abuse of our services
Enforcing our terms and conditions

5. Sharing of Personal Data

We only share your personal data in the circumstances described below:

5.1 Service Providers

We share your personal data with third parties who provide services to us, including:

Payment processing: To process your payment transactions securely
Logistics and delivery: To deliver your products to the address you provide
Website hosting and maintenance: Shopify (see Section 6 for details)
Data analysis: To help us understand how users interact with our Sites
Marketing services: To assist us in running marketing campaigns and advertising
Customer service: To provide after-sales support and warranty services
IT and security services: To maintain the security and functionality of our systems

All service providers are required to sign Data Processing Agreements (DPAs) with us, which commit them to strict protection of your personal data and to processing data only in accordance with our instructions.

5.2 Legal Requirements

We may disclose your personal data if required by law, or if we believe in good faith that such disclosure is necessary to:

Comply with legal proceedings, court orders, or government requests
Protect our rights, property, or safety
Protect the safety of our users or the public
Investigate and prevent fraud or other illegal activities

5.3 Business Transfers

In the event of a merger, acquisition, asset sale, or business restructuring, your personal data may be transferred as part of the transaction. We will notify you before any such transfer takes place and ensure that the transferee agrees to comply with this Privacy Policy.

5.4 With Your Consent

We may share your personal data with other third parties with your explicit consent.

6. Shopify Platform Information

Our Sites are hosted and operated by Shopify Inc. Shopify provides us with the e-commerce platform that enables us to sell our products and services to you.

Your personal data is stored in Shopify's data centers, databases, and general Shopify application. Shopify protects your data through the following measures:

Encrypted transmission (TLS 1.2+)
Firewall protection
Regular security audits
Access control and authentication
PCI-DSS compliant payment processing

For more information about how Shopify processes your personal data, please refer to:

Shopify Terms of Service: https://www.shopify.com/legal/terms
Shopify Privacy Policy: https://www.shopify.com/legal/privacy

7. International Data Transfers

We may transfer your personal data to countries outside the European Economic Area (EEA), including:

United States (Shopify, payment processors, analytics service providers)
China (company headquarters and data centers)
Other countries where our service providers are located

When we transfer your personal data outside the EEA, we implement appropriate safeguards to ensure that your data receives the same level of protection as required by the GDPR. These safeguards include:

Use of Standard Contractual Clauses (SCCs) approved by the European Commission
Binding Corporate Rules (BCRs) where applicable
Ensuring that the recipient has obtained appropriate certifications such as the EU-US Data Privacy Framework

You have the right to obtain a copy of the safeguards used for international data transfers by contacting us using the details in Section 17.

8. Data Retention Periods

We retain your personal data for no longer than is required by applicable legal and regulatory obligations, and only for the minimum period necessary to achieve the specific purposes for which the data was collected.

After the retention period expires, we securely delete or anonymize your personal data. If complete deletion is not possible due to technical limitations, we will isolate the data and cease any further processing.

9. Your Data Subject Rights

Under the GDPR, you have the following rights regarding your personal data:

9.1 Right of Access

You have the right to request confirmation that we are processing your personal data and to obtain a copy of that data along with information about the processing.

9.2 Right to Rectification

If your personal data is inaccurate or incomplete, you have the right to request that we correct it.

9.3 Right to Erasure ("Right to be Forgotten")

You have the right to request the deletion of your personal data in the following circumstances:

The data is no longer necessary for the purposes for which it was collected
You withdraw your consent on which the processing was based
You object to the processing and we have no overriding legitimate interest
The data has been unlawfully processed
Deletion is necessary to comply with a legal obligation

9.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in the following circumstances:

You contest the accuracy of the data
The processing is unlawful and you oppose erasure
We no longer need the data but you require it to establish, exercise, or defend legal claims
You have objected to processing based on legitimate interests, pending our response

9.5 Right to Data Portability

You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance from us.

9.6 Right to Object

You have the right to object at any time to the processing of your personal data based on legitimate interests, including processing for direct marketing purposes.

9.7 Right to Withdraw Consent

If we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

9.8 Right to Lodge a Complaint

If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with the data protection supervisory authority in your country of residence.

10. Children's Privacy

Our Sites and services are intended for users who are at least 16 years old. We do not knowingly collect personal data from children under the age of 16. If you become aware that we have collected personal data from a child under 16, please contact us immediately and we will take steps to delete that data.

11. Automated Decision-Making and Profiling

We do not make any decisions that have a legal or similarly significant effect on you based solely on automated processing, including profiling.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, use, disclosure, modification, or destruction.

While we take the above measures, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal data.

13. Data Breach Notification

In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will:

Notify the relevant data protection supervisory authority within 72 hours of becoming aware of the breach
Promptly notify affected individuals
Take all necessary measures to mitigate the effects of the breach

14. Third-Party Links

Our Sites may contain links to third-party websites. We are not responsible for the privacy practices or content of these third-party websites. We recommend that you read the privacy policies of these websites when you visit them.

15. NAVEE App Specific Information

If you use the NAVEE App, we may collect additional information including:

Precise location data (if you enable location services)
Riding statistics including distance, speed, and duration
Device information including serial number, firmware version, and battery status
Anti-theft alarm activation data

You can control the collection of location data through your device settings. Disabling location services may affect certain features of the App.

16. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, business practices, or technological developments. The updated policy will be posted on our Sites with a new effective date.

If we make material changes to this policy, we will notify you in advance by email or by posting a prominent notice on our Sites.

17. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy, or if you wish to exercise your data subject rights, please contact us at:

Email: privacy@navee.tech

We will respond to your request within 30 days of receipt. For complex requests, we may need to extend this period, but we will notify you in advance.

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