Sungrow New Energy Personal Information Authorization and Protection Policy

Version Update Date: January 1, 2024

Before using our services, we strongly recommend that you read and fully understand this Policy. If you do not agree with its contents, please do not log in, register, or use the services.

Important information regarding personal sensitive data and user rights has been highlighted in bold for your attention. If you are under the age of 18, please read this Policy under the guidance of your guardian and ensure that your guardian’s consent is obtained before using the Lead Forms products and/or services.

By starting to use the Lead Forms products or services, you are deemed to have accepted and agreed to be bound by this Policy.

This Lead Capture Form is a tool used by Sungrow New Energy Development Co., Ltd. in various scenarios, including third-party advertising campaigns (e.g., Douyin, WeChat Moments, Kuaishou, and other industry-specific media platforms), offline event QR code posters, the “Sungrow Life Hub” mini-program, and the “Sungrow Cooperative” mini-program.

The primary purpose of this form is to collect your information in order to provide services such as telephone consultation and on-site surveys.

To explain how your personal information is collected, used, stored, and what rights you have, we set out the following key points:

(1) Personal information refers to all kinds of information, recorded electronically or otherwise, that relates to an identified or identifiable natural person, excluding anonymized data. This includes, but is not limited to, name, date of birth, ID number, biometric information, address, contact details, communication records and content, account credentials, property information, credit information, location data, accommodation information, health and physiological information, and transaction information. You warrant that the personal information you provide is true, lawful, complete, and valid.

(2) We will clearly explain the categories of personal information we collect and their corresponding purposes, so that you can understand what data is collected, why it is collected, and how it is obtained for each specific function.

(3) When using certain features, we will collect sensitive personal information only after obtaining your consent. Typical scenarios include:

A. When booking online services or on-site survey services, you may be required to provide your name, unified social credit code (for enterprises), mobile number, and region/address information.
B. When applying to become a Sungrow New Energy distributor for residential PV, C&I distributed PV, energy storage (ESS), or EV charging stations, you may be required to provide your name, unified social credit code, mobile number, and region/address information.

Unless required by applicable laws and regulations, refusal to provide such information will only prevent you from using specific features but will not affect your use of other functions of the Lead Capture Form.

(4) When SMS services are triggered, in order to ensure successful message delivery, your mobile number may be shared with third-party telecom operators (China Telecom, China Unicom, China Mobile). We assess such data sharing activities in accordance with this Policy and confirm that the above third-party providers are legally authorized to provide verification services.

(5) Currently, the Lead Capture Form does not actively obtain personal information from third parties outside Sungrow New Energy Development Co., Ltd.. If in the future business development requires indirect collection from third parties, we will clearly inform you of the source, type, and scope of use of your personal information in advance and obtain your consent if the processing exceeds the original authorized scope. We strictly comply with applicable laws and regulations and do not obtain personal information through illegal channels.

For more detailed information, please refer to the following sections:

1. Definitions and Interpretation

2. How We Collect and Use Your Personal Information

3. How We Share, Transfer, and Publicly Disclose Your Personal Information

4. How We Protect Your Personal Information

5. How We Store Your Personal Information

6. How You Can Exercise Your Rights Over Your Personal Information

7. How We Protect Minors’ Personal Information

8. How We Update This Policy

9. How to Contact Us

10. Service Description for Recommended C&I Rooftop Solutions

11. Miscellaneous

1、Definitions and Interpretation

1. Personal Information You Actively Provide When Using Our Products and/or Services

1.1 Basic Service Requirements

To provide our core business functions, you are required to provide certain personal information. If you refuse to provide such information, we may not be able to deliver the corresponding services to you. Please note that if you provide personal information of others, you must ensure that you have obtained their consent.

(1) When using appointment services (residential PV business: online booking / offline on-site survey), you are required to provide your real name, mobile number, province/city/district (county), detailed address, property ownership type, and housing type. This information is collected to facilitate online or offline service delivery. Your mobile number will be used as the primary contact method.

(2) When using appointment services (C&I distributed PV business: online booking / offline on-site survey), you are required to provide your real name, unified social credit code (for enterprises), mobile number, province/city/district (county), detailed address, industry type, company size, company nature, and intended cooperation model. This information is collected to provide relevant services efficiently. Your mobile number will serve as the primary contact method.

(3) When applying for cooperation (becoming a residential PV distributor, C&I distributed PV distributor, or EV charging station distributor), you are required to provide your real name, unified social credit code, mobile number, province/city/district (county), detailed address, PV industry experience, and existing PV brands you have cooperated with. This information is collected to evaluate your qualification for cooperation. Your mobile number will serve as the primary contact method.

(4) When registering as a partner:

If you are an individual user, you are required to provide your real name, gender, mobile number, province/city/district (county), and ID number.

If you are a corporate user, you are required to provide your unified social credit code/tax registration number/organization code, entity name, province/city/district (county), contact person’s name, and contact mobile number.

This information is collected for identity verification purposes. The mobile number (and contact person details for corporate users) will serve as the primary contact method.

2. Information We Collect Automatically During Service Use

Subject to applicable laws and regulations, and in order to ensure account security, improve service quality, and optimize user experience, we may collect and use the following information generated during your use of the Lead Capture Form services:

When you use the services, we may collect system information, login IP address, and service log information (such as profile updates, login activities, clicks, browsing, and sharing actions). This information is used to analyze usage of the services, calculate or distribute incentives based on activity logs, and optimize system performance to provide you with a better user experience.

Please note that our products and services are continuously evolving. If a specific feature or service is not covered in the above description, we will inform you of the scope, purpose, and method of data collection through page prompts, interactive processes, or official announcements, and we will only collect such information after obtaining your consent.

3、How We Entrust the Processing of, Share, Transfer, and Publicly Disclose Your Personal Information

1 Entrusted Processing

To provide you with enhanced products and services, we may entrust certain partners to process your personal information on our behalf. We enter into strict data processing and confidentiality agreements with all entrusted parties, specifying the scope, purpose, duration, processing requirements, and responsibilities of each party. Entrusted processors are required to process your personal information solely in accordance with our instructions, this Policy, and applicable confidentiality and security requirements.

If you refuse to allow our service providers to collect the personal information necessary for delivering their services, you may be unable to access certain features or services provided through the Lead Capture Form.

2 Sharing

We do not share your personal information with any company, organization, or individual other than service providers supporting this product, except in the following circumstances:

1. With your explicit consent. We may share your personal information with third parties after obtaining your explicit consent.

2. As required by law. We may share your personal information where required by applicable laws and regulations, legal proceedings, or lawful requests from competent administrative or judicial authorities.

Whenever personal information is shared, Sungrow New Energy Development Co., Ltd. requires the recipient to enter into appropriate confidentiality agreements and to process the information in compliance with applicable laws, industry standards, this Policy, and our security requirements.

3 Transfer

We do not transfer your personal information to any company, organization, or individual, except under the following circumstances:

1. With your explicit consent;

2. Where required by applicable laws, legal procedures, or mandatory administrative or judicial requirements;

3. In connection with a merger, acquisition, bankruptcy, or similar corporate transaction. If such a transfer involves your personal information, we will require the new data controller to continue complying with this Policy. Otherwise, we will require the new controller to obtain your consent again where required by law.

4 Public Disclosure

We will publicly disclose your personal information only under the following circumstances:

1. With your explicit consent or at your direction;

2. Where disclosure is required by applicable laws, legal proceedings, litigation, or mandatory government requests;

3. Where necessary to investigate or address violations of applicable laws or the terms governing this product, or to protect the personal safety or property of users, affiliated companies, or the public, and where such disclosure is permitted by applicable laws or authorized by you.

5 Exceptions to Prior Consent

Under the following circumstances, your personal information may be processed without obtaining your prior consent for sharing, transfer, or public disclosure:

1. Where necessary to fulfill legal or regulatory obligations;

2. Where directly related to national security or national defense;

3. Where directly related to public security, public health, or significant public interests;

4. Where directly related to criminal investigations, prosecutions, judicial proceedings, or enforcement of judgments;

5. Where necessary to protect the vital interests, life, health, or property of you or others and obtaining your consent is impracticable;

6. Where the personal information has been voluntarily made public by you;

7. Where the personal information is obtained from lawfully public sources, such as official government disclosures or legitimate news reports.

Please note that, where personal information has been de-identified in accordance with applicable laws and the recipient cannot restore or re-identify the data subject, the processing of such information does not constitute the sharing, transfer, or public disclosure of personal information, and no additional notice or consent is required.

4、How We Protect Your Personal Information 

1 Personal Information Protection

We attach great importance to the protection of your privacy and personal information and implement reasonable security measures to safeguard it. Except as otherwise required by applicable laws and regulations or provided in this Policy, we will not disclose your personal information to third parties without your consent. We also adopt industry-standard encryption technologies for data storage and transmission to ensure the security of your personal information.

(1) We implement comprehensive administrative, technical, and organizational measures to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction.

(2) In accordance with applicable laws and regulations, we may collect your personal information without obtaining your prior consent under the following circumstances:

• To fulfill legal or regulatory obligations;

• Where related to national security or national defense;

• Where directly related to public security, public health, or significant public interests;

• Where directly related to criminal investigations, prosecutions, judicial proceedings, or enforcement of judgments;

• Where necessary to protect the vital interests, life, health, or property of you or others and obtaining your consent is impracticable;

• Where the personal information has been voluntarily disclosed by you;

• Where the personal information is obtained from lawful public sources, such as official government disclosures or legitimate news reports;

• Where necessary for entering into or performing a contract at your request;

• Where necessary to ensure the secure and stable operation of our products or services, including fault detection and troubleshooting;

• Other circumstances permitted by applicable laws and regulations.

2 Data Analysis

You acknowledge and agree that, provided individual users cannot be identified, Sungrow New Energy Development Co., Ltd. may perform technical analysis on aggregated user data. Only anonymized data generated from such analysis may be used for legitimate business purposes.

3 Data Security Measures

(1) We adopt security safeguards consistent with industry best practices, including administrative controls and technical measures, to prevent unauthorized access, use, modification, loss, or damage to your personal information. These measures include, but are not limited to, server firewalls, remote access whitelisting, periodic security assessments, and data backup. Access to personal information is restricted to employees and authorized partners of Sungrow New Energy Development Co., Ltd. on a need-to-know basis, supported by strict access controls, monitoring mechanisms, and confidentiality obligations. Any breach of these obligations may result in legal liability or termination of the relevant cooperation. We also provide regular security and privacy awareness training to our personnel.

(2) We take all reasonable and practicable measures to ensure that only personal information necessary for the purposes described in this Policy is collected. Your personal information will be retained only for as long as necessary to fulfill those purposes, unless a longer retention period is required or permitted by applicable law.

(3) Please note that the Internet is not an absolutely secure environment. Communications such as email, instant messaging, and other online communication methods may not be encrypted. We strongly recommend that you do not transmit sensitive personal information through these channels and that you use strong passwords to help protect your account.

(4) Although no Internet transmission or storage system can be guaranteed to be 100% secure, we will use commercially reasonable efforts to protect the information you provide. If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, disclosure, alteration, or destruction of your personal information, we will promptly take appropriate remedial actions to minimize the impact and notify you, where required, via email, SMS, telephone, push notification, or other appropriate means.

(5) In the event of a personal information security incident, we will notify you in accordance with applicable laws and regulations of the nature and impact of the incident, the measures taken or planned, recommendations for mitigating potential risks, and any available remedies. Where individual notification is impracticable, we will issue a public notice through appropriate channels. We will also report the incident to the competent regulatory authorities as required by law.

5、How We Store Your Personal Information

This product and/or service is intended for use only within Mainland China (for the purposes of this Policy, excluding the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan). In principle, personal information collected within the People's Republic of China is stored within the territory of the People's Republic of China and is not transferred across borders.

5.1 Data Storage Location

In accordance with applicable laws and regulations, the personal information we collect will be stored on servers operated by Sungrow New Energy Development Co., Ltd. within Mainland China.

Exceptions may apply in the following circumstances:

• Where otherwise required by applicable laws or regulations;

• Where you have provided your explicit consent;

• Where cross-border transfer is initiated by you, such as through international online transactions.

5.2 Data Retention Period

As a general principle, we retain your personal information only for the minimum period necessary to fulfill the purposes described in this Policy. Personal information used to identify you or record your activities will generally be retained until your account is deleted, unless a longer retention period is required or permitted by applicable law.

We may retain your personal information for a longer period where necessary to:

• Comply with applicable laws and regulations;

• Comply with court judgments, rulings, or other legal procedures;

• Comply with requests from competent government authorities or legally authorized organizations;

• Meet other legal or regulatory obligations reasonably believed to apply to Sungrow New Energy Development Co., Ltd.;

• Enforce applicable service agreements or this Policy, safeguard the public interest, or protect the legitimate rights, property, and safety of Sungrow New Energy, its customers, users, employees, or other parties.

Once you stop using Sungrow New Energy's products and services, we will cease collecting and using your personal information unless otherwise required by applicable laws or regulatory authorities.

If the Lead Capture Form or its related services are discontinued, we will notify you through appropriate means, including push notifications or public announcements, and within a reasonable period, delete or anonymize your personal information stored on our servers in accordance with applicable laws and regulations.

6、Your Rights Regarding Your Personal Information 

In accordance with applicable laws, regulations, and industry practices in China and other jurisdictions, you have the following rights regarding your personal information.

1 Right to Rectification

If you discover that any personal information we process is inaccurate or incomplete, you have the right to request its correction.

If you are unable to update your information through the available functions or webpages, or if you need to change your mobile number or that of your designated contact person, you may contact us using the details provided in Section 9 of this Policy.

2 Right to Deletion

You may request the deletion of your personal information by contacting us through the channels provided in Section 9 of this Policy.

You may request deletion where:

1. Our processing of your personal information violates applicable laws or regulations;

2. We collected or used your personal information without obtaining the required consent;

3. Our processing violates our agreement with you;

4. You no longer use our products or services or have deleted your account; or

5. We no longer provide the relevant products or services.

Where we grant your deletion request, we will also notify any third parties with whom we have shared your personal information and require them to delete it, unless otherwise required by law or where they have obtained your separate authorization.

3 Right to Withdraw Consent

You may withdraw your consent at any time by contacting us through the channels provided in Section 9 of this Policy.

Please note that, once your consent is withdrawn, we may no longer be able to provide the corresponding products or services that rely on such consent. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

4 How We Respond to Your Requests

We will implement appropriate technical and organizational measures to enable you to exercise your rights to access, correct, or delete your personal information. You may also submit requests through the official feedback or complaint channels of Sungrow New Energy.

To protect your account and personal information, we may require identity verification before processing your request. Individual users may be asked to provide their mobile number and SMS verification code. Corporate users may be required to provide the contact person's name, mobile number, and SMS verification code.

We will respond to your request within 15 business days. We generally do not charge a fee for reasonable requests. However, for repeated requests or requests that exceed reasonable limits, we may charge a reasonable administrative fee where permitted by law.

We reserve the right to refuse requests that are manifestly unfounded, repetitive, technically impracticable (such as requiring the development of new system capabilities or fundamental changes to existing processes), that would adversely affect the legitimate rights and interests of others, or that are otherwise unreasonable.

If you are unable to correct or delete your personal information, wish to request the correction or deletion of other personal information generated through your use of the Lead Capture Form, or believe that our processing of your personal information violates applicable laws or our commitments under this Policy, you may contact us through the official customer service channels of Sungrow New Energy Development Co., Ltd..

5 Circumstances Where We May Decline Your Request

We may be unable to respond to your request where:

• It is necessary to fulfill our legal or regulatory obligations;

• It is directly related to national security or national defense;

• It is directly related to public security, public health, or significant public interests;

• It is directly related to criminal investigations, prosecutions, judicial proceedings, or enforcement of judgments;

• We have sufficient evidence that the request is made in bad faith or constitutes an abuse of rights;

• It is necessary to protect the vital interests, life, health, or property of you or others where consent cannot reasonably be obtained;

• Responding to the request would seriously impair the legitimate rights and interests of other individuals or organizations; or

• The requested information involves trade secrets or other legally protected confidential information. 

7、How We Protect Minors' Personal Information

We attach great importance to the protection of minors' personal information.

1 Protection of Minors

We protect minors' personal information in accordance with applicable laws and regulations. Although the legal definition of a minor may vary by jurisdiction, for the purposes of this Policy, any individual under the age of 18 is considered a minor.

If you are a minor, you should read this Policy together with your parent or legal guardian and obtain their prior consent before registering for, accessing, or using the Lead Capture Form products or services.

If you are the parent or legal guardian of a minor and have any questions regarding the processing of the minor's personal information, please contact us using the details provided in Section 9 of this Policy.

2 Additional Protection for Children Under the Age of 14

For personal information relating to children under the age of 14, we implement additional safeguards as follows:

(1) Enhanced Protection Measures

In addition to complying with the provisions of this Policy applicable to all users, we process children's personal information in accordance with applicable laws and regulations, including the Provisions on the Cyber Protection of Children's Personal Information. We adhere to the principles of lawfulness, necessity, informed consent, purpose limitation, security, and lawful processing.

Children's personal information will be retained only for the period necessary to fulfill the stated purposes, after which it will be deleted or anonymized. We also maintain dedicated internal policies and designate responsible personnel for the protection of children's personal information.

(2) Collection of Children's Personal Information

Where you, as the parent or legal guardian, choose to use the Lead Capture Form products or services on behalf of a child, we may collect the child's personal information where necessary to provide the requested services.

Before collecting such information, we will obtain your authorization and clearly inform you of the purpose and intended use of the information. If you choose not to provide the required information, we may be unable to provide the relevant services.

As a parent or legal guardian, you are responsible for safeguarding the child's personal information and providing appropriate guidance and supervision when the child accesses or uses our products or services.

(3) Rights of Children and Their Guardians

Children and their parents or legal guardians have the right to access, correct, and request the deletion of the child's personal information at any time.

If you have any questions, suggestions, complaints, or requests regarding a child's personal information, please contact us using the contact details provided in Section 9 of this Policy. We will process your request in accordance with applicable laws and regulations.

If we become aware that we have collected a child's personal information without verifiable parental consent where such consent is required, we will take prompt steps to delete the relevant information.

8、How We Update This Policy

1. To provide you with better products and services, the Lead Capture Form and its related services may be updated from time to time. Accordingly, we may revise this Policy as necessary. Such revisions form an integral part of this Policy. However, without your explicit consent, we will not reduce the rights granted to you under this Policy.

2. After this Policy is updated, we will notify you through appropriate means, such as telephone calls, email, or other available communication channels, and remind you to review the latest version. If you do not agree with the updated Policy or object to any changes, you may discontinue using the Lead Capture Form products and services or request the deletion of the personal information you have submitted. Please note that your activities prior to deleting your personal information or discontinuing the services will remain subject to this Policy.

3. For material changes, we will provide more prominent notice, including but not limited to email, SMS, or prominent notices on the relevant webpages, explaining the specific changes to this Policy.

Material changes include, but are not limited to:

• Significant changes to our service model, including the purposes of processing personal information, the categories of personal information processed, or the methods of processing;

• Significant changes to our ownership structure, corporate organization, or business operations, including those resulting from business restructuring, mergers, acquisitions, or bankruptcy;

• Significant changes to the primary recipients of personal information shared, transferred, or publicly disclosed;

• Significant changes to your rights regarding personal information or the methods for exercising those rights;

• Changes to the department responsible for personal information protection, our contact information, or complaint channels;

• Circumstances where a personal information security impact assessment identifies high risks;

• Changes required to comply with newly enacted or amended laws, regulations, or government policies.

      4.The latest version of this Policy is available at any time by            clicking "Privacy Policy" at the bottom of the Lead Capture Form page.

9、How to Contact Us

To better protect your personal information, we have established a dedicated Cybersecurity and Personal Information Protection department.

If you have any questions, comments, or suggestions regarding this Policy or the processing of your personal information while using our products and services, please contact us through the following channels. We will generally respond within 15 days:

1. Company Name: Sungrow New Energy Development Co., Ltd.

2. Address: No. 2 Tianhu Road, High-Tech Industrial Development Zone, Hefei, Anhui Province, China

3. Tel: 400-958-5888

If you are not satisfied with our response, especially if you believe that our processing of your personal information has infringed upon your lawful rights and interests, and we fail to provide a satisfactory resolution after your feedback, you may file a complaint or report to the relevant regulatory authorities in accordance with applicable laws and regulations.

10、Project Information Feedback, Filing, and Protection Mechanism

When you successfully register as a Commercial & Industrial (C&I) Partner, you will become an authorized Sungrow C&I Partner. The following describes the policy governing the project rooftop information you subsequently submit.

1 Project Information Feedback

After you submit project information through the Lead Capture Form, we will arrange personnel to contact you within 7 business days to communicate project details and jointly discuss subsequent cooperation and implementation arrangements.

2 Project Execution and Protection

(1) First Filing Confirmation

When you submit project information, the Lead Capture Form will automatically perform duplicate checking to determine whether it is the first filing of the project.

If the project is confirmed as a first filing, we will grant you exclusive protection. The exclusive protection period will last for 2 months from the date you successfully submit the project information (hereinafter referred to as the “First Protection Period”).

(2) Project Data Collection

During the First Protection Period, you are required to cooperate with us to complete project data collection. The specific scope of work will be jointly confirmed in writing based on the actual project situation.

If you complete the required work on time, your project protection will be extended by 4 months starting from the end of the First Protection Period (hereinafter referred to as the “Second Protection Period”).

If you fail to complete the required work on time, we reserve the right to revoke your exclusive protection.

(3) On-site Survey

During the Second Protection Period, you are required to cooperate with us to complete the on-site survey of the project. The specific scope of work will be jointly confirmed in writing based on the actual project situation.

If you complete the required work on time, we will further discuss and proceed with subsequent commercial negotiations with you.

If you fail to complete the required work on time, we reserve the right to revoke your exclusive protection.

3 Cooperation Benefits

During the stages of project feedback, data collection, and on-site survey, we will communicate with you in a timely manner based on project progress. The cooperation benefit sharing scheme will be determined based on your specific contribution, cooperation content, and subsequent collaboration arrangements.

4 Commitment

We hereby commit that if we, without justified reason, infringe upon your exclusive protection rights (for example, if we directly contact the commercial and industrial property owner introduced by you for photovoltaic project investment cooperation without your involvement, or disclose your submitted project information to any third party without your consent), we will compensate you for your actual losses.

11、Any dispute arising out of or in connection with this Policy shall first be resolved through friendly consultation between both parties. If such consultation fails, you agree that the dispute shall be submitted to the People’s Court of Hefei High-Tech Industrial Development Zone, Anhui Province, China for litigation.If any provision of this Policy is held invalid or unenforceable by a court of competent jurisdiction, such provision shall be severed from this Policy and shall not affect the validity and enforceability of the remaining provisions. The remaining provisions shall continue in full force and effect.