TriSpark Charging User Agreement

Update Date: August 16, 2025

Preamble

TriSpark Charging attaches great importance to the protection of users' personal information. These Personal Information Processing Rules apply to the TriSpark Charging APP, open platform products or services. [TriSpark Charging] is provided by Trispark Electric Vehicle Charging Station Co., Ltd. (Registered Address: Office 009 ban Wattay Noi , Sikhottabong, Vientiane capital) for mobile Internet technology development services and charging information technology platform services ("Charging Information Services"). Hereinafter referred to as "TriSpark CHARGING" or "we".

In compliance with local laws, regulations, judicial procedures, or mandatory government requirements, TriSpark Charging is a consumer-side App categorized as "online shopping", whose basic functional service is "purchasing goods". The necessary personal information includes: 1. Registered username and password; 2. Payment information such as payment time, payment amount, and payment channel.

The key contents of these Personal Information Processing Rules include:

1. The scope, purpose, and method for which specific functions may collect and use personal information, as well as the potential impact of refusing to provide personal information;

2. The scope, purpose, and method for which SDKs collect and use personal information and access device permissions;

3. The device permissions that the App (and SDKs) may need to access, the purposes of access, their corresponding business functions, and the method for users to disable the corresponding permissions;

4. How we share and protect your personal information;

5. The rights you hold as a personal information subject, etc.

Your acceptance of these Personal Information Processing Rules only means that you have understood the functions provided by this App and the necessary personal information required for the operation of these functions; it does not mean that you have agreed to our collection of non-essential personal information. For the processing of non-essential personal information, we will separately seek your consent during your use of the services. If you refuse to allow us to collect non-essential personal information, it will not affect your use of basic business functions.

Your acceptance of these Personal Information Processing Rules does not mean that permissions related to personal information will be enabled by default. When you use the corresponding business functions, we will display a separate pop-up window to obtain your consent again before enabling the relevant permissions. After a permission is enabled, you can also disable it at any time through your device settings. If you do not agree to enable a permission, it will not affect the normal use of other unrelated business functions.

Table of Contents：

1. Definition and Scope of Personal Information;

2. Collection of Personal Information;

3. Circumstances Requiring Your Authorization for Access to System Permissions;

4. How We Use Cookies and Similar Technologies;

5. Storage and Protection of Personal Information;

6. Protection of Minors' Information;

7. Use of Personal Information;

8. Sharing, Transfer, Public Disclosure of Personal Information and Connected Third Parties;

9. Circumstances Where Third-Party SDKs Collect and Use Your Personal Information;

10. User Rights;

11. Changes (or: Amendments);

12. How to Contact Us

1.1 Personal information refers to various types of information recorded electronically or by other means that relate to an identified or identifiable natural person, excluding information that has undergone anonymization.

1.2 Sensitive personal information refers to personal information that, if leaked or illegally used, may easily lead to infringement of a natural person’s dignity or endanger their personal or property safety.

1.3 Anonymization refers to the process by which personal information is processed such that it can no longer identify a specific natural person and cannot be restored.

In accordance with local laws, regulations, judicial procedures, or mandatory government requirements, TriSpark Charging is a consumer-side App categorized as "online shopping", whose basic functional service is "purchasing goods". The necessary personal information includes: 1. Registered username and password; 2. Payment information such as payment time, payment amount, and payment channel. If you only wish to use the basic functions of this product/service, you may log in as a guest.

2.1 User Registration/Login

(1) Scope of Essential Information and Non-Essential Information

When you use the registration function, you are required to provide us with at least your real name, account, and password. Such information is essential for this function—if you fail to provide it, you will not be able to complete the registration. Additionally, you may optionally set your gender, mobile phone number, and email address based on your own needs. Such information is non-essential for this function; if you refuse to provide it, the security protection level of your account will be reduced, but it will not affect your use of the registration function.

When you use the login function, you need to provide the account and password you used during registration to log in. If you forget your account password and need to retrieve it, you must contact the relevant person in charge or administrator to reset the password. After that, you can log in again by entering the new password. Please note that if the account and password you provide have not been registered on this platform, you will not be able to complete the password reset. Such information is essential for the login function—if you fail to provide it, you will not be able to log in normally.

2.2 Purchasing Goods (i.e., Charging Services)

(1) Scope of Essential Information and Non-Essential Information

After registering as a TriSpark Charging user, you may purchase goods via TriSpark Charging—specifically, charging your vehicle. This function is a basic service, and we need to collect the following information from you:

1. Order and payment information (payment amount, payment time, payment channel)

In accordance with local laws, regulations, judicial procedures, or mandatory government requirements, as well as to protect your property safety and handle user disputes in accordance with platform rules, we will collect your order and payment information (payment amount, payment time, payment channel). The aforementioned information is essential for this function; if you refuse to allow us to collect such information, you will not be able to use this function.

2. Location Information (Longitude and Latitude)

To recommend nearby charging stations to you, we will collect your location information (longitude and latitude). Before you use the platform for the first time, we will prompt you to choose whether to allow the platform to access your location information (longitude and latitude) and under what circumstances it can do so. After obtaining your permission, we will collect and process your dynamic location information, or calibrate your location information via IP address, GNSS information, base station information, WiFi list, and BSSID. The aforementioned information is non-essential for charging services; if you refuse to allow us to collect it, you will not be able to receive recommended stations, but it will not affect your use of basic charging services. You can also find charging stations by manual search.

2. Sensitive Permissions Invoked

When we use your location information to recommend charging stations, we will invoke the location permission; when you use the scan function to access offline charging scenarios, we will invoke the camera permission.

3. Third-Party SDKs Used

The payment function is implemented through WeChatSDK (WeChat Pay) and Alipay App Payment Client SDK. Among them, the Alipay App Payment Client SDK requires location information (non-GPS positioning) to complete payment security verification; failure to provide the aforementioned essential information will prevent the payment function from being implemented.

2.3 Invoice Function

(1) Scope of Essential Information and Non-Essential Information

In accordance with the provisions of local laws, regulations, judicial procedures, or mandatory government requirements, TriSpark Charging provides you with a channel to issue invoices, and the requirements related to invoices shall be the responsibility of a third-party professional institution. When you choose to issue an invoice through this platform, you are required to provide the third-party professional institution with relevant information such as charging order information, invoice receiving information, and the necessary invoice-issuing information required by the tax authorities; if you apply for a paper invoice, you also need to provide information related to the delivery address. The aforementioned information is essential for the third-party professional institution to handle invoice matters. If you refuse to provide it, you may not be able to obtain the invoice through this channel, but it will not affect your use of the basic charging service functions.

2.4 Sharing Function

(1) Third-Party SDKs Used

The sharing function is an additional feature of TriSpark Charging, and you may choose whether to use it independently. When you use the sharing function:If you share content with WeChat contacts or to WeChat Moments, the "WeChat Sharing and Collection" SDK will be used. This SDK will collect the images or content you actively select within the App.Failure to provide the aforementioned essential information will prevent the WeChat sharing function from working, but it will not affect your use of the basic charging service functions.

2.5 App Update

(1) Scope of Essential Information and Non-Essential Information

When you use the in-App update function, we need to collect network usage information. Such information is essential for this function.When an updatable version of the App is available, you will receive a prompt, and you may choose to install the update or decline it.

2.6 App Adaptation and Security

(1) Scope of Essential Information and Non-Essential Information

When you use TriSpark Charging, to resolve issues such as App crashes and runtime errors, ensure a consistent experience across different devices, and maintain App compatibility with various mobile phone brands and models, we need to collect and use the following information:

Device type, OAID, UTDID, device model, operating system version, and other device information (screen resolution, CPU architecture, memory capacity, storage capacity).To ensure a smooth experience for users on different browsing devices, maintain App function compatibility across versions, and assist in identifying and troubleshooting quality issues, we need to collect your browser type.To help you access your recent search history, we need to collect your search content.To verify whether your click behavior complies with normal product processes, we need to collect your click and view records.The aforementioned information is essential for analyzing and fixing bugs and ensuring security. Failure to provide such information may cause the App to not function properly.

2.7 Personal information that you directly provide to third parties when using third-party services through the TriSpark Charging platform, or authorize TriSpark Charging to share with third parties, shall be subject to the third party’s Personal Information Processing Rules.When you view web pages created by third parties or use applications developed by third parties, these third parties may place their own Cookies or pixel tags. Such Cookies or pixel tags are not under our control, and their use is not governed by these Personal Information Processing Rules.We will make commercially reasonable efforts to require these entities to take protective measures for your personal information, but we cannot guarantee that these entities will definitely take protective measures in accordance with our requirements. Please carefully read their Personal Information Processing Rules before use to decide whether to continue using the third-party services.

2.8 Please understand that the functions and services we provide to you are constantly updated and evolving. If a certain function or service is not mentioned in the preceding descriptions and requires the collection of your information, we will separately explain the content, scope, and purpose of the information collection to you through page prompts, interactive processes, website announcements, or separate agreement signing, in order to obtain your consent.

2.9 In accordance with relevant laws and regulations, we may collect your relevant personal information without seeking your authorization and consent under the following circumstances:

When providing you with the aforementioned basic functions, additional functions, functions for improving products/services, or when third-party SDKs collect and use your personal information, the implementation of some scenarios depends on your consent for the client (App) and third-party SDKs to access the corresponding system permissions of your device.Only when you log in and enter a specific usage scenario for the first time will the client (App) request your consent through a pop-up window. You can check the activation status of various permissions one by one on your terminal device, and enable or disable these permissions at any time (there may be slight differences depending on the terminal device and operating system). In addition, we have also set up a dedicated and centralized permission management page in the client (App) to facilitate your viewing and management of some sensitive permissions.Please note that enabling these permissions means that you continuously authorize us to collect and use this personal information to realize the above-mentioned functions during your use of our services; disabling the permissions means that you revoke these authorizations, in which case we will no longer continue to collect and use this personal information of yours, nor will we be able to provide you with the above-mentioned functions corresponding to these authorizations. Your decision to disable permissions will not affect the processing of personal information previously conducted based on your authorization.

4.1 A Cookie is a mechanism that enables a server-side (or script) to store and retrieve information on the client-side. When you use TriSpark Charging products or services, to provide you with a more convenient and secure access experience, we may use Cookies or similar technologies to collect and store information. During this process, one or more Cookies or anonymous identifiers may be sent to your device.We do this to collect your information, which is used to understand your preferences, conduct research or data analysis, improve products, services, and user experience, or promptly identify and prevent security risks to provide you with better services. We will not use Cookies for any purposes other than those stated in these Rules. You may retain or delete Cookies according to your own preferences. You can clear all Cookies stored in the software, and your relevant information will be deleted once you manually clear them.

4.2 Our platform may also contain certain electronic images (hereinafter referred to as "single-pixel GIF files" or "web beacons"). Web beacons can be used to count users who view web pages or access certain Cookies. We will collect information about your web browsing activities through web beacons, including Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referral/exit pages, operating system, date/time stamp, and clickstream data.

5.1 Information Retention Period

5.1.1 During your use of the services on the TriSpark Charging platform, we will continuously retain your personal information.

5.1.2 When you independently delete your personal information, cancel your account, or withdraw your authorization for the Personal Information Processing Rules, we will retain your personal information in accordance with the following rules:

a.In accordance with the provisions of local laws, regulations, judicial procedures, or mandatory government requirements, we will continue to retain your personal information for three years. Within this retention period, we will cease any processing of your personal information other than storage and the implementation of necessary security protection measures. When your personal information exceeds the aforementioned retention period, we will delete it or process it through anonymization.

b. If you have seriously violated laws, regulations, platform agreements, or platform rules while using the services on the TriSpark Charging platform, your illegal or breach records, as well as the corresponding platform credit records, will be retained permanently. If you register a new account again, we will restore the above-mentioned information.

c. To cooperate with local government authorities and judicial authorities in investigating criminal acts committed by users while using the services on the TriSpark Charging platform, and to better protect users' lives and property safety, if your use of the TriSpark Charging platform services involves a criminal case, we will retain your personal information in accordance with the statute of limitations stipulated in relevant laws.

5.1.3 If any specific agreement signed separately between TriSpark Charging and you contains special provisions on the retention period of a certain type of information, such special provisions shall prevail.

5.2 Geographic Location of Information Storage

5.2.1 As a globally operating company, we provide our products or services through resources and servers worldwide. Meanwhile, we have established data centers in multiple regions across the globe. Therefore, on the premise of complying with local laws and regulations and obtaining your authorization, your personal information may be transferred to or accessed from jurisdictions outside your country/region for the purpose of providing better services. However, data protection laws and the level of protection vary by country and region, and you need to be aware of the risks associated with different data protection laws.Regardless of where your information is processed, we will adopt the protective measures described in this Policy to ensure that the collected data is processed in accordance with this Privacy Policy and applicable laws, and that your personal information receives equal protection in the regions where the products or services are used. For example, during cross-border data transmission, we will obtain your consent and implement security measures such as encryption, de-identification, and signing data transmission/sharing agreements with the recipients.

5.3 Security Protection Measures

5.3.1 We will implement strict information security systems and adopt industry-standard and widely accepted security protection measures to protect your personal information, preventing personal information from being lost, leaked, damaged, or subjected to unauthorized access, use, public disclosure, or modification.

5.3.2 TriSpark Charging adopts the following security technical measures to protect your personal information:

1. Sensitive personal information is encrypted and stored on servers, with storage implemented through data isolation technology;

2. Encrypted transmission protocols are used during data transmission;

3. Strictly control data access permissions, and establish a sound system for applying for and approving access permissions to sensitive data;

4. Establish a data security monitoring and auditing system to implement comprehensive data security controls.

5.3.3 TriSpark Charging also adopts other security measures to protect your personal information:

1. We have established a dedicated personal information protection team and a personal information protection officer to uniformly coordinate and manage the processing and protection of personal information (Contact: trispark.ev@gmail.com);

2. Issue and implement internal personal information management specifications to clearly define protection standards and requirements for users’ personal information;

3. Conduct project risk assessments on personal information processing activities before the launch of new projects or new systems;

4. Sign confidentiality agreements with all employees and service outsourcing personnel, and strictly assign data access permissions based on job responsibilities;

5. Regularly conduct personal information compliance education and training for all company employees and outsourcing service personnel.

We will make every effort to continuously enhance security measures to protect your personal information, but we also ask you to understand that no measure can guarantee 100% security of information.

5.4 Handling of Security Incidents

5.4.1 To address potential security risks, including the leakage, damage, or loss of personal information, we have issued multiple systems within the company. These systems clearly define the classification and grading standards for security incidents and vulnerabilities, as well as the internal handling procedures (including emergency response procedures) and remedial measures for the aforementioned security incidents and vulnerabilities.

5.4.2 In the event of a security incident, we will promptly inform you in accordance with the law of the basic details and risks of the incident, the measures we have taken or will take, and suggestions on how you can reduce risks on your own.

5.4.3 We will promptly notify affected users of the security incident through push notifications, letters, or phone calls. If it is difficult to notify each user individually, we will issue warning information by publishing a platform announcement.

5.4.4 We will also report the handling of personal information security incidents in accordance with the provisions of local laws, regulations, judicial procedures, or mandatory government requirements.

5.5 Cessation of Operations

5.5.1 If the TriSpark Charging platform ceases operations, we will issue an announcement on the TriSpark Charging platform at least 30 days in advance and promptly stop collecting personal information.

5.5.2 After ceasing operations, we will stop the commercial use of personal information. Upon expiration of the minimum retention period stipulated by laws and regulations, we will delete the collected personal information or process it through anonymization.

6. Protection of Minors' Information

We are committed to protecting the personal information of minors who use our products and services. For the purposes of this clause, a "minor" refers to an individual under the age of 18. This App and the services we provide are primarily intended for adults and are not targeted at minors. Minors shall not create their own accounts without the consent of a parent or guardian.With regard to minors' information collected without parental consent, we will only use or publicly disclose such information if permitted by law, explicitly consented to by a parent or guardian, or necessary to protect the minor. If we discover that we have collected a minor's personal information without first obtaining verifiable consent from a parent or guardian, we will take steps to delete the relevant data as soon as possible.

7. Use of Personal Information

7.1 Your personal information will be used in the scenarios explicitly specified in the clause "Collection of Personal Information".

7.2 Your personal information may be used in the following scenarios that are directly or reasonably related to the purposes stated in the clause "Collection of Personal Information":

7.3 If we need to use your personal information beyond the scope directly or reasonably related to the purposes stated in the clause "Collection of Personal Information", we will inform you again and obtain your explicit consent.

8. Sharing, Transfer, Public Disclosure of Personal Information and Connected Third Parties

8.1 "Sharing" refers to the process where TriSpark Charging provides personal information to other personal information processors, and both parties respectively have independent control over the personal information. TriSpark Charging will not share your personal information with external parties, except in the following circumstances:

8.1.1 Sharing with explicit consent: After obtaining your explicit consent, TriSpark Charging will share the information within the scope of your authorization with the third party designated by you.

8.1.2 Sharing under statutory circumstances: TriSpark Charging may share your personal information with external parties in accordance with the provisions of laws and regulations, the needs of resolving litigation disputes, or the requirements legally put forward by administrative or judicial authorities.

8.1.3 Sharing with TriSpark Charging’s affiliated companies: Your information may be shared among TriSpark Charging’s affiliated companies: For businesses using the same account system, we will share your account information (account number, password) among affiliated companies; To maintain platform order and protect the legitimate rights and interests of the platform or platform users, we will share information about users’ illegal acts, breach of contract, or violations of platform rules among affiliated companies. Since the purposes and types of personal information shared by different affiliated companies vary, before you use different business functions or services, we will present you with the independent Personal Information Processing Rules for the corresponding business function or service. The operator’s name and contact information for the business function or service, as well as the type, purpose, and processing method of personal information shared from affiliated companies, will be detailed in the independent Personal Information Processing Rules, and your consent will be obtained. We will only share necessary personal information, which shall be subject to the purposes stated in these Personal Information Processing Rules. If we share your sensitive personal information or if the affiliated companies change the purpose of using and processing the personal information, we will seek your authorization and consent again.

8.1.4 Sharing with business partners: TriSpark Charging may share your personal information with partners or third-party service providers to ensure the smooth provision of services to you. However, we will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary for providing the services. Our partners include:

8.1.5 To protect the legitimate rights and interests of users or other relevant parties, when assisting in handling transaction disputes or conflicts related to you, we may provide the counterparty of your transaction or a third party with a stake in the matter with the information necessary to resolve the transaction disputes or conflicts. Under the following circumstances, if you fail to cooperate in paying the corresponding fees, handling the corresponding accidents, or resolving the corresponding disputes, we will provide your mobile phone number and vehicle information (if available and necessary) to the corresponding charging service provider:

8.1.6 In accordance with relevant laws and regulations, we may share, transfer, or publicly disclose your relevant personal information without seeking your authorization and consent under the following circumstances:

8.2 In the event of acquisition, merger, or restructuring changes, we will require the subject after the change to still comply with the provisions of these Personal Information Processing Rules and perform the original responsibilities and obligations. If the subject after the change needs to modify the purpose of using personal information, we will require it to obtain your explicit consent in advance. Internally, in previous acquisition and merger activities, the data managed by the acquired or merged entity (including users’ personal information) has been processed and protected in accordance with the same standards and requirements as TriSpark Charging’s own data.

8.3 We will comply with relevant laws and regulations and keep your personal information confidential. We will not publicly disclose your personal information unless we have obtained your explicit consent or authorization in advance, it is required by law, or it is for protecting the major legitimate rights and interests of other relevant parties and the personal information has been de-identified.

9. Circumstances Where Third-Party SDKs Collect and Use Your Personal Information

When providing certain functions and/or services, we need to use third-party SDK technology. These third-party SDKs may collect or use some of your personal information/device permissions (for details, please click this link to view the Instructions on Third-Party SDKs Collecting Personal Information and other third-party SDK instructions). Please be informed that when an SDK uses relevant system permissions, it will separately request your consent through a device system pop-up window.We will conduct strict security tests on the relevant SDKs and take technical measures to strive to ensure that they process personal information in accordance with these Rules and other relevant confidentiality and security measures.

10. User Rights

10.1 You may access, copy, correct, or delete your personal information on the TriSpark Charging platform through the following methods:

10.2 We will protect your right to withdraw consent through the following methods. If you withdraw your consent or authorization, it may result in our inability to continue providing you with the services corresponding to the withdrawn authorization. Your withdrawal of consent or authorization will not affect the processing of personal information conducted based on your prior consent.

10.3 In accordance with relevant laws and regulations, we may not respond to the requests for personal information rights listed in this chapter under the following circumstances:

If we determine that we cannot respond to your request, we will inform you of the reason for this decision and provide you with a channel for filing a complaint.

11. Changes

11.1 If the TriSpark Charging platform undergoes the following changes, we will promptly revise these Personal Information Processing Rules accordingly:

a. Changes occur in the purposes, methods of processing users’ personal information, or the types of personal information processed;

b. Changes occur in the geographic location where users’ personal information is stored;

c. Changes occur in our contact information and complaint channels;

d. Other changes occur that may affect the security of users’ personal information or users’ rights related to personal information.

11.2 After revising the Personal Information Processing Rules, we will publish the latest version on the TriSpark Charging platform and re-obtain your consent.

11.3 Without your explicit consent, we will not reduce the rights you enjoy under these Personal Information Processing Rules.

12. How to Contact Us

12.1 We have also set up a dedicated email address for personal information feedback. You may send your questions to the following email address: info@TriSpark-ess.com. No fees are required for you to exercise your personal rights. In accordance with local data protection laws, if your account is serviced from Mainland China, we will respond to your request within 15 working days; if your account is serviced from a region outside Mainland China, we will respond within 30 days.

12.2 If you are not satisfied with our response, especially if you believe that our personal information processing activities have infringed upon your legitimate rights and interests, you may also seek a solution by filing a lawsuit with the competent court at the defendant’s place of domicile.

Important Note: Due to local legal and linguistic differences, the local language version of the privacy policy may differ from this version. In case of any discrepancy, the local language version shall prevail.