We are SUNGROW USA CORPORATION, with registered offices in 1209 Orange Street in the City of Wilmington, County of New Castle, Delaware, 19801 , with the registered business objective of marketing and selling products in the field of renewable energies.

Personal information means any information relating to an identified or identifiable natural person (“Data Subject”). As the Controller in the sense of the GDPR, we collect personal information for the provision of SUNGROW Website services. Below you can find the categories of personal information that we collect and information on how we use and process such data:

2.1. Personal information you provide

2.1.1. 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.

2.1.2. We collect personal information 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 information: 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 information from customer service emails to address your inquiries and manage your service requests.

2.2. Personal information we collect automatically

2.2.1. 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 information for specific purposes and process only the personal information 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 information 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.

6.1. Service Providers and Contractors

We engage third-party service providers (such as hosting providers, IT and maintenance support providers, customer support, marketing, and survey services providers) to perform services on our behalf. These entities are restricted from using your personal information for any purpose other than providing their contracted services. The are subject to contractual obligations to maintain the confidentiality and security of your information and process it only on our instructions, in compliance with applicable US data protection laws, including the California Consumer Privacy Act (CCPA) and other state privacy regulations.

6.2. Government authorities

Personal information 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 federal and state laws and whilst protecting your personal information.

As a rule, we store and process your personal information within the United States. However, to provide our services and for the purposes described in this privacy policy, your information may be processed by our service providers and partners located in other countries. When we transfer your personal information outside the US, we implement reasonable and appropriate contractual safeguards with the recipients to ensure a comparable level of privacy protection and security as required under applicable US federal and state laws, including the CCPA and other state privacy acts. We require our service providers and partners to protect your information and restrict them from using it for any purpose other than those explicit specified in our agreements, in line with our own security standards.

We adhere to the regulations established by Executive Order (EO) 14117. We do not knowingly engage in prohibited data transactions, such as certain data brokerage activities, with covered persons or countries of concern. For any potentially restricted transactions (e.g., involving certain vendor or employment agreements), we implement robust data compliance programs and security measures, as required by the DOJ and the Cybersecurity & Infrastructure Security Agency (CISA) security requirements, including due diligence, audits, and specific contractual clauses to prevent unauthorized access.

You can obtain more information about our data transfer practices by contacting us using the details provided in our “Contact us” section.

Sungrow attaches great importance to the security of your personal information 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 information during transmission. When we store your personal information, 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 information, we have conveyed to the whole SUNGROW Website team the applicable privacy and security and strictly implement privacy protection measures within the team.

Under applicable privacy and data protection laws, you have certain rights regarding the personal information we process about you. You can review Your U.S. State Privacy Rights to learn more about your specific rights. To exercise these rights, please contact our privacy officer at infosec@sungrowpower.com. We will acknowledge receipt of your request within 10 business days and may verify your identity as needed to protect your personal information. We will then process your request within 45 days, in accordance with legal requirements. While we strive to honor all valid requests, please note that certain legal or official obligations may prevent us from fulfilling specific requests in some circumstances.

9.1. 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.

9.2. 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.

9.3. Addressing Concerns and Filing Complaints

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

If your concerns remain unresolved after contacting us directly, residents of the United States have the option to contact federal or state consumer protection authorities. While there is no single national data protection authority like those in the EU, oversight is shared across various bodies:

● Federal Oversight: You can file a complaint with the Federal Trade Commission (FTC)regarding general unfair or deceptive business practices.

● State Oversight: You may also lodge a complaint with the Attorney General in your state of residence. For example, California residents can file a complaint with the California Attorney General's Office or the California Privacy Protection Agency (CPPA). Residents of other states with comprehensive privacy laws (e.g., Virginia, Colorado, Connecticut, Utah) can find relevant contact information on their state's official website.

Finally, please note that where we require personal information 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 information 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 information, 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 information of Minors. Sungrow does not knowingly collect or store any personal information of Minors. If we learn that personal information 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 of our privacy officer at infosec@sungrowpower.com.