Privacy Policy

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Privacy Policy

Effective Date: This Privacy Policy is effective as of March 4, 2024.

Thank you for visiting or using any websites, products, online or offline services, or any other services that reference this Privacy Policy (collectively, the “Services”) owned or operated by Beijing Horizon Information Technology Co., Ltd. and/or its affiliates (collectively, “Horizon Robotics” or “we”). We respect your privacy and take the protection of your personal information seriously. Unless Horizon Robotics has published a separate or supplemental privacy policy for a specific website or service, this Privacy Policy explains the purposes, methods, and scope of the collection, storage, use, and disclosure of personal information in connection with the Services we provide to you, as well as the security measures we adopt to protect such personal information and the choices available to you. Unless otherwise agreed by the Horizon Robotics entity with which you have entered into the Terms of Use (where applicable), the entity that provides the relevant Services to you and is responsible for processing your personal information is Beijing Horizon Information Technology Co., Ltd., a company incorporated in the People’s Republic of China, with its registered address at Unit 301, 3/F, Building 2, No. 9 Fenghao East Road, Haidian District, Beijing.

Unless otherwise specified herein, this Privacy Policy does not apply to any products and/or services provided to you independently by a third party that are accessed through our Services, including any websites or services operated by third parties that are linked through our Services. Please note that if you provide your personal information to a third party while using its products and/or services, such personal information will be subject to that third party’s privacy policy or similar policies. We shall not be liable for any improper use or disclosure of such information by any third party.

Please read this Privacy Policy carefully and pay particular attention to the bolded provisions. If you do not agree with any part of this Privacy Policy, please do not provide your information when requested and discontinue your use of our Services.

We comply with this Privacy Policy and the applicable laws and regulations of the jurisdictions in which we operate. In certain jurisdictions, we may provide additional Privacy and/or Cookies Notices applicable to specific Services or regions (“Special Notices”). Such Special Notices, together with this Privacy Policy, constitute the rules governing the processing of your Personal Data in the relevant jurisdiction. Where a Special Notice applies to you and there is any conflict or inconsistency between this Privacy Policy and the Special Notice, the Special Notice shall prevail. To the extent that a Special Notice does not address a particular matter or is unclear, the provisions of this Privacy Policy shall apply.

This Privacy Policy explains the following:

I. How We Collect and Use Your Personal Data

II. How We Use Cookies and Similar Tracking Technologies

III. How We Retain Your Personal Data

IV. How We Share, Transfer and Publicly Disclose Your Personal Data

V. How We Protect Your Personal Data

VI. Your Rights to Your Personal Data

VII. How We Process/Protect Minors' Personal Data

VIII. How This Privacy Policy is Updated

IX. Contact us

Appendix I List of Horizon Robotics Entities

I. How We Collect and Use Your Personal Data

Unless otherwise provided by applicable laws and regulations in your jurisdiction, “Personal Data”refers to any information, recorded electronically or otherwise, relating to an identified or identifiable natural person, excluding anonymized information. “Sensitive Personal Data” refers to Personal Data that, once leaked or unlawfully used, may easily result in infringement of an individual’s personal dignity or harm to personal or property safety. Such data includes, without limitation, biometric data, religious beliefs, specific identity information, medical and health information, financial account information, location and movement data, as well as Personal Data of minors under the age of fourteen (14).

1. Sources from which we collect Personal Data

We collect Personal Data from the following sources:

(1) information you voluntarily provide to us;

(2) information gathered during your utilization of our Services; and

(3) information concerning you obtained from third parties (if any), with your consent or as otherwise permitted by applicable laws and regulations.

2. Personal data we collect and how we use your Personal Data

The Personal Data we collect will depend on the nature of your interaction with Horizon Robotics (for example, you may be involved in the recruiting process or you may request information about Horizon Robotics or its Services), your chosen privacy settings and the Services you used.

Our Services include basic business functions and non-basic business functions.You are not obligated to provide your Personal Data to us. However, failure to provide necessary Personal Data may prevent us from providing certain Services or responding to your requests. With respect to non-basic business functions, you have the right to refuse our collection of your Personal Data, and such refusal will not affect your use of our basic business functions.

As our functions and Services evolve, if we introduce new Services or features that require the collection of Personal Data not described in this Privacy Policy, we will inform you of the nature, scope, and purpose of such collection through email notifications or updates to this Privacy Policy and obtain your consent.Please note that if you provide us with Personal Data relating to any third party, you represent and warrant that you have obtained all necessary consents from such third party.

Generally, we collect the following categories of Personal Data for the business or commercial purposes described below (with bold and underlined items indicating Sensitive Personal Data):

No.	Scenario	Category of Personal Data	Purposes for Collection	Note
1	•Human Resources Management	•Basic Personal Information:Name, date of birth, gender, place of origin, email address, and phone number • Identity information: ID card, passport, officer ID, residence permit, visa, work permit, Mainland Travel Permit for Hong Kong/Macao residents, Mainland Travel Permit for Taiwan residents, etc. •Online Identifiers:Social media account identifiers and any information you publicly disclose on social media pages (LinkedIn, personal website, GitHub, etc.) or disclose when interacting with us •Education and Employment Information:Information about education and training; information about job seeking and employment history	• Registering and maintaining your account on Horizon Robotics’ Chinese official website and the “Horizon Recruitment” WeChat Official Account • Registering and maintaining your account on Horizon Robotics’ Chinese official website and the “Horizon Recruitment” WeChat Official Account	• Your name, phone number, gender, date of birth, work experience, education background, and email address are required to create an account. If you refuse to provide such information, we will be unable to create an account for you and therefore cannot engage with you in recruitment-related activities or provide related services. • You may choose to provide ID numbers or internship experience, to enable us to offer more personalized services. You may decide whether to provide such information during registration or when updating your profile. We will not require you to proactively provide this information, and refusal to do so will not affect your ability to create an account.
2	•Business Inquiry	•Basic Personal Information: •：Name, email address, and phone number •Employment Information:：Job title and employer •Other Personal Data: Your communications and other feedback, including inquiries, questions, and other messages you send to us directly	• To communicate with you, including responding to your comments, questions, and requests	• To provide business inquiry services, you are required to provide your phone number and email address so that we can contact you and provide quotations and detailed service information. This information is essential for the provision of business inquiry services. If you refuse to provide such information, we will not be able to provide you with the business inquiry service. • You may choose to provide your name, employer, job title, and any other information to help us better understand and address your needs. Provision of such information is voluntary, and refusal to provide it will not affect your use of our business inquiry services.
3	•Service-related	•Basic Personal Information:：Address, email address (optional), and phone number •Online Identifiers:：Social media account identifiers (optional), IP address •Internet activity records: Internet or other electronic network activity information, browsing history(For example, the pages you viewed, the duration of your interaction with each page), log information, and information regarding your interactions with our website, social media accounts, applications, or advertisements. •Device Information:: May include unique device identifiers of the computer, mobile device, technology, or other device you use to access the Services. •Location Information:：Geolocation inferred from your IP address and precise location based on mobile device location.	• To provide and improve the Services and other related business purposes • To determine your location and manage access rights to digital content • For authentication • To provide you with customized content • To fulfill other purposes disclosed at the time we collect your Personal Data	• For more information, please see the “How We Use Cookies and Similar Tracking Technologies” section, including your settings for these technologies. •A unique device identifier is a number automatically assigned to your device when you access a website or server; our systems use it to identify your device. Some service providers may also provide us with the physical location of the device used to access content. For more information, please refer to the “Cookies and Similar Tracking Technologies” section.
4	•Marketing	•Basic Personal Information:：Name, phone number, home address, work address, mailing address, email address •Identity information: ID card •Education and employment information:：Company/industry/department/school, job title/major •Online Identifiers:：Social media account identifiers •Other Personal Data:: Driving history (years of driving), test-drive time, test-drive model, whether you use our developer kits, prior development experience and learnings, event participation intent, etc.	•For market research and other promotional activities beyond Horizon Robotics’ website.	•You may choose to provide addresses and other Personal Data for marketing purposes. Refusal to provide such information will not affect your participation in our activities.
5	•Resume analysis	•Resume:Age, gender, work location, household registration, salary range, political status, nationality, height •Work experience:Company, Job tile, Years of experience •Education:School, degree, major, study mode •Skills:Professional skills, certificates	• Your resume will be collected directly by Shanghai Dayi Cloud Computing Co., Ltd. and used to train the intelligent matching algorithm model to improve recruitment efficiency.	The system will automatically identify hiring preferences for different positions based on historical recruitment data, combined with job deions and candidate profiles, to provide candidates that better match the job requirements. If you do not wish your resume to be used for algorithm model training, you may send a refusal request to: Data-privacy@horizon.auto。

3. Legal bases for our use of your Personal Data

We process your Personal Data only when we have a lawful basis. Depending on applicable law, the bases include your explicit consent, necessity for entering into or performing a contract, compliance with applicable laws, and legitimate interests, as follows:

(1) Your explicit consent

We process your Personal Data based on your prior explicit consent. Subject to applicable laws and regulations, your consent must be voluntary, specific, informed, and explicit. You may withdraw your consent at any time; withdrawal does not affect the lawfulness of processing conducted before the withdrawal. Please note that if our processing relies on your consent and you refuse or withdraw it, we may not be able to provide certain Services.

(2) Necessity for entering into or performing a contract

Where you have the legal capacity to enter into a contract, we may process your Personal Data where necessary to enter into or perform a contract with you, including account registration, password reset, etc.

(3) Compliance with applicable laws

We may process your Personal Data as necessary to comply with our legal obligations. For example, we may use your Personal Data to prevent security incidents, malicious, deceptive, fraudulent, or illegal activities, and to prosecute those responsible. We may also process your Personal Data to conduct internal audits, as required under applicable laws and regulations.

(4) Legitimate interests

If you are a resident of the UK, Switzerland or the European Economic Area (“EEA”),We may also process your Personal Data where necessary to pursue our legitimate interests, or those of you or third parties, provided that these interests do not override your interests or fundamental rights and freedoms. For example, we may use IP addresses and access times to improve our Services and respond to your requests. We may also use your name, email address, phone number, type of inquiry, or information regarding requests for personal data rights to respond to such requests. You have the right to object to processing based on legitimate interests.

II. How We Use Cookies and Similar Tracking Technologies

1. What are cookies and similar tracking technologies?

(1)Cookies

Cookies are small text files downloaded to your browser or device when you visit a website. The web server that sets the cookie can access this information. Cookies typically contain a string of letters and numbers that identify your device, but may also include other data. Some cookies are placed by third parties acting on our behalf.

Cookies may remain on your device for varying durations. Some cookies are "session" cookies, which exist only while your browser or application is open and are automatically deleted when you close them. Other cookies are called “Persistent” cookies. Other cookies are referred to as “Persistent” cookies. The duration that a persistent cookie remains on your device varies depending on the cookie. Persistent cookies can recognize your device when you revisit and use the website.

(2) Web beacons

Some of our webpages contain electronic tags known as web beacons (such as pixel tags, clear GIFs, JavaScript, and local storage, also known as “tracking pixels”) that we use to help deliver cookies, count users who have visited our webpages, and deliver co-branded products (if any). We also include web beacons or similar tracking technologies in our electronic communications to determine whether you open and act on them.

(3) Other similar tracking technologies

In addition to standard cookies and web beacons, our Services may also use other similar tracking technologies to store and read data files on your device. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. But, like standard cookies, these tracking technologies can also store a unique identifier for your device, which can then track behavior.

(4) Third-party cookies

Finally, our Services may include standard cookies, web beacons, or similar tracking technologies (collectively, “Cookies”) provided by third-party analytics providers. These Cookies help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operational activities. Through these technologies, analytics providers may set or access their own Cookies or identifiers on your device to collect information about your use of our websites and other Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or within applications, links clicked, and conversion data. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address). If you would like more information about the types of cookies or similar technologies we use, how we use them, and how to control cookies, please see the Cookies Policy. [Cookies Policy].

III. How We Retain Your Personal Data

"III. How We Retain Your Personal Data We retain Personal Data for no longer than the period necessary to fulfill the purposes outlined in this Privacy Policy and as required by applicable law."

The retention period is three (3) years. Upon expiry, we shall delete or anonymize your Personal Data.

IV. How We Share, Transfer and Publicly Disclose Your Personal Data

1. With your consent or at your direction

Our websites and the “Horizon Recruitment” WeChat Official Account may offer social sharing features and other integrated tools, enabling you to share information with other media platforms, and vice versa. You can use these features to share information with friends or the public. Use of such features is subject to the settings you select on the platforms providing these features. For detailed information regarding the purposes and scope of Personal Data collection and processing associated with social sharing features, please refer to the privacy policies of the respective third-party entities.

2. Third parties providing services on our behalf

We may share Personal Data with vendors, consultants, and other third parties engaged to perform functions on our behalf, including but not limited to hosting or operating our websites and applications, sending emails, and conducting data analytics. We enter into strict confidentiality agreements with such third parties, requiring them to process Personal Data solely for the purposes set forth in this Privacy Policy and to implement and maintain appropriate technical and organizational measures to ensure the confidentiality and security of such Personal Data.

3. Sharing with affiliates

For the purposes described herein, Horizon Robotics may share your Personal Data with its current and future parent companies, affiliates, subsidiaries, and other entities under common control or ownership. We may also share your Personal Data with other Horizon Robotics entities for analytics, account management, and direct marketing in accordance with applicable laws. The entity responsible for managing Personal Data shared under this section is listed in here.

4. Transfer of Personal Data in mergers, divisions, dissolutions, bankruptcy, etc.

Horizon Robotics may undergo corporate transactions, including mergers, divisions, dissolutions, bankruptcies, or the sale of its business. In the course of such transactions, your Personal Data may be transferred. Prior to any transfer, we will inform you of the recipient’s identity and contact information and require that the recipient process your Personal Data in a manner consistent with this Privacy Policy. If the recipient intends to process your Personal Data for new purposes or using new methods, it will seek your separate consent.

5. Mandatory disclosures and legal protections

We may disclose Personal Data to governmental or law enforcement authorities and to other parties involved in or considering legal proceedings to comply with legal obligations, to verify or enforce contracts (if any), or as necessary to protect the rights, property, safety, or security of Horizon Robotics or any third party.

V. How We Protect Your Personal Data

Horizon Robotics is committed to safeguarding the privacy and integrity of your Personal Data, regardless of where it is stored. We implement reasonable measures to protect your Personal Data from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure.

Although we implement and maintain reasonable measures to protect your Personal Data, we cannot guarantee the security of information transmitted through the Website or otherwise via the Internet; any transmission is at your own risk.

VI. Your Rights to Your Personal Data

We acknowledge and respect your rights concerning your Personal Data. The following summarizes the rights you are entitled to under applicable laws and our commitment to safeguarding these rights:

1. Right to be informed

We inform you how we process your Personal Data through this Privacy Policy and ensure transparency in our processing.

You may also learn how we process your Personal Data through the following channels: Data-privacy@horizon.auto

2. Right of access

You may access your Personal Data directly via our Chinese website or service interface (as applicable), including by logging into your account to view information related to your account. If you are unable to access your Personal Data or encounter any issues when exercising your right of access, you may contact us using the contact details provided in this Privacy Policy. We will handle and respond in accordance with applicable laws and regulations.

You may also access your Personal Data through the following channels: Data-privacy@horizon.auto。

3. Right to rectification

If you find that any Personal Data we process about you is inaccurate or incomplete, you have the right to request correction or supplementation. Certain Personal Data can be corrected directly through the relevant product or service pages. For Personal Data that cannot yet be modified through self-service channels, please contact us, and we will process your request in accordance with applicable laws and regulations.

You may also rectify your Personal Data through the following channels: Data-privacy@horizon.auto。

4. Right to erasure

You may delete certain Personal Data you have submitted via your account on our Chinese website and/or through the relevant product interface (as applicable). If we collect or use your Personal Data in violation of our agreement with you, you may also contact us using the contact details in this Privacy Policy to request erasure.We will process and respond in accordance with applicable laws and regulations.

You may also erase your Personal Data through the following channels: Data-privacy@horizon.auto。

5. Right to account cancellation

We provide account cancellation services. You may request to cancel your account via our Chinese website and/or product interface (as applicable). Upon cancellation, we will delete or anonymize all related Personal Data, except where otherwise required by law. Following account cancellation, we will no longer be able to provide services that require account login.

You may also request account cancellation through the following channels: Data-privacy@horizon.auto。

6. Right to restrict processing

You have the right to request the restriction of processing of your Personal Data. This means that we may store your Personal Data but will not process it further, except as necessary to respond to your future requests. You may contact us via the contact details provided in this Privacy Policy to exercise this right, and we will respond in accordance with applicable laws and regulations.

You may also exercise your right to restrict processing through the following channels: Data-privacy@horizon.auto。

7. Right to data portability

To the extent permitted by applicable law, you have the right to obtain your Personal Data in a structured, commonly used, and machine-readable format. For example, if you choose to switch to a new service provider, this right enables you to reliably and securely transfer, copy, or move your Personal Data between our IT system and the new provider’s IT system without affecting its usability.

Upon providing formal authorization, you may exercise your right to data portability by emailing the following address: Data-privacy@horizon.auto。

8. Right to object

Even where processing is based on your explicit consent, necessity for a contract, our legitimate interests, or compliance with applicable laws, you have the right to object to our processing of your Personal Data.

You may exercise your right to object by emailing the following address: Data-privacy@horizon.auto。

9. Right to withdraw consent

Each business function requires certain basic Personal Data to be completed (see “How We Collect and Use Your Personal Data”). You may withdraw your consent or modify the scope of your authorization by deleting information, changing relevant settings, cancelling your account, or by other applicable means.

You may change your consent authorization through the following methods: Data-privacy@horizon.auto。

If you withdraw your consent, we will no longer be able to provide the services associated with that consent, and we will cease processing the relevant Personal Data. However, your withdrawal of consent will not affect the lawfulness of any processing carried out based on your consent prior to its withdrawal.

10. Right to complain

You have the right to lodge a complaint by contacting us using the contact details provided in this Privacy Policy.

VII. How We Process/Protect Minors’ Personal Data

Horizon Robotics does not knowingly collect Personal Data from minors without obtaining appropriate consent from their parents or legal guardians. If you believe that we may have collected Personal Data from a minor without the necessary consent, please notify us using “Contact us” section. We will investigate and resolve the issue promptly. For purposes of this Privacy Policy, “Minors” refers to individuals who have not reached the age of majority in their place of residence.

VIII. How This Privacy Policy is Updated

We recognize that information privacy is a continuing responsibility. Accordingly, we may update this Privacy Policy from time to time to reflect new Personal Data practices or the introduction of new privacy policies. Updates will be communicated by revising the effective date at the top of the Privacy Policy and, in certain circumstances, by providing additional notice (e.g., a notice on our homepage or by sending a notification). We encourage you to review this Privacy Policy periodically when visiting our website.

IX. Contact us

To the extent permitted by applicable laws, you have statutory rights regarding your Personal Data held by us. You may request access to or correction of your Personal Data. You may also choose to opt out of receiving Horizon marketing messages described in our communications. Please note that even if you opt out of marketing messages, we may still send you non-marketing emails, such as emails regarding ongoing business relationships.

If you have any questions or concerns regarding this Privacy Policy, or if you wish to exercise any rights described herein, please contact our Data Protection Officer (or the department responsible for Personal Data protection) via email or postal mail at the address provided below. In general, we will respond within 15 business days or within the timeframe required by applicable laws and regulations.

Department: Data Compliance Committee

Email: Data-privacy@horizon.auto。

Address: Unit 301, 3/F, Building 2, 9 Fenghao East Road, Haidian District, Beijing

Appendix I List of Entities

Horizon Robotics entity	Address
Beijing Horizon Information Technology Co., Ltd.	Unit 301, 3/F, Building 2, No. 9 Fenghao East Road, Haidian District, Beijing
Shenzhen Horizon Robotics Technology Co., Ltd.	Room 04-06, 4/F, Building 5, WeXin Software Science Park, No. 009 Gaoxin South 9th Road, Gaoxin Community, Yuehai Sub-district, Nanshan District, Shenzhen