Spin to Win Promotion – Privacy Notice

TENWAYS TECHNOVATION INC. | U.S. website (us.tenways.com)

This notice explains how TENWAYS TECHNOVATION INC. (“Tenways”, “we”, “our”, or “us”) handles personal information collected through our “Spin to Win” promotion on our U.S. website (October 26 – November 30, 2026). It applies only to the promotion. Our Privacy Policy covers everything else we do with personal information.

1. Notice at Collection

What we collect. Your email address, your spin result and coupon code, the date and time of your spin, and your choice to receive marketing emails. We also collect your IP address, device and browser identifiers, and similar technical data to prevent duplicate or fraudulent entries. Under California law, these fall into the categories of identifiers, commercial information (coupon issued and redeemed), and internet or similar network activity.

Where it comes from. Directly from you, and automatically from your device and browser.

Why we collect it. To run the promotion and deliver your coupon; to send you Tenways marketing emails, which you opt in to when you spin; to prevent fraud and abuse; and to comply with legal obligations.

Sale and sharing. We do not sell or share the email address you give us through Spin to Win for cross-context behavioral advertising, and we use it only to deliver your coupon and send you Tenways marketing emails. Our website’s cookies and similar technologies may be considered a “sale” or “sharing” under California law. You can opt out on our Do Not Sell or Share My Personal Information page.

How long we keep your data. See Section 4.

More information. See our Privacy Policy.

2. Who We Share It With

We use email and promotion service providers to operate the promotion and send our emails. They process your information on our behalf under written contracts that restrict their use of it. We do not share the email addresses collected through Spin to Win with our subsidiaries or affiliates. We may disclose information to authorities where the law requires it.

3. Notice of Financial Incentive

Summary. If you sign up for Tenways marketing emails through our Spin to Win promotion on our U.S. website between October 26 and November 30, 2026, you receive a one-time coupon of $50, $70, $80, or $100 toward a complete Tenways e-bike. Every spin wins a coupon. Each of the four coupon amounts has an equal (25%) chance.

Material terms. One spin per person. The coupon applies to complete e-bike purchases only and expires on November 30, 2026, at 11:59 PM PST. Full terms are in the Promotion Terms.

Personal information involved. Your email address, IP address and device identifiers, and your spin result.

How to opt in. Enter your email address in the pop-up, tick the box agreeing to receive marketing emails, and click “Spin.”

Your right to withdraw. You can withdraw at any time using the unsubscribe link in any marketing email or by emailing support@tenways.com. Withdrawing does not affect the validity of a coupon you have already received.

Value of your information. We estimate that each active subscriber’s email address and related information is worth $21.03 USD per year to us. We calculate this using the Average Net Revenue Per User method: our total revenue from email marketing over the past 12 months, minus the annual cost of our email tool, divided by the total number of active subscribers. The coupon can be used only toward a complete e-bike purchase, so we incur its cost only if you buy. We set the coupon range of $50 to $100 based on our profit margins, our cost of acquiring customers, and market practice for comparable offers, which we consider reasonably related to the value of a subscriber to us.

4. How Long We Keep It

We keep your email address and spin records until you unsubscribe or ask us to delete them. If you have not opened or clicked any of our emails or made a purchase for 12 months, we will remove your email address from our marketing list. After you unsubscribe, we keep your email address on a suppression list so that we do not email you again. We keep records of your consent, spin result, and coupon for four (4) years after the promotion ends so that we can show that we complied with the law and respond to any claims. We keep records of privacy requests and our responses for at least 24 months.

5. Your Choices and Rights

• Unsubscribe. Use the link in any marketing email. We will stop sending marketing emails within 10 business days.

• Delete, know, or correct. You can ask us to delete your email address, tell you what personal information we hold about you, or correct it. Email support@tenways.com. After you unsubscribe or ask for deletion, we keep your email address on a suppression list so that we do not email you again.

• Opt out of sale and sharing. Visit our Do Not Sell or Share My Personal Information page or email support@tenways.com.

• How we handle requests. We will confirm receipt of your request within 10 business days and respond within 45 days of receiving it. If we need more time, we may extend this once by up to 45 more days, and we will tell you why. We will verify your identity before acting on a request to know, delete, or correct. You may use an authorized agent, and we may ask for proof of their authority. You do not need an account to make a request.

• No discrimination. We will not discriminate against you for exercising your privacy rights, other than by offering the incentive described in Section 3.

6. Contact Us

TENWAYS TECHNOVATION INC.

1400 Page Mill Road, Palo Alto, CA 94306

Email: support@tenways.com