Personal data means any information relating to an identified or identifiable natural person ("Data Subject"). Depending on your location and applicable law, the entity responsible for processing your data (the Data Controller) is the relevant Sungrow entity as listed in the controller list. We collect personal data for the provision of SUNGROW Website services. Below you can find the categories of personal data that we collect and information on how we use and process such data:

1.1. Personal data you provide

1.1.1. When you make personalized settings, you may provide data according to your preferences in connection with the personalization of SUNGROW Website (e.g. track behavioral trajectories, analyze website traffic and usage behavior, optimize our advertising efforts). We may use cookies to achieve this purpose. You can find more detailed information through our Cookie Policy contained in Section 4 of this privacy policy.

1.1.2. We collect personal data directly from you through the following methods when you interact with the SUNGROW Website:

● Account Registration: Data provided when you register for a user account on the website.

● Form Submissions: Data provided by you when completing contact forms, registration forms (e.g., for events), lead generation forms, or event questionnaires.

● Marketing Preferences: When you actively provide consent to receive marketing communications from us.

● Phone Calls: We record phone calls with our customer service to process your data as outlined in Section 3, 'Processing of Personal Data: Short Overview,' of this privacy policy. You have the option to not be recorded during a phone call. To proceed with an unrecorded call, please follow the instructions provided by the customer service representative. Please note that for unrecorded calls, we will not have a record of the conversation for future reference.

● Email: We process personal data from customer service emails to address your inquiries and manage your service requests.

1.2. Personal data we collect automatically

1.2.1. When you visit SUNGROW Website, your visit will be logged like for any other website. This means that initially, the following automatic logging data ("Log Data"), which your browser/device transmits to us. This data is only collected for data security purposes and for error analysis.

We process your personal data for specific purposes and process only the personal data relevant for achieving that purpose. Depending on our business relationship with you and the products and services that we are providing to you, we use collected personal data for the following purposes as assigned to the above description of the respective processing activity:

We may use cookies and similar technologies when you visit SUNGROW Website. Cookies are small text files that are stored by your browser and saved on your computer. Cookies and similar technologies are used to make the website more user-friendly.

For more detailed information on how we use cookies and similar technologies and how you can manage your settings and preferences regarding cookies, please refer to our Cookie Policy.

On our websites, we incorporate social plugins from popular social networks like LinkedIn, Instagram, Facebook, X and YouTube. Here’s how they work:

When you visit our websites, social media plugins are initially deactivated. This means no information is transmitted to the network operators. If you want to use any of these networks, simply click on the respective plugin to establish a direct connection to their servers.

If you're logged into your user account on a social network when you activate the plugin, the network can recognize your visit to our websites and associate it with your account. To prevent this, please log out of the network before activating the social plugin. The social network cannot detect your visits to other websites of ours unless you activate its social plugin on those sites too.

When you activate a social plugin, the network directly transfers the available content to your browser, which integrates it into our websites. During this process, data transfers controlled by the respective social network may occur. Your connection to a social network, the data transfers between the network and your system, and your interactions on the platform are governed solely by the network’s data protection provisions.

Please note that our website may feature links to external websites beyond our control, and this Privacy Policy does not apply to them. If you access these websites through the provided links, the operators of those websites may collect information from you according to their own privacy policies, which may differ from ours.

5.1. Third-party service providers

We may share your personal data with third-party service providers (such as hosting providers, IT and maintenance support providers, customer support, marketing, and survey services providers) strictly for the purpose of providing and maintaining our services. We engage these providers under written data processing agreements or binding contracts that require them to process your data only on our specific instructions, maintain robust security standards, uphold confidentiality obligations, and adhere to applicable data protection laws. These agreements also typically restrict the ability of providers to subcontract your data without our prior approval. We regularly monitor these providers to ensure ongoing compliance with data privacy principles.

5.2. Government authorities

Personal data may further be shared with government authorities and/or law enforcement officials if required by law or a court order or if required for the legal protection of our legitimate interests in compliance with applicable laws and whilst protecting your personal data.

As a rule, we process your personal data in the country or region where we operate or where our SUNGROW Website services are provided. However, in the context of delivering these services, your data may be transferred to countries outside of your home jurisdiction. This may occur, for instance, if one of our carefully selected and contractually bound service providers is in such a third country.

If we transfer your personal data across borders, we ensure that appropriate safeguards are in place to protect your data in compliance with applicable privacy laws. These transfers may occur:

1) To countries/territories that have been recognized by relevant authorities as providing an adequate level of data protection through an adequacy decision.

2) To other countries/territories where we have implemented safeguards such as the use of Standards Contractual Clauses (SCCs) approved by relevant authorities. In these cases, we evaluate the third country’s ability to protect personal data and implement necessary supplementary measures.

You can obtain copies of the applicable safeguards from us by sending a respective request to the contact details outlined in Section "Contact us" below.

Sungrow attaches great importance to the security of your personal data and has implemented appropriate technical and organizational measures. The SUNGROW Website will use encryption techniques such as transport layer security protocol (TLS) to protect your personal data during transmission. When we store your personal data, we use computer systems with limited access authority, and these systems are deployed in facilities protected by physical security measures.

To ensure the security of your personal data, we have conveyed to the whole SUNGROW Website team the applicable privacy and security and strictly implement privacy protection measures within the team.

You have specific rights designed to protect your personal data. The scope of these rights may vary depending on your country or region of residence and the applicable laws. If you would like to exercise any of the following rights, please contact us as described in Section "Contact us" below.

8.1.  Right of access (Right to know)

You may have the right to request access to the personal data we process about you and to receive a copy of that data.

8.2. Right to rectification (Right to correct)

You have the right to request that we update or correct inaccuracies in your personal data to ensure it is accurate and complete.

8.3. Right to erasure (Right to delete or be forgotten)

You have the right to request the deletion of your personal data from our records under certain conditions, such as:

1) The data is no longer necessary for the purpose for which it was collected;

2) We unlawfully processed your personal data;

3) You withdraw your consent for processing and we have no other legal basis to continue;

4) You successfully object to the data processing; or

5) Applicable law requires us to delete the personal data.

Account Cancellation:

You can request the cancellation and deletion of your account by contacting our service email at media@mkt.sungrowpower.com. Following your request for account cancellation, we will retain your account data for a limited period (e.g., 90 days) for internal analysis purposes, such as aggregated statistical reporting on user churn and website performance metrics, before initiating the final deletion process. This analysis will be conducted using pseudonymised or aggregated data where possible to protect your identity.

8.4. Right to restriction of processing

In certain circumstances defined by law, you may have the right to request us to limit or restrict the processing of your personal data, for instance, while the accuracy of your data is being verified or if you have objected to processing.

8.5. Right to data portability

Where applicable laws allow, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. You may also have the right to transmit that data to another data controller, provide the processing is based on consent or contractual necessity and is carried out by automated means.

8.6. Right to object

You have the right to object to us processing your personal data in certain circumstances, including processing for direct marketing purposes or processing based on legitimate interests. These rights may be limited in some situations – for example, where we can demonstrate that we have a compelling legal requirement or overriding legitimate ground to process your data, or if disclosing the information would reveal personal data about another person.

Unsubscribe from Marketing:

You can unsubscribe from our marketing email at any time by clicking the “Unsubscribe” link found at the bottom of every marketing email.

8.7.  Right to withdraw your consent

Where we rely on your consent as the legal basis for processing your personal data,  you have the right to withdraw that consent at any time. If you withdraw a consent, we are no longer allowed to continue the data processing which was the subject of the withdrawn consent in the future. This does not affect the legality of the processing carried out on the basis of the consent up to the point of withdrawal of the consent.

You may withdraw your consent easily, e.g. by contacting us via email at: infosec@sungrowpower.com. Withdrawing your consent is free of charge and does not affect your other rights under applicable privacy laws.

8.8. Complaints

If you have any concerns about how we process your data, you can contact us as described in Section "Contact us" below.

In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority responsible for your jurisdiction. This is typically the authority in the country or region of your habitual residence, place of work, or where the alleged infringement took place.

Finally, please note that where we require personal data to comply with legal obligations or to provide you the SUNGROW Website services, the provision of such data is mandatory: if such data is not provided, then we may not be able to manage our business relationship with you, or to meet legal obligations placed on us. In all other cases, provision of requested personal data is optional.

This data is retained only for the period necessary to resolve your inquiry or provide the requested information. Upon your request to delete your personal data, we will erase it, except where we have a legal obligation to retain it.

Sungrow will keep your information only as long as necessary for the duration of any relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this privacy policy.

Our SUNGROW Website services can only be used by persons of legal age and is not designed for access and use by persons under the legal age threshold (“Minors”). Therefore, Sungrow requires that users do not provide any personal data of Minors. Sungrow does not knowingly collect or store any personal data of Minors. If we learn that personal data of Minors has been collected, we will remove such data.

SUNGROW Website may update its privacy policy from time to time. If we make major changes to our privacy policy, we will issue announcements and the updated privacy policy on SUNGROW Website.

For any queries, feedback, complaints, and suggestions in relation to the use of SUNGROW Website, please contact us by using the following contact details: infosec@sungrowpower.com.