1. Controller
The data controller is the JWH-TUNER operator identified in the Legal Notice. Contact: 3767471929@qq.com.
2. Data we process
- Identity and contact data: name, company, email, phone, WhatsApp or portal account details.
- Vehicle and project data: vehicle model, ECU/TCU/CPC identifiers, software versions, hardware setup, logs, calibration request notes and uploaded files.
- Commercial data: quotes, orders, invoices, support history, renewal status and delivery records.
- Technical data: IP address, browser, device category, referrer, visited page path, visit time, language preference, security logs, and country, region or city derived from the IP address.
3. Purposes and legal bases
- To answer inquiries and prepare quotes: legitimate interests or pre-contractual steps.
- To provide ordered services/products: contract performance.
- To keep accounting, tax, consumer and legal records: legal obligation.
- To secure the website, portal and file workflow: legitimate interests.
- To measure website visits, traffic sources, country or city distribution, device categories and service demand: legitimate interests.
- To send optional marketing: consent, where implemented.
4. Recipients
Data is shared with hosting providers, portal/service providers, payment providers, logistics providers, professional advisers, tax/accounting providers, licensed software vendors, compliance authorities where required, and support contractors operating under appropriate confidentiality or data-processing terms.
5. International transfers
If data is transferred outside the EU/EEA, we will use a lawful transfer mechanism where required, such as an adequacy decision, Standard Contractual Clauses, or another mechanism recognised under GDPR.
6. Retention
Inquiry records are kept only as long as needed for follow-up. Contract, tax and warranty records are retained for the statutory limitation and accounting periods that apply to the relevant transaction. Website analytics records are kept for operational reporting and security review. Uploaded files and logs are deleted or archived according to the project agreement, support need and legal retention duties.
7. Your GDPR rights
Subject to legal conditions, you have the right to request access, rectification, erasure, restriction, portability, objection to processing, and withdrawal of consent. You also have the right to lodge a complaint with a competent EU/EEA Data Protection Authority.
8. Automated decision-making
The public website does not make automated decisions with legal or similarly significant effects. Portal pricing, security screening and account controls are reviewed under the privacy notice that applies to the portal workflow.
9. Security
We use reasonable technical and organisational measures for website, portal and file workflow security. No online transmission is fully risk-free, so customers should avoid uploading files or personal data they are not authorised to share.