AvatrLink Privacy Policy
Updated: August 10, 2025
1. Scope of Application of This Policy
This policy is intended to outline how SMART MOBILITY INTERNATIONAL COMMERCIAL AGENCIES L.L.C (hereinafter referred to as "AVATR", "we", or "us") uses your personal data when you enjoy the services provided via the AvatrLink app (hereinafter referred to as "AvatrLink") (collectively referred to as the "Services").
The AvatrLink app provides a range of features, each involving the processing of various types of personal information. These features include scanning the QR code for binding and connection, device management, vehicle status viewing, and vehicle control.
This policy further clarifies your data protection rights, including the right to object to specific data processing activities conducted by AVATR. For more information about your rights and how can you exercise these rights, please refer to the "Your Choices and Rights" section.
This Privacy Policy only applies to the services provided by us through the app and complements any other privacy policies or notices that might govern your interactions with AVATR.
If you disagree with this Policy, you should not use our AvatrLink services. If you have any questions or wish to exercise any of your rights under this Privacy Policy, please contact us using the following information:
Company: SMART MOBILITY INTERNATIONAL COMMERCIAL
Address: 2nd Floor, Star Tower, Corniche Street, Abu Dhabi, UAE, P.O. Box: 53580
Email of our Data Protection Officer ("DPO"): avatr@smartmobilityint.com
2. How We Use Your Personal Data
We will use your personal data for the purposes and on the lawful bases outlined below.
When processing your personal data for legitimate interests, we will conduct a balancing test to evaluate whether our interests are outweighed by your own interests and rights. You can get more information about this from us through the contact information at the end of this Policy.
You are required to provide your personal data if necessary for the execution of a contract under which you are a party or to comply with legal obligations. We will obtain your information necessary for us to provide you with our services. In other circumstances, you may opt not to provide the personal data we request. However, if such information is essential to implement the related service, refusal to provide your personal data may prevent you from using the service or some features of the service properly.
2.1 Scan the QR Code for Binding and Connection
To assist you and your rear passengers in quickly establishing a connection between the tablets and the IVI system, we provide a QR code for fast connection. You may simply use a mobile tablet to scan the QR code displayed on the central control panel and allow the permissions as prompted. After that, the connection will be successfully established. If you have allowed the permissions before, this step will be omitted. Once Wi-Fi and Bluetooth are turned on, AvatrLink will establish the connection automatically. We will record the time of your consent to our Privacy Policy, and use your VIN and the consent timestamp.
2.2 Device Management
To facilitate the management of connected tablet devices, after successful connection, we will obtain the model information of the connected tablet. You can also disallow the permissions for any previously authorized device in Device Management. Vehicle status viewing
To display the latest status of your vehicle on the tablet, we will collect vehicle status data, including your vehicle's VIN, in-vehicle temperature, rear-row A/C settings, air volume control, air quality information, temperature control information, fragrance status, rear seat ventilation settings, rear seat temperature status, seat position adjustments, and ambient light information.
2.3 Vehicle Control
To help us offer you convenient vehicle services, you can use the AvatrLink app to control rear-row functions such as adjusting A/C, seats, fragrance, and ambient lights. Additionally, you also can manage the rear entertainment screen via the central control panel. When using this function, we will collect your vehicle's VIN, in-vehicle temperature, rear-row A/C settings, air volume control, air quality information, temperature control information, fragrance status, rear seat ventilation settings, rear seat temperature status, seat position adjustments, and ambient light information.
3. How We Share Your Personal Data
We will not share your personal data referenced in the above Section 2 with our affiliates, processors, or any third parties.
We will share your personal data with our affiliates which partnered with us in providing you with vehicle services and related services.
We may share your personal data with government authorities or law enforcement agencies if required for the above purposes, by law, or to safeguard our legitimate interests under applicable legislation.
If our company is involved in a merger or acquisition, your information will be disclosed to our consultants and those of potential acquirers, and transferred to the company's new ownership.
4. How We Transfer Your Personal Data
We do not transfer your personal data used by the AvatrLink app, as mentioned under the above Section 2.
5. Your Choices and Rights
5.1 Rights of the Data Subject
You have certain legal rights regarding the personal data we process about you. These rights may differ depending on your jurisdiction and the nature of the data processing.
In most cases, you may have the following rights:
Withdraw a consent
Refuse to our processing of your data (Right to Object)
Request a copy of the data we maintain about you (Right to Access)
Request the transfer of your data to another entity (Right to Data Portability)
Request correction of your data or restriction of its processing (Right to Rectification and Right to Restriction of Processing)
Request the deletion of your data (Right to Erasure): To exercise this right, you can register your account via Personal Center > Account and Security > Delete Account in the app.
As mentioned above, these rights are not absolute. In some circumstances, data protection laws may impose limits on their applicability. If your request falls under this category, we will explain to you why we cannot fulfill your request.
We seriously consider all requests regarding the above rights and respond within a reasonable timeframe, ensuring compliance with applicable laws. Please note, however, that in certain circumstances, the above rights may be subject to limitations. If exceptions are applicable, we will inform you when responding to your request. Before processing any request you submit, we may require you to provide necessary information for identify authentication.
If you believe we are not complying with any applicable data protection law, you have the right to file a complaint with your local data protection authority. The competent data protection authority depends on the country or region where you reside.
6. How Long We Retain Your Personal Data
We will only retain your personal data as long as we are providing you with our services, and during the period necessary for the purpose of personal data processing or required by laws and regulations.
If you withdraw your previous consent for data processing, we will ensure that measures are taken as soon as possible after receiving your withdrawal request (so that we can fulfill your request) to discontinue any use of your personal data.
7. Update to This Privacy Policy
We reserve the right to update this Privacy Policy at any time and will provide you with a new version every time major changes are made. We may also notify you by other means from time to time about the processing of your personal information.
8. Contact Us
Should you have any questions or concerns about the processing of your personal data, or if you wish to exercise any of your rights, please contact us. The contact details are as follows:
Company: SMART MOBILITY INTERNATIONAL COMMERCIAL AGENCIES L.L.C
Address: 2nd Floor, Star Tower, Corniche Street, Abu Dhabi, UAE, P.O. Box: 53580
Email of our Data Protection Officer ("DPO"): avatr@smartmobilityint.com