Privacy Policy

1. Introduction

CJ TECH LLC ("Company," "we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, share, and protect your information when you use the EVcoder mobile application ("the App").

This Privacy Policy complies with the Law of the Republic of Uzbekistan "On Personal Data" (No. ZRU-547, dated July 2, 2019) and other applicable data protection laws and regulations.

Please read this Privacy Policy carefully. By using the App, you acknowledge that you have read and understood this policy and consent to the collection and processing of your information as described herein. If you do not agree with this policy, please do not use the App.

2. Data Controller Information

The data controller responsible for your personal data is:

CJ TECH LLC

Tashkent, Uzbekistan

Email: John@cjonhk.com

3. Information We Collect

We collect the following categories of information:

3.1 Information You Provide Directly

• Account Information — Full name, email address, phone number
• Login Credentials — Username and password (encrypted)
• VIN Queries — Vehicle Identification Numbers (VINs) you search for, vehicle makes and models queried, parts numbers searched
• Contributed Data — Repair experience data, parts compatibility information, technical tips, vehicle configuration notes, images you upload
• Communications — Messages, feedback, support requests, survey responses, and any other information you send to us

3.2 Information Collected Automatically

• Device Information — Device type, operating system version, mobile network information
• Usage Data — App features accessed, pages viewed, search queries, time spent, click patterns, crash logs, error reports
• Performance Data — App launch time, API response time, data load time, connectivity diagnostics
• IP Address — Your IP address and derived approximate location (country/region level only)

3.3 Information from Third-Party Sources

• Vehicle Data — VIN decoding results, vehicle specifications, parts catalogs, OE numbers obtained from third-party automotive data platforms and public databases

3.4 Sensitive Data

We do NOT collect or process sensitive personal data as defined by the Law of the Republic of Uzbekistan "On Personal Data," such as:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Biometric data
• Health information
• Precise geolocation data

If our data collection practices change to include any such categories, we will update this Privacy Policy and obtain your explicit consent.

4. Sources of Data

Our data comes from the following sources:

4.1 Direct from You

Information you provide when creating an account, performing VIN queries, submitting repair data, or contacting us.

4.2 From Authorized Repair Shops and Partners

Vehicle repair experience data, parts usage data, and technical information shared by authorized automotive repair facilities and business partners through the App's professional features.

4.3 From Third-Party Data Platforms

Vehicle specifications, EPC data, and OE parts information obtained from third-party automotive data providers, industry databases, and publicly available sources.

4.4 Automatically from Your Device

Usage analytics, device information, and performance data collected automatically when you interact with the App.

5. How We Use Your Information

We use your information for the following purposes:

5.1 Core Service Delivery

• Providing VIN decoding, EPC, and OE data lookup services — Data: VIN queries, vehicle data, account info · Basis: Performance of contract
• Creating and managing your account — Data: Account information, login credentials · Basis: Performance of contract
• Processing your search queries and returning results — Data: VIN queries, vehicle data · Basis: Performance of contract
• Displaying Contributed Data (repair tips, parts info) to other users — Data: Contributed data · Basis: Consent (implied by submission)

5.2 Service Improvement

• Improving the accuracy and coverage of VIN decoding and parts data — Data: Aggregated query data, contributed data · Basis: Legitimate interest
• Analyzing app usage to enhance user experience — Data: Usage data, performance data · Basis: Legitimate interest
• Fixing bugs, errors, and performance issues — Data: Crash logs, error reports, device info · Basis: Legitimate interest
• Developing new features and services — Data: Aggregated and anonymized data · Basis: Legitimate interest

5.3 Communication and Support

• Responding to your inquiries and support requests — Data: Communications, account info · Basis: Performance of contract / Legitimate interest
• Sending service-related notifications (e.g., account changes, security alerts) — Data: Account information, email · Basis: Performance of contract

5.4 Legal and Security

• Detecting and preventing fraud, abuse, and unauthorized access — Data: All data categories · Basis: Legitimate interest / Legal obligation
• Complying with applicable laws and regulations — Data: All data categories · Basis: Legal obligation
• Enforcing our Terms of Service — Data: All data categories · Basis: Legitimate interest

6. Legal Basis for Processing

For Users located in jurisdictions that require a legal basis for data processing, we process your personal data on the following grounds:

• Performance of Contract: Processing necessary to provide the App services you have requested
• Consent: Processing based on your explicit consent, which you may withdraw at any time
• Legitimate Interest: Processing necessary for our legitimate business interests, provided these interests are not overridden by your rights and freedoms
• Legal Obligation: Processing necessary to comply with applicable laws and regulations

7. Data Storage and Security

7.1 Data Localization

All personal data collected through the App is stored on servers physically located within the Republic of Uzbekistan. This complies with the data localization requirements of the Law of the Republic of Uzbekistan "On Personal Data" (Article 27-1), which requires that personal data of citizens of Uzbekistan be processed and stored using databases located within the territory of the Republic of Uzbekistan.

7.2 Security Measures

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

• Encryption: Data transmission via HTTPS/TLS protocols; sensitive data encrypted at rest using industry-standard encryption (AES-256)
• Access Controls: Role-based access controls limiting data access to authorized personnel only
• Authentication: Multi-factor authentication for administrative access; strong password policies
• Monitoring: Continuous security monitoring, intrusion detection, and regular security audits
• Backup: Regular encrypted backups stored in secure facilities within Uzbekistan
• Data Minimization: Collection limited to data necessary for the specified purposes

7.3 Breach Notification

In the event of a data breach that may compromise your personal data, we will notify you and the relevant regulatory authorities in accordance with applicable law.

7.4 No Guarantee

While we implement robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account Information — For the duration of your account plus 12 months after account deletion
• VIN Query History — For the duration of your account; anonymized after account deletion
• Contributed Data — Indefinitely (as it becomes part of the shared knowledge base); personal attribution removed upon account deletion
• Communications — 24 months from last communication
• Usage Analytics — 36 months in aggregated/anonymized form
• Crash Logs and Error Reports — 12 months

Upon expiration of the retention period, personal data is securely deleted, anonymized, or aggregated so that it can no longer be associated with an identified individual.

9. Data Sharing and Disclosure

9.1 We Do NOT Sell Your Personal Data

The Company does not sell, rent, or trade your personal data to third parties for their marketing purposes.

9.2 Service Providers

We may share your information with trusted third-party service providers who assist us in operating the App, including:

• Cloud hosting provider — Purpose: Server infrastructure and data storage (within Uzbekistan) · Data shared: All stored data (encrypted)
• Customer support platform — Purpose: Managing support tickets and inquiries · Data shared: Account info, communications

All service providers are contractually bound to protect your data and process it only on our instructions.

9.3 Legal and Regulatory Disclosure

We may disclose your information:

• To comply with applicable laws, regulations, legal process, or governmental requests
• To enforce our Terms of Service and investigate potential violations
• To detect, prevent, or address fraud, security, or technical issues
• To protect the rights, property, or safety of the Company, our Users, or the public, as required or permitted by law

9.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.

9.5 With Your Consent

We may share your information for other purposes with your explicit consent.

10. International Data Transfers

10.1 Local Storage Priority

As stated in Section 7.1, all personal data is primarily stored and processed on servers located within the Republic of Uzbekistan.

10.2 Limited Transfers

In limited circumstances, certain data (such as anonymized usage analytics) may be processed by international service providers. In such cases, we ensure that:

• Transfers comply with the Law of the Republic of Uzbekistan "On Personal Data"
• Adequate data protection safeguards are in place (e.g., standard contractual clauses, binding corporate rules)
• Your rights and protections remain equivalent to those provided under Uzbekistan law
• Explicit consent is obtained where required by applicable law

10.3 Cross-Border Access

If you access the App from outside Uzbekistan, your data will be transmitted to and processed on our servers in Uzbekistan. By using the App, you consent to this transfer.

11. Your Rights

Under the Law of the Republic of Uzbekistan "On Personal Data" and other applicable laws, you have the following rights regarding your personal data:

11.1 Right to Access

You have the right to request confirmation of whether we process your personal data, and if so, to access a copy of that data.

11.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data we hold about you.

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

You have the right to request deletion of your personal data when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw your consent (where processing is based on consent)
• The data has been unlawfully processed
• Deletion is required by applicable law

11.4 Right to Restrict Processing

You have the right to request restriction of processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

11.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

11.6 Right to Object

You have the right to object to processing of your personal data based on legitimate interests, including profiling.

11.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

11.8 Right to Complain

You have the right to lodge a complaint with the State Inspectorate for Control in the Field of Informatization and Telecommunications of the Republic of Uzbekistan ("Uzkomnazorat") or your local data protection authority if you believe your rights have been violated.

11.9 Exercising Your Rights

To exercise any of these rights, please contact us at John@cjonhk.com. We will respond to your request within thirty (30) days. We may require proof of identity before processing your request.

11.10 How to Delete Your Account and Data

You can delete your account and all associated personal data at any time:

• In-App: Go to Profile → Delete Account and follow the instructions. This will permanently delete your account, VIN query history, and all personal information from our servers within 30 days.
• By Email: Send an email to John@cjonhk.com from the email address associated with your account with the subject "Account Deletion Request." We will process your request within 30 days and send you a confirmation once completed.

Note: Contributed Data (repair tips, parts information) that you have shared with the community will be anonymized — your personal attribution will be removed, but the technical content may remain in the shared knowledge base to preserve its value for other users.

12. Third-Party Data Acknowledgment

12.1 VIN and Vehicle Data

The VIN decoding, EPC, and OE data you receive through the App is obtained from third-party data providers, public databases, and User/repair shop contributions. The Company does not guarantee the accuracy, completeness, or timeliness of any vehicle data, parts data, or repair information displayed in the App.

12.2 User Responsibility

You acknowledge that it is your responsibility to verify any data before relying on it for vehicle repairs, parts purchasing, diagnostics, or any other purpose that may affect vehicle safety, performance, or compliance.

12.3 Data of Other Individuals

If you submit Contributed Data that includes information about other individuals (e.g., customer vehicle data from a repair shop), you represent and warrant that you have obtained all necessary consents from those individuals for the collection, use, and sharing of their data as described in this Privacy Policy.

13. Children's Privacy

The App is not intended for use by children under the age of 18. We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child without verified parental consent, we will delete that data promptly. If you believe we have collected data from a child, please contact us at John@cjonhk.com.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will:

• Post the updated policy within the App
• Notify you via email or through an in-app notice at least thirty (30) days before the changes take effect
• Obtain your renewed consent where required by applicable law

Your continued use of the App after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. The "Last Updated" date at the top of this policy indicates when it was last revised.

15. Language

This Privacy Policy is published in English, Uzbek, Chinese, and Russian. In the event of any discrepancy between the versions, the Uzbek version shall prevail for Users in Uzbekistan, and the English version shall prevail for international Users.

16. Contact Us

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or our data practices, please contact us:

Data Protection Contact:

CJ TECH LLC

Tashkent, Uzbekistan

Email: John@cjonhk.com

We will acknowledge your inquiry within five (5) business days and provide a substantive response within thirty (30) days.

Regulatory Authority

If you believe your data protection rights have been violated, you may contact:

State Inspectorate for Control in the Field of Informatization and Telecommunications of the Republic of Uzbekistan ("Uzkomnazorat")

Tashkent, Uzbekistan (contact via https://www.mitc.uz)

Website: https://www.mitc.uz

This Privacy Policy was last updated on July 22, 2026.