Armada Energy group and its affiliated parties (collectively, "Armada Energy", "we", "us", and "our") respect your privacy. Therefore, we have developed a privacy statement (hereinafter referred to as "this Statement") that covers how we collect, use, disclose, process, and protect your personal data when using our websites, products (including software), or services. Please take a moment to read and understand our Privacy Statement and let us know if you have any questions.
This Statement explains how Armada Energy processes your personal data, but does not cover all processing scenarios as you will be informed in specific processing activity. Therefore, before using a specific product or service, it is recommended that you read the privacy notice or supplementary statement released by Armada Energy for that product or service to understand how it processes your personal data.
This Statement applies only to websites, products, and services that display or mention this Statement.
This Statement describes:
I. How Armada Energy Collects and Uses Your Personal Data
II. How Armada Energy Processes, Shares, Transfers and Discloses Your Personal Data
III. How Armada Energy Protects Your Personal Data
IV. Your Rights
V. How Armada Energy Protects Children's Personal Data
VI. Links to Third-Party Websites, Products, and Services
VII. International Transfers of Your Personal Data
VIII. Contact Us
IX. Updates to This Statement
I. How Armada Energy Collects and Uses Your Personal Data
A. Personal Data Collected by Armada Energy
Personal data means any electronic or other information which alone or jointly with other information can be used to identify a natural person or make him/her identifiable. You may directly provide us with such data when you use our website, our RA software, or services, or interact with us by, for example, creating an RA account or contacting us for support. We may also obtain data by recording how you interact with our websites, products, or services. For example, we may use technologies like cookies or receive use data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our services. The personal data we collect includes name, enterprise name, email addresses, login information (account and password), etc., depending on how you interact with Armada Energy. We also collect the information you provide to us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service support. In addition, we may also collect non-identifiable data, which refers to data that cannot be used to identify an individual, for example, the statistics on website visits and application downloads.
Before using our products or services, you may need to provide personal data. You do not have to provide your personal data to Armada Energy, but in some cases, the non-provision of certain personal data will cause the inability to provide you with some related products or services.
B. How Armada Energy Uses Your Personal Data
Armada Energy may use your personal data for the following purposes:
(1) To register an RA account.
(2) To verify your identity. When you verify your identity, we and third-party service providers may collect personal data from you including your name or your entity name, email address and other log in information.
(3) To send you important notifications.
(4) To provide personalized user experience and content.
(5) To send you information with respect to RA and services you might be interested in, invite you to Armada Energy's promotional activities and market surveys, or send marketing information to you. If you do not want to receive such information, you can opt-out at any time.
(6) To collect user feedback. The feedback you choose to provide is important to help Armada Energy improve its services. To process your feedback, we may use the personal data you provide to contact you and keep records.
(7) To carry out internal auditing, data analysis, and research; analyze business operation efficiency and measure market shares; and improve Armada Energy's products and services.
(8) Troubleshooting when you send us error reports.
(9) Ensuring the security of our products, services, and customers or users.
(10) To comply with applicable laws, regulations, relevant industry standards or our policies.
(11) Other purposes with your consent.
II. How Armada Energy Processes, Shares, Transfers and Discloses Your Personal Data
（A）Entrusted Process
Armada Energy may entrust third parties to process your personal data on Armada Energy's behalf, including but not limited to the companies that could handle hotlines, send emails, provide technical support. Those companies will only use the personal data for providing the services to you on behalf of Armada Energy.
Armada Energy will sign strict confidentiality agreements or personal data processing agreements with the entrusted parties, requiring them to comply with this Statement and take appropriate confidentiality and security measures when processing personal data.
（B）Share
"Share" refers to the process by which Armada Energy provides personal data to other personal information controllers and each party has independent control over the personal data. We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:
(1) Sharing with consent: After obtaining your consent, Armada Energy will share the information that you have authorized with specified third parties or categories of third parties.
(2) Sharing pursuant to laws and regulations: Armada Energy may share your information as required by laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law.
(3) Sharing with Armada Energy's affiliates: Your information may be shared within Armada Energy's affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services. For example, we verify the global uniqueness of accounts before allowing them to be registered.
(4) Sharing with business partners: Your information, including order, account, device, and location information, may be shared with third parties such as business partners to ensure the smooth completion of the services provided to you. Your information will be shared within legitimate, proper, necessary, specific and definite purposes, and only the information necessary to provide services would be shared.
(5) Sharing with service providers: Armada Energy may share your information with third parties who support our functions, including third parties who supply or provide us with infrastructure technology services, logistics and distribution services, payment services, data processing services, etc. We share this information in order to achieve the functions of our products and services, for example, we may share your order information with logistics service providers to arrange delivery; or we may need to share your order number and order amount with third party payment institutions to enable them to confirm your payment instructions and complete payment.
In scenarios (3) to (5), Armada Energy will ensure that the lawfulness of this sharing and sign stringent non-disclosure agreements (NDAs) and/or data processing clauses with the companies, organizations, and individuals with whom personal data is shared, requiring them to comply with this Statement and take appropriate confidentiality and security measures when processing personal data.
（C）Transfer
"Transfer" refers to the process of transferring control of personal data from Armada Energy to another personal data controller. We will not transfer your personal data to any company, organization or individual, except in the following cases:
(1) Transfer with express consent: After obtaining your express consent, we will transfer your personal data to other parties;
(2) In the case of merger, acquisition or bankruptcy liquidation, such as the transfer of personal data, we will require the new company or organization that holds your personal data to continue to be bound by this Statement, otherwise we will require the company or organization to seek authorization from you again.
（D）Disclosure
We will only publicly disclose your personal data in the following circumstances:
(1) After obtaining your express consent.
(2) Public disclosure based on law or reasonable grounds: Armada Energy may publicly disclose your data when required by law, legal process, litigation or public and government authorities.
III. How Armada Energy Protects Your Personal Data
Armada Energy attaches great importance to the security of your personal data and has adopted standard industry practices to protect your personal data and prevent it from unauthorized access, disclosure, use, modification, damage, or loss. To this end, Armada Energy takes the following measures:
(1) We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We will retain your personal data only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements, unless extension of the retention period is required or permitted by law. If we no longer need to use your personal data for the purposes set out in this Statement and privacy notice of specific product or service and/or we are not legally required to retain your personal data, we will take reasonable steps to destroy your personal data or render it anonymous. The personal data that you provide to us for know-your-customer (KYC) due diligence purpose will be retained for as long as the relevant anti-money laundering (AML) and data protection legislation requires. By providing us with your personal data for KYC purposes, you expressly acknowledge and consent to such retention period.
(2) We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks.
(3) We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels.
(4) We strictly select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities.
Armada Energy is committed to protecting your personal data. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure.
To cope with possible risks, such as personal data leakage, damage, and loss, Armada Energy has developed several mechanisms and control measures, clearly defined the rating standards of security incidents and vulnerabilities and corresponding processing procedure. Armada Energy has established an emergency response team to implement security planning, loss reduction, analysis, locating, and remediation, and to perform tracking operations with related departments based on security incident handling regulations and requirements.
If any personal data incident occurs, Armada Energy will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that Armada Energy has taken or will take, suggestions about active defense and risk mitigation, and remedial measures. The notification may take the form of an email, text message, push notification, etc. If it is difficult to notify data subjects one by one, we will take appropriate and effective measures to release a Security Notice. In addition, we will also report the handling status of personal data security incidents as required by supervisory authorities.
IV. Your Rights
A. Access, Rectification, Deletion
Legislation in some countries and regions to which Armada Energy provides products and services or from where Armada Energy processes personal data, provides that data subjects the rights request (hereinafter referred to as "requests") in regards to the accessing, rectifying or deleting related personal data by Armada Energy retains.
Requesting modes and channels
Data subjects' requests must be submitted in accordance with Armada Energy designated privacy channels. The requests are valid even when the requester does not specify the laws on which the requests are based.
If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please submit your request to email at ra_techsupport@armada-energy.com. A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
Validity of requests
Most laws require data subjects to comply with specific requirements when they initiate requests. This Statement requires data subjects to:
(1) Submit requests to ra_techsupport@armada-energy.com.
(2) Provide sufficient information for Armada Energy to verify their identities (to ensure those who initiate the requests are the data subjects themselves or those authorized by them).
(3) Ensure that their requests are specific and feasible.
There are some circumstances, provided by laws and regulations, in which Armada Energy may not have to comply with the request in full or at all.
Processing period of requests
Armada Energy will make every effort to ensure that a response is made within one month of the request for access to the personal data subject, and this period may be extended by another two months or such other reasonable time if necessary, taking into account the complexity and volume of requests. In the event of a delay in providing information, Armada Energy will inform the personal data subject of the relevant circumstances and the reasons for the delay. In the event of a conflict between the time limit set out in this paragraph and the local laws and regulations, the local laws and regulations shall prevail.
Result of requests
Upon receipt of the requests from the data subjects, the following results may occur:
(1) The request will be denied
In some cases, the personal data subject's request will be denied, including but not limited to:
a. When the local law does not grant the relevant rights to the personal data subject;
b. When the identity of the person making the request cannot be verified;
c. Requests made by personal data subjects cannot be verified, are out of scope, or are likely to make Armada Energy unable to comply with applicable laws, or make repeated requests;
d. The information is relevant to Armada Energy in a dispute or potential dispute, and the execution of the requested content is likely to harm Armada Energy's interests;
e. If the information is retained for statistical and research purposes only, and the publication of statistics and research results will not disclose the identity of the individual; and
f. Other circumstances provided by law.
If Armada Energy rejects the request for access to the personal data subject, it will formally explain the reason to the requestor.
(2) The request will be processed
When the situation in (1) does not occur, Armada Energy will fulfill the request of the personal data subject. In order to improve the likelihood of success of the request, please provide as much detailed information as possible at the time of making the request, such as the type and specific content of the request, the relevant information of the information holder (such as the name of Armada Energy products and services you use), and the time frame during which the information is generated or processed.
Special Policy
(1) The laws and regulations in most jurisdictions may specify the circumstances under which an organization may not provide data to a personal data subject. These include situations where providing the data would undermine efforts to combat terrorism, where the personal data subject has made repeated requests, or where obtaining and providing the information would require disproportionate resources.
(2) In principle, Armada Energy does not provide the following information:
a. Information in relation to other individual - The personal data subject access request seeks to obtain data that may relate to others other than the personal data subject. Armada Energy does not provide such information unless the individual concerned has consented.
b. Duplicate application - The requester makes the same or similar request for the same personal data subject, the data has not changed in the past period of time, and Armada Energy has already provided the data, in which case Armada Energy will usually not provide a copy of the data. In addition, Armada Energy is under no obligation to provide information that has already been made public.
c. Statements made under conditions of confidentiality - Armada Energy is under no obligation to provide information about the personal data subject if such information is made under conditions of confidentiality.
d. Special Documents - Any special information retained by Armada Energy will not be made public upon the request of the personal data subject for access. In general, special information includes any confidential documents (such as direct communication between the client and his lawyer) and information for the purpose of obtaining or giving corresponding legal advice (whether it is information involved in the proceedings themselves or in the course of court proceedings).
B. Consent Withdrawal
You can change the authorized personal data collection scope or withdraw your consent without affecting the lawfulness of the processing activities based on the consent and prior to such withdraw.
Your rights can be exercised by deleting information, disabling related functions, or setting privacy options on your Armada Energy's product. Armada Energy will release the methods for withdrawing consent for specific products and services in the privacy notice or supplementary statement of those products and services or upon request according to section A above.
C. Deregistering a Armada Energy ID
You can deregister your account in Armada Energy ID-related products. After you deregister your account, we will stop providing products and services, and delete your personal data unless otherwise stipulated by law. Your account cannot be restored after deregistration. You need to register a new Armada Energy ID if you want to use related Armada Energy's products or services again. You can submit a deregistration application and complete the process in setting menu after logging in to your Armada Energy ID on related devices, applications or official website.
V. How Armada Energy Protects Children's Personal Data
We consider it the responsibility of parents to monitor their children's use of our products and services. Nevertheless, it is our policy not to require personal data from children or offer to send any promotional materials to persons in that category.
Armada Energy does not seek or intend to seek to receive any personal data from children. Should a parent or guardian have reasons to believe that a child has provided Armada Energy with personal data without their prior consent, please contact us to ensure that the personal data is removed and the child unsubscribes from any of the applicable Armada Energy's services.
VI. Links to Third-Party Websites, Products, and Services
Armada Energy's websites, application software, products, and services may contain links to third-party websites, products, and services. Armada Energy's products and services may also use or provide products or services from third parties.
All links to third-party websites, products, and services are provided for users' convenience only. We are not responsible for and cannot control how third-parties use personal data which they collect from you. Our privacy policy does not apply to other sites linked from our services.
You need to determine your interaction with such links on your own. Before submitting your personal data to third parties, please read and refer to these third parties' privacy policies.
VII. International Transfers of Your Personal Data
Our products and services are delivered through resources and servers located in different places, to offer our products and services, we may need to transfer your personal data among several countries. By providing us with your personal data through Armada Energy's website or otherwise, you expressly consent to Armada Energy's cross-border transfer of such personal data for the purposes mentioned in this Statement. Authorized Armada Energy personnel and third parties acting on our behalf may access, use and process personal data collected from you in a country/region that is different from the country/region where you entered the personal data, which may have less stringent data protection laws. When we transfer your personal data to other countries/regions, we will protect that the personal data as described in this statement or as otherwise disclosed to you at the time the data is collected (e.g., via privacy notice or supplementary statement of specific product or service).
Armada Energy has implemented global privacy practices for processing personal data protected under various data protection laws. Armada Energy transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data protection laws, including standards and conditions related to security and processing.
VIII. Contact Us
Questions, comments and requests regarding this Privacy Policy are welcome. We have set up a personal data protection team in charge of personal data protection. If you have any questions, complaints or suggestions about this privacy policy or personal data protection related matters, you can submit your questions to ra_techsupport@armada-energy.com.
IX. Updates to This Statement
Armada Energy reserves the right to update this Statement at any time.
Should this Statement be revised from time to time, Armada Energy will release the change notice via various channels, for example, posting the latest version on our official website. If we make any material changes we may notify you by means of a notice on this website.
"Material changes" in this Statement include but are not limited to:
(1) Material changes in our service modes, for example, purposes of personal data processing, types of processed personal data, and ways of using personal data;
(2) Material changes in our ownership structure, organizational structure, etc., for example, ownership changes caused by business adjustment, bankruptcy, or acquisition;
(3) Changes in the main objects of personal data sharing, transfer, or disclosure;
(4) Material changes in your rights regarding personal data processing and the ways in which you can enjoy those rights;
(5) Changes of Armada Energy's departments, contacts, and complaint channels responsible for the security of personal data processing; and
(6) High risks identified in personal data security impact assessment reports.