Last Updated: [January] 2024
OVERVIEW
Sungrow USA Corporation (the “Firm”or “we”) recognizes its obligations in relation to the processing of your personal information under applicable data protection and privacy laws. This U.S. Privacy Policy and Notice or Business Representative (this “Notice”) provides information in relation to the collection, storage, access, use, and disclosure (“processing”) of your personal information by the Firm.
These links will take you to sections of this Notice explaining the following topics and, together with the information contained in the below sections, constitute our Notice of Collection:
l The categories of personal information we collect;
l The purposes for which personal information are collected and used;
l Whether we sell or share, as defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), personal information and a description of your right to opt out; and
l The criteria we use to determine how long to retain personal information.
This Notice applies only to U.S. resident individual representatives (including officers, managers, employees, personnel, contractors, and other representatives) of businesses with whom we interact in the context of a relationship that is not otherwise covered by a different Privacy Policy, including former, current, and prospective (i) clients, (ii) vendors and business partners. This Notice describes the rights you have over your personal information held by us.
1. WHAT PERSONAL INFORMATION THE FIRM COLLECT
The Firm may collect personal information about you, or a third party upon your instruction or permitted by the laws, from a number of sources, including, but not limited to:
l You provide personal information directly to us or authorize us to obtain it from a third party;
l A business provides information about its personnel (such as you) in connection with its relationship with us; or a company with which we may do business provides information about its personnel in connection with its due diligence or application to use our services;
l You communicate with us (e.g., by email, over the phone, by post, through our social media platforms, via your account profile or using any other method). We may record and monitor telephone calls and record the phone number from which the call was received;
l You visit our website or use our products or services;
l We request personal information from third parties, whom we use to check your identity and risk profile. In particular, we use fraud prevention agencies and providers of identity verification checks;
l We also search lists of government sanctions and run searches on representatives or other connected parties of the account holder or representative;
l We may receive personal information from regulators or law enforcement agencies about you. This could happen, for instance, when you apply for an account or seek to do business with us on behalf of a business, represent a corporate account holder or you make or receive a payment to or from a Sungrow account, or when we investigate fraud or other suspicious activity.
2. WHAT PERSONAL INFORMATION THE FIRM COLLECT
The following is a list of categories of personal information, along with some descriptions and examples, that we may collect or generate through each of the processes described above. Please note some data elements will fit into multiple categories.
Categories of Personal Information We May Collect | Examples of Personal Information We May Collect |
Personal Identifiers | Name, address, work addresses, phone numbers, work phone numbers, email, work email, social security number or other government-issued identification numbers (Optional, only when you are the individual suppliers/vendors) |
Professional or employment-related information | Employer name |
Sensitive Personal Information (note this is a subset of Personal Information) | Social security number or other government-issued identification numbers (Optional, only when you are the individual suppliers/vendors) |
Personal information does not include information that has been anonymized or aggregated so that it does not identify an individual.
3. THE PURPOSES FOR WHICH THE FIRM PROCESSES YOUR PERSONAL INFORMATION[ZL1]
The Firm may collect and use personal information for the following business purposes:
l Opening accounts: Opening an account for a business; reviewing and processing application and account opening documents; conducting background prudential and regulatory compliance checks.
l Offering and providing products and services to businesses: Administering, operating and managing the business relationship and/or accounts with us; providing our product and related services/aftersales services; understanding needs of companies with which we do business and offering services.
l Managing our relationship with businesses and connected parties: Compiling and utilizing internal reports and notes; managing files of companies with which we do business; conducting due diligence and risk reviews; managing any agreement or arrangement between us and a business.
l Managing our relationship with vendors and partners: Compiling and utilizing internal reports and notes; conducting due diligence and other risk reviews; and managing any agreement in place between us or with the vendor or partner.
l Promoting security: Authenticating identity to ensure the proper provision of our products and services; mitigating fraud and enhancing the security of the services and our websites.
l Communicating with you: Contacting and communicating with you in person, by telephone, mail, and email (including issuing statements and reports); keeping records of our communications and managing any complaints; providing support and responding to your questions, inquiries, or other requests.
l Carrying out operational and administrative functions: Carrying out billing-related and payment administration, staff and access management; preparing business reports and accounts; operating information technology systems, archiving and backing up data.
l Complying with legal obligations: Meeting and providing evidence that we comply with applicable law and regulations; complying with contractual obligations and relevant industry standards; fulfilling our legal and regulatory requirements.
l Managing our business and protecting and enforcing our rights: Assessing, monitoring, and managing financial, reputational, and other risk; conducting audits of our business; liaising with our regulator; protecting information used by our business; detecting, investigating, and preventing illegal activities or situations involving potential threats to the rights, property, or safety of any person; establishing, protecting, and exercising our legal rights and defending against legal claims.
l Engaging in risk management: Producing management information and reports to help us identify potential issues, and to ensure we are managing risk appropriately; assessing, monitoring and managing financial, reputational and other risks; conducting audits of our business; liaising with our regulators.
l Helping us to improve our products, services and operations: Developing new products and services; improving and personalizing existing products and services; analyzing preferences of businesses with which we currently and may interact, transactions and market trends; evaluating potential new products and services; evaluating the effectiveness of our marketing; testing new systems and upgrading existing systems.
l Other permitted purposes: We also use your personal information for any other purpose that we disclose at the time you provide, or when we collect, your information, and other purposes permitted by applicable law. We may occasionally ask you for specific consent to process your personal information. We may also use your information that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.
l
4. TO WHOM THE FIRM DISCLOSES YOUR PERSONAL INFORMATION
To the extent permitted by applicable law, in the past 12 months we may have disclosed the categories of your personal information listed in “WHAT PERSONAL INFORMATION THE FIRM COLLECT” to some or all of the following categories of recipients, for the purposes specified in this Notice:
l Within the Sungrow Group of companies, including Sungrow Power Supply Co., Ltd. for IT support and global management which will be conducted on an aggregate or anonymous basis within reasonable business efforts;[ZL2]
l To the Business you represent to help provide our products and services to, and manage our relationship with the business;
l To national and international regulatory, enforcement or exchange bodies or courts anywhere in the world or at their requests;
l As required by applicable law or regulations; and
l To any third party to whom you authorize us to disclose your personal information.
5. HOW THE FIRM PROTECTS YOUR PERSONAL INFORMATION
The Firm maintains appropriate physical, technical and procedural safeguards designed to protect any information that you provide to us from accidental or unauthorized loss, misuse, damage, modification, access, or disclosure.
6. HOW DOES THE FIRM RETAIN YOUR PERSONAL INFORMATION
The Firm retain personal information for varying time periods depending on our relationship with you and the status of that relationship. When determining how long to keep personal information, we take into account our legal and regulatory obligations and legitimate business interests (such as preventing fraud, responding to regulatory or supervisory inquiries, and establishing, exercising or defending legal claims, disputes or complaints).
7. NOTICE TO CALIFORNIA RESIDENTS
This section describes your rights under the CCPA and how to exercise those rights.
Description of Your Rights
Subject to certain exceptions and limitations, you have the following rights with respect to your personal information.
l Right to request access to personal information. You have the right to request the following information from us.
ü Specific pieces of personal information we have about you;
ü Categories of personal information we have collected about you;
ü Categories of sources from which the personal information is collected;
ü Categories of personal information sold, shared, or disclosed, if any;
ü Categories of third parties with whom the personal information was sold, shared, or disclosed, if any; and
ü The purpose(s) for collecting, sharing, or selling the personal information, if any.
l Right to delete personal information. You have the right to request that we delete the personal information we have collected about you.
l Right to correct inaccurate personal information. You have the right to request that we correct inaccurate personal information that we maintain about you.
l Right not to be discriminated against for exercising the rights identified above. You have the right not to be denied goods or services, charged different prices or rates for goods or services, or receive a differing level of quality of goods or services as a result of exercising the above rights.
Please note that we do not sell, share, and have not sold, shared your personal information. We do not use sensitive personal information in ways that the CCPA permits you to limit.[ZL3]
How to Submit a Request
You or your authorized agent may submit a California rights request by:
l Telephone: [ ]
l Email: [ ][ZL4]
l Web Form: [Contact Us – Privacy Inquiries]
In order to provide a response, we may ask that you provide clarifying or identifying information to verify your request. We will respond to authorized requests within the time-frame required by law. The above rights are subject to our ability to reasonably verify your identity and authority to make these requests.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents who make requests on behalf of individuals will be required to verify their authority to make the request by submitting written authorization from the individual.
Your California privacy rights are subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
We will not provide social security numbers or other specific pieces of personal information if the disclosure presents an unreasonable risk to the security of personal information, user accounts or our systems and network security.
8. CHANGES TO THIS NOTICE
We reserve the right to modify or supplement this Notice at any time. We encourage you to periodically review this Notice to learn about updates to our privacy practices. The Last Updated Date of this Notice, as stated above, indicates the last time this Notice was revised.
合规提示:
此处披露的B端联系人信息处理目的为基于项目事实以及常规行业实践进行撰写,贵司可基于公司实际情况进行调整。
合规提示:
目前关于阳光总部的披露尺度按照“总部作为Contractor”进行描述,但美国子公司与总部仍未签署相关协议约定数据处理关系,此处可结合后续总部与子公司合作关系和协议签署情况进行细化和调整。
合规提示:
基于目前阳光美国子公司个人信息跨境合规事实,主要涉及个人信息向总部传输用于运营管理等目的,不涉及CCPA相关个人信息销售、共享,也不涉及使用个人信息用于个人特征分析(即不涉及允许个人限制敏感个人信息的情况)。
此处披露尺度均基于前述跨境事实进行描述,如贵司在B端联系人全量场景下可能涉及其他数据处理活动落入上述范围的,需相应调整披露内容。
请贵司补充个人信息主体行权联系方式。