Boneng Photovoltaic Personal-Information Protection and Privacy Policy

This policy applies only to photovoltaic products or services and related mobile apps, websites, WeChat Official Accounts, mini programs, and other channels operated by Shenzhen Boneng Photovoltaic Technology Co., Ltd. (Address: Room No.0801,C Block,Building -5,Huaqiang Creative Park,Guangming Street,Guangming District,China) and its subsidiaries, branches, or other related parties, whether existing or to be established from time to time (hereinafter referred to as or collectively referred to as "our," "us," "we," or "Boneng PV"). By clicking to accept the "Boneng Photovoltaic Energy Consulting Personal-Information Protection and Privacy Policy" (hereinafter referred to as "this Policy") online, this Policy constitutes the agreement between you and us. If you have any questions, comments, or suggestions, please contact us using the contact information in Section 10 of this Policy.

This Policy will help you understand the following:

I. How we collect and use your personal information

II. How we manage and protect your personal information

III. How we use cookies and similar technologies

IV. How we process the information of children

V. Legal basis for data processing

VI. Your rights

VII. How your personal information is transferred globally

VIII. Statement on third-party responsibility

IX. How we update this Policy

X. How to contact us

We are fully aware of the importance of personal information to you and will do our best to protect the security and reliability of your personal information. We are committed to maintaining your trust in us and protecting your personal information. At the same time, we promise that we will take corresponding security protection measures to protect your personal information in accordance with mature security standards in the industry.

Please read this Policy carefully to understand it before using our products and/or services, especially the content in bold.

I. How we collect and use your personal information

(1) How we collect your personal information

Boneng PV uses third-party servers from Alibaba Cloud to collect your personal information.

Personal information refers to various information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information. We may collect your personal information when you use Boneng PV's products and services or interact with us. The specific types of data collected will vary depending on the products and services you use and your interactions with us. You are not required to provide personal information to Boneng PV. However, in some cases, if you choose not to provide personal information, Boneng PV may not be able to provide you with relevant products or services, and respond to or solve the problems you encounter. Your personal information will be collected and used only for the purposes stated in this Policy. Personal information we may collect includes the following:

1. Information you provide to Boneng PV

(i) Account sign-up information. When you sign up for an account, we will ask you to provide corresponding personal information, including your name, account, password, email address, contact number, and organization name.

(ii) Personal contact information. When you contact us for purposes such as providing us with comments and suggestions or inquiring, participating in our online and offline activities, and subscribing to marketing materials, you may leave your contact information, including your name, company name, email address, and phone number.

(iii) Agent application information. When you apply to become an agent, we will ask you to provide corresponding company information, including your name, email address, organization name, country, state/province/region/city, detailed address, postal code, and contact number.

2. Information obtained when you interact with us or use our products and services

(i) Device and network information. We will collect information related to your device when you use Boneng PV's products and services, such as the device type, device name or model, device identifier, operating system type and version, browser type and version, screen resolution, language settings, IP address, Internet service provider, and other technical information that varies from product to product.

(ii) Interaction records. This information will be submitted directly to us by you when you use our website, products, or services, and interact with us. Examples are information requests you provide to us, including query information you enter or questions or information you provide to obtain customer service support, and records of your communication online or through phone calls, emails, and participation in online and offline activities.

(iii) Log information. When you use Boneng PV's products and services or view content provided by Boneng PV, we will automatically collect and store necessary log information, such as the time of each access to the service, the page path visited, the client IP address, and information about events (such as errors, crashes, reboots, and upgrades).

3. Information from third-party sources and public information

Where permitted by law, we will also obtain relevant data from public and commercial third parties or publicly available sources. For example, we purchase statistical data from other companies to support our services.

Boneng PV may also collect and use non-identifying data. Non-identifying data is data that cannot be used to identify an individual. For example, Boneng PV collects aggregate statistics such as website visits. Boneng PV collects this data to understand how users use its website, products, and services. This allows us to improve our services and better meet customer needs. We may collect, use, process, transfer, or disclose non-identifying data for other purposes at our sole discretion. We will try our best to isolate your personal information from your non-identifying data and use both types of data separately. If personal information is mixed with non-identifying data, it will still be treated as personal information.

(2) How we use your personal information

We may use your personal information for the following purposes:

(i) Creating an account. Customers interested in Boneng PV's products and services can create a Boneng PV account. This account can provide identity authentication and permission management when you use Boneng PV's products and services to protect the security of products and services; and allows us to contact you to send you important notifications and other notices. To create an account, we will collect the personal information you provide to us, including the name, account, password, email address, contact number, country or region, and detailed address you enter.

(ii) Responding to your interaction requests. When you visit our website, participate in online or offline activities, request changes, or request information (such as the marketing materials of products or services, white papers, and subscriptions to e-magazines), and contact us for any questions or product information (such as requests for technical support, providing us with comments or suggestions, and inquiring), we will collect the following information from you:

(iii) Recommending relevant content, products, or services for you. With your consent, we may send you information about products and services that may be of interest to you; invite you to participate in Boneng PV's activities (including promotional activities), market research, or satisfaction surveys; or provide you with personalized content and services when you visit online platforms such as websites and apps. We will collect the following information from you:

If you do not want to receive such information, you can unsubscribe at any time according to the methods provided in text messages or other methods provided by us.

(iv) Other circumstances: troubleshooting errors where you choose to send us error details; protecting the security of our products, services, and customers or users, to implement and improve our loss-prevention and anti-fraud programs; complying with and enforcing applicable legal requirements, relevant industry standards, or our policy.

II.  How we manage and protect your personal information

(1) Sharing

We will not share your personal information with any company, organization, or individual other than Shenzhen Boneng Photovoltaic Technology Co., Ltd. and the financial company responsible for part of the business (if any) and their affiliates, except for the following circumstances. We will share your personal information only for legal, legitimate, necessary, specific, and clear purposes, and we will share only the personal information necessary to provide services.

1. We may share your personal information with your authorization and consent. We will inform you of the purpose of sharing your personal information, the types of data recipients, and possible consequences, and obtain your authorization and consent.

2. We may share your personal information externally in accordance with laws and regulations and litigation and dispute-resolution needs, or as required by administrative and judicial authorities in accordance with the law.

3. To the extent permitted by laws and regulations, we may share your personal information where it is necessary to protect the interests, property, or safety of Boneng PV, our affiliates or partners, you or other users, or the public from harm.

4. Please click here to view a directory of third-party SDKs integrated with our products, to learn about third-party SDKs that may obtain your information, the identities of the relevant service providers, the scope of your information they collect or obtain through us, and their purposes of use. We will conduct technical inspections and behavioral audits on such partners or service providers from time to time, and require them to follow legal agreements on cooperation to ensure to the greatest extent that they collect and use data in compliance with laws, regulations, and agreements.

(2) Storage

1. Storage location: Personal information that is collected by us and generated in the EU will be stored within the EU. If we do need to provide your personal information to overseas institutions due to business needs, we will do so in accordance with relevant laws and regulations and relevant regulations of industry authorities, and obtain your authorization and consent.

2. Storage period: We will retain your personal information only for the period necessary to achieve the purposes stated in this Policy unless there are mandatory retention requirements by law. We mainly refer to the following standards to determine the storage period of personal information, whichever is longer:

(i) fulfillment of the business functions of the products and/or services you agreed to use;

(ii) a longer retention period you agreed to;

(iii) whether we have any other special agreements with you on the retention period;

(iv) whether a longer period is required or stipulated by law and regulation. For example, since the law stipulates a statute-of-limitation period, in order to deal with possible future disputes, we may need to retain some basic information during this period as evidence materials that may be used in the future.

(3) Public disclosure

Generally, Boneng PV will not disclose your personal information externally, except in the following scenarios:

1. In cases where certain services are provided by Boneng PV's authorized partners, Boneng PV will share your personal information with such partners as described in this Policy. For example, if we entrust a partner with providing services such as handling hotlines, sending emails, and providing technical support on behalf of Boneng PV, we will require the partner to use your personal information only to provide services to you on behalf of Boneng PV.

2. We may disclose personal information among Boneng PV's affiliates. We will disclose your information within Boneng PV's affiliates only for specific, clear, and legitimate purposes, and will disclose only the information necessary to provide services.

3. Boneng PV may also disclose your personal information to relevant law enforcement agencies or other government agencies when required by applicable laws or in response to legal procedures. In some jurisdictions, if Boneng PV is involved in reorganizations, mergers, or bankruptcy and liquidation proceedings, your personal information may also be disclosed to parties to the transactions.

4. Boneng PV will also disclose your data where there is a reasonable need to do so, such as for contract performance and when we believe that disclosure is necessary and appropriate to prevent physical harm or property damage or to investigate possible or actual illegal conduct.

(4) Protection

1. We have used industry-standard security safeguards to protect the personal information you provide to prevent its unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonably practicable measures to protect your personal information. For example, we will use encryption technology to ensure data confidentiality; we will use trusted protection mechanisms to prevent malicious attacks on data; we will deploy access-control mechanisms to ensure that only authorized personnel can access personal information; we will organize training courses on security and privacy protection to enhance employees' awareness of the importance of protecting personal information.

2. If all or part of the business we provide ceases operations, we will notify you through announcements and other forms and, at the same time, stop the collection of your personal information by relevant products or services to protect the security of your personal information. If all or part of the business is interrupted due to various reasons such as technical failures, cyberattacks, natural disasters and accidents, and human factors, we will take emergency response and recovery measures to respond, restore services as soon as possible, and properly protect your personal information.

3. We will protect the security of your personal information in accordance with industry-wide evaluation and certification requirements for network security and privacy protection such as China's Cybersecurity Classified Protection Scheme and ISO 27001 certification standards for information-security protection.

4. We will take all reasonably practicable measures to ensure that irrelevant personal information is not collected.

5. Please understand that due to technical limitations and possible malicious attacks, unexpected circumstances that we cannot reasonably foresee, prevent, avoid, and control may occur. The Internet is not an absolutely secure environment. Please use complex passwords to help us protect the security of your account.

6. If a personal-information security incident occurs, we will promptly notify you of incident-related information through ways such as phone calls and push notifications, or publish announcements in a reasonable and effective manner in accordance with the requirements of laws and regulations. At the same time, we will also report the handling of the personal-information security incident in accordance with regulatory requirements.

7. Anti-fraud and transaction-security protection: In order to prevent fraud, verify user identities, prevent account theft or other fraudulent behavior, and maintain transaction security and the security of your property, we need to collect the network information of your device, including the IP address, MAC address, IMEI and Android ID, port, and other related device information to check whether your device has been stolen and detect unusual account activity. In addition, we will also verify your identity with third-party anti-fraud service providers to determine whether the user presents risk of fraud and obtain anti-fraud assessment reports.

III. How we use cookies and similar technologies

We may use cookies and similar technologies. The details of how we use them are as follows:

(1) Cookies

To ensure the normal operation of websites, we sometimes store small data files called cookies on your computer or mobile device. A cookie is a plain text file that a web server stores on your computer or mobile device. The contents of a cookie can be retrieved or read only by the server that created it. Each cookie is unique to your web browser or mobile app. A cookie usually contains an identifier, the site name, and some numbers and characters. With the help of cookies, websites can store data such as user preferences or items in shopping baskets.

Like with most websites or Internet service providers, enabling cookies allows Boneng PV to improve user experience. With the help of cookies, a website can remember a user's single visit (using session cookies) or multiple visits (using persistent cookies). Cookies enable websites to save settings such as language, font size, and other browsing preferences on your computer or mobile device. This means that users do not need to reconfigure their user preferences every time they visit. If a website does not use cookies, the website will treat a user as a new visitor every time the user opens the web page. For example, if you log in to a website and then go to another page, the website will not recognize you and you will be logged out again. Boneng PV will not use cookies for any purpose other than those stated in this Policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have a function to block cookies. However, if you do this, you will need to change your user settings yourself each time you visit our website. To learn more about changing your browser settings, please visit the following links:

Chrome: https://support.google.com/accounts/answer/32050?hl=en&co=GENIE.Platform%3DDesktop

Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Safari: https://support.apple.com/zh-cn/guide/safari/sfri11471/mac

Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/
(2) Web beacons and pixel tags

In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on websites. For example, an email sent to you by Boneng PV may contain a clickable URL that links to Boneng PV's website content. If you click this link, Boneng PV will track this click to help us understand your product and service preferences and improve customer service. A web beacon is typically a transparent image embedded into a website or an email. With the help of pixel tags in emails, we can know whether the emails have been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from Boneng PV's mailing list at any time.

Your use of our website means you agree to the use of cookies, web beacons, and pixel tags as described above.

(3) SSL or TLS encryption programs

For security reasons and to protect the transmission of confidential content (such as purchase orders or queries you submit to our website operator), this website uses Secure Sockets Layer (SSL) or Transport Layer Security (TLS) encryption programs. You can identify an encrypted connection by checking whether your browser's address line switches from "http://" to "https://" and whether there is a lock icon in the browser's address bar.

When SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties.

IV. How we process the information of children

Our products, website, and services are primarily intended for adults. Children may not create their own user accounts without the consent of their parents or guardians.

In case the personal information of children is collected with the consent of their parents, we will use or disclose this data only when it is permitted by law, explicitly agreed by their parents or guardians, or necessary to protect children.

Although local laws and customs define children differently, we consider anyone under the age of 14 to be a child.

If Boneng PV discovers that it has collected the personal information of children without first obtaining verifiable parental consent, it will seek to delete the relevant data as soon as possible.

V. Legal basis for data processing

If you have consented to the processing of your data, we will process your personal data in accordance with Article 6(1)(a) or Article 9(2)(a) of the General Data Protection Regulation (GDPR). If the data is a special category of data, the processing will be carried out in accordance with Article 9(1) of the GDPR.

If you have given your explicit consent to the transfer of personal data to third countries/regions, we will also process the data in accordance with Article 49(1)(a) of the GDPR.

If you have given us your consent to store cookies or to access information on your terminal device (such as the device fingerprint), the data will also be processed in accordance with Section 25(1) of the Telecommunications-Telemedia Data Protection Act (TTDSG). You may withdraw this consent at any time.

If your data is necessary for contract performance or carrying out pre-contractual measures, we will process your data in accordance with Article 6(1)(b) of the GDPR. In addition, if your data is necessary for the fulfillment of a legal obligation, we will process this data in accordance with Article 6(1)(c) of the GDPR. Among other things, we may process data based on our legitimate interests in accordance with Article 6(1)(f) of the GDPR.

VI. Your rights

As a website user, you have specific rights under the GDPR regarding the processing of personal data.

1. Right of access: In accordance with Article 15 of the GDPR, you have the right to request confirmation from us as to whether we are processing your personal data and, where that is the case, you also have the right to access this personal data and information.

2. Right of rectification and erasure: In accordance with Article 16 of the GDPR, you have the right to request that the controller promptly rectify inaccurate personal information concerning you and, if necessary, you also have the right to have incomplete personal information completed. At the same time, you also have the right to request that the controller promptly erase this data, where one of the grounds listed in Article 17 of the GDPR applies.

3. Right to restriction of processing: You have the right to restrict the processing of your data, where one of the circumstances listed in Article 18 of the GDPR applies.

4. Right to data portability: In accordance with Article 20 of the GDPR, you have the right to request to receive the personal data concerning you in a structured, commonly used, and machine-readable form, and to request the transmission of this data to a third party.

5. Right to object: If your data is processed in accordance with Article 6(1)(e) or 6(1)(f) of the GDPR, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data. This section also applies to any collection of data based on these provisions. If you object, we will no longer process your personal data unless we have compelling grounds for protection for the processing which outweigh your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal rights (objection in accordance with Article 21(1) of the GDPR). If your personal data is processed for direct advertising purposes, you have the right to object at any time to the processing of your personal data for such advertising purposes. This also applies to the collection of data in connection with such direct advertising. If you object, your personal data will no longer be used for direct advertising purposes (objection in accordance with Article 21(2) GDPR).

6. Right to lodge a complaint: In accordance with Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your data has infringed the GDPR. You may exercise your right to lodge a complaint in particular in the Member State of your place of residence, place of work, or the place of the alleged infringement.

VII. How your personal information is transferred globally

Boneng PV is a multinational company, which means that your personal information collected by Boneng PV may be processed in the country/region where you use products or services and in other countries/regions in which Boneng PV or its affiliates, subsidiaries, service providers, and business partners have establishments, or accessed from these countries/regions. Data protection laws in these countries/regions may differ. In such cases, Boneng PV will take steps to ensure that the data we collect is processed in accordance with the requirements of this Policy and applicable laws. These cases include when the personal information of data subjects located in the EU is transferred to a country or region that is not recognized by the EU as having the same level of data protection, in which cases Boneng PV will use various legal mechanisms, such as signing standard contractual clauses (SCCs) approved by the European Commission or requesting your consent to cross-border transfer of personal information, or implement security measures such as data anonymization before cross-border data transfer. You can obtain a copy of the EU SCCs by clicking here https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en Personal information collected and processed by us in our operations within the EU will be stored within the EU.

VIII. Statement on third-party responsibility

To ensure a smooth browsing experience, you may receive content or web links from third parties external to Boneng PV and its partners (hereinafter referred to as "Third Parties"). Boneng PV has no control over such Third Parties, and you can choose whether to access the links, content, products, and services provided by Third Parties.

Boneng PV has no control over the privacy and data-protection policies of Third Parties, and such Third Parties are not bound by this Policy. Before submitting personal information to Third Parties, please refer to the privacy policies of those third parties. If you find that web pages created by these Third Parties or applications developed by Third Parties are risky, we recommend that you promptly terminate the relevant operations to protect your legitimate rights and interests.

IX. How we update this Policy

Our policy may change from time to time.

We will not reduce your rights under this Policy without your explicit consent. We will post any changes to this Policy on this page. If the changes are significant, we will also provide more prominent notices. (For certain services, we may contact you through ways such as pop-up windows, system push notifications, and text messages, to explain the specific policy changes.)

Significant changes referred to in this Policy include, but are not limited to:

1. significant changes in our service model, such as the purposes of processing personal information, the type of personal information processed, and how we use personal information;

2. significant changes in control and other aspects, such as changes in owners caused by mergers, acquisitions, and reorganizations;

3. changes in the main objects to whom personal information is shared, transferred, or publicly disclosed;

4. significant changes in your rights to participate in the processing of personal information and how you exercise them;

5. changes in our responsible departments, contact information, and complaint channels for handling personal-information security;

6. indications of high risk in impact assessment reports on personal-information security.

We will also archive prior versions of this Policy for your review.

X. How to contact us

If you need to contact Boneng's data protection officer about any privacy complaints or questions, please email us: inquiry@solavita-pv.com. Normally, we will respond within fifteen business days. If you are not satisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you can also lodge a complaint or report with relevant regulatory authorities.