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1.Introduction
2.When and how do we process your personal data?
3.To whom do we disclose your personal data?
4.To which third countries do we transfer your data?
5.How do we protect your personal data?
6.What rights do you have regarding your personal data?
7.Contacts & About us
8.How do we update privacy policy?
Candidates & Partners
Last updated: 2026.04.06
1.Introduction
LINKTOUR (“we”, “us”) prioritizes and is committed to complying with applicable personal data protection laws and regulations, considering personal data protection a crucial component of the company’s business ethics and compliance management.

LINKTOUR believes that protecting personal data is essential for building and maintaining trust with customers, partners, and users. Therefore, we are committed to maintaining a high degree of transparency in processing the personal data you provide to us, or the personal data collected through your interactions with us, and ensuring that your personal data is appropriately protected.

This Privacy Notice aims to explain to you the circumstances and methods LINKTOUR collects, uses, and protects your personal data, and to inform you of your rights regarding personal data, as well as how you can control your personal data and protect your privacy.
2.When and how do we process your personal data?
· Candidates

Categories of Personal Data Name, e-mail, phone number, address, resume information, interview records, and background verification information where applicable and legal.
Purpose Assess qualifications and experience, manage the recruitment process, communicate potential employment opportunities with candidates, and, where applicable and permitted by law, verify the information provided by candidates as necessary.
Legal Basis Contract (Pre-contractual steps): Processing necessary steps before signing an employment contract, at the candidate's request.

Legitimate interests: Managing and implementing recruitment activities, screening suitable candidates, and conducting necessary verifications related to the position, where applicable.

Legal obligations: Complying with employment, labor, equal employment, or other regulatory requirements to the extent expressly required by applicable law.

Where background checks involve criminal record data, health data or other sensitive data, we will only process such data where permitted by applicable law and subject to additional safeguards.
Retention If a candidate is hired, the portions of their recruitment materials that need to be included in the personnel file will be retained in accordance with the applicable personnel file retention rules. For candidates who are not hired, their materials will generally be deleted after the recruitment process concludes; if we wish to retain a candidate’s information for future job opportunities, the candidate will be notified and their consent obtained where applicable. The retention period is usually no longer than two years from the date of the candidate’s last contact, unless applicable law requires a shorter or longer period.


· Partners

Categories of Personal Data Name, job title, company name, work email, work phone number, business communication information, contract signatory information, authorized representative information.
Purpose Establish and manage business relationships, fulfill contractual obligations (orders, delivery, after-sales support, etc.), communicate business matters and provide support, and comply with legal or regulatory requirements where applicable.

Any background checks will be limited to what is necessary and proportionate for the relevant role and will only be carried out where permitted by applicable law.
Legal Basis Contract (Pre-contractual steps): Steps taken at the request of individual partners before entering into a contract, or to fulfill existing contracts (distribution agreements, service agreements, etc.) with partners as necessary.

Legitimate interests: Used to manage partnerships, communications, business operations, risk control, and general compliance management.

Legal obligations: Processing to comply with accounting, tax, auditing, regulatory reporting, anti-fraud, export control, or other legal obligations, where applicable.
Retention We will retain the relevant personal data for the duration of the business relationship. After the termination of the business relationship, such data may continue to be retained, to the extent necessary for contract management, dispute resolution, auditing, taxation, accounting, regulatory compliance, or legal claims, for the applicable statutory retention periods, limitation periods, or periods of potential liability. Upon expiry of these periods, the data will be deleted or anonymized.


In certain circumstances, we may not collect your personal data directly from you. For example, in the case of candidates, we may obtain relevant information from recruitment platforms, headhunters, recruitment consultants, referees, publicly available professional social profiles, or other lawful sources; in the case of partner contacts, we may obtain relevant information from the partner company, publicly available business registration information, business introducers, or other lawful sources.

In some scenarios, providing certain personal data to us is necessary to advance the recruitment process, assess job suitability, enter into or perform contracts with you, conduct business communications, or comply with legal obligations. If you do not provide the required information, we may be unable to process your application, establish a business relationship with you, or perform the corresponding contract and compliance obligations. For non-essential information, you may choose whether or not to provide it.
3.To whom do we disclose your personal data?
We may disclose your personal data to the following categories of recipients as necessary to provide you with products and services and to fulfill our legal obligations:

• Authorized distributors and service providers for vehicle sales, delivery, after-sales service, and customer support;
• Our affiliates and subsidiaries for group management, business operations, and service provision;
• Cloud service providers, third-party service operators, and IT service providers for system operation, data storage, and technical support;
• Accountants, legal counsel, and other professional service providers for auditing, legal compliance, and professional consulting services;
• Local law enforcement agencies, regulatory bodies, or government departments, as required by law or by lawful request.

We disclose personal data only to the extent necessary to achieve the above purposes and require the relevant recipients to protect your personal data in accordance with applicable data protection laws.
4.To which third countries do we transfer your data?
Your personal data may be transferred to affiliated companies or service providers located in China. China is not currently recognized by the European Commission as a country providing an adequate level of protection. In such cases, to ensure data security, we have adopted the Standard Contractual Clauses (SCC) approved by the European Commission and/or other applicable legal transfer mechanisms, and implemented appropriate technical and organizational measures to ensure that your personal data is adequately protected during transfer and processing. You can contact us at dataprivacy@linktour-auto.com for a copy or summary of these safeguards.
5.How do we protect your personal data?
To protect your personal information from loss, theft, and unauthorised access, use, or disclosure, we have implemented technical, administrative, and physical security measures including encryption of transmitted and stored data, and access right concepts. We will continuously evaluate and improve our data protection measures to ensure that your personal data is properly protected throughout the entire processing.
6.What rights do you have regarding your personal data?
•Right of Access:You have the right to request confirmation from us regarding the processing of your personal data and to obtain an accessible copy of the data.

•Right to Rectification:If you find your personal data to be inaccurate or incomplete, you have the right to request correction or supplementation.

•Right to Erasure / Right to be Forgotten:In certain circumstances, you may request the deletion of your personal data, such as when the data is no longer necessary or you withdraw your consent.

•Right to Restriction of Processing:In certain circumstances, you may request restrictions on the processing of your data.

•Right to Data Portability:Where processing is based on your consent or a contract with you and is conducted automatically, you may request access to the data you have provided to us and, where technically feasible, its transmission to other controllers in a readable format.

•Right to Object:When we process your personal data based on legitimate interests, you have the right to object on grounds relevant to your specific circumstances. You always have the right to object to processing for direct marketing purposes.

•Withdrawal of Consent:If processing is based on your consent, you may withdraw your consent at any time without affecting the legality of the processing prior to the withdrawal.

•Right to Lodge a Complaint:You have the right to file a complaint with the relevant regulatory body regarding our processing of your personal data.

The above rights are not absolute and its application depends on the specific processing activities and applicable laws.

We do not carry out decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you, unless we specifically notify you otherwise in relation to a particular service.

If you wish to exercise any of your rights, please contact us by the email dataprivacy@linktour-auto.com. If you have any objections or complaints about the way we process your personal data, please let us know and we will try to help. You always have the right to lodge a complaint with the supervisory authority where you live, work or where you believe an infringement has taken place. You may find the contacts of the data protection authority on this webpage: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
7.Contacts & About us
Linktour Automobile Co., Ltd. (“LINKTOUR”) is the controller who processes your personal data as described in this notice. Depending on the relevant processing activity, certain LINKTOUR group entities may act either as separate controllers or jointly with LINKTOUR in determining the purposes and means of processing. Where LINKTOUR entities act as joint controllers, the essence of the relevant arrangement is available upon request. LINKTOUR is also the primary point of contact for data subjects that wish to exercise their rights and the main responsible party for providing information to data subjects. You may contact LINKTOUR as the primary contact point for all requests relating to this notice, including where processing is carried out jointly with another LINKTOUR entity.

Data Controller Primary Contact: Linktour Automobile Co., Ltd.
Unified Social Credit Code: 91130534689267660K
Company Address: No. 12, Huigong Avenue, Qinghe County, Xingtai City, Hebei Province, China.

Other Controllers: Linktour Automobile Co., Ltd. Hefei Branch
Unified Social Credit Code: 91340111MAE3085Y7P
Company Address: First floor, Building A4, Yungu Innovation Park, Xizang South Road, Yandun Street, Baohe District, Hefei, Anhui Province, China.

Other Controllers: Linktour Automobile SRL
Company Registration No.: 14461170962
Company Address: Milan Via Luca Signorelli 3 Cap 20514

LINKTOUR has appointed a Data Protection Officer who can be reached via e mail or via post as set out below:
E-mail address: dataprivacy@linktour-auto.com
Postal address: First floor, Building A4, Yungu Innovation Park, Xizang South Road, Yandun Street, Baohe District, Hefei, Anhui Province, China.
8.How do we update privacy policy?
We reserve the right to change this privacy notice from time to time. We will inform you of any changes by posting the updated privacy notice on our website (including clarification of updates). We encourage you to contact us if you have any questions about the privacy notice or about how we process your personal data.
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