Energy Storage Pro Privacy Policy

Updated: March 1, 2024

Effective: March 1, 2024

Zhejiang Inventronics New Energy Technology Co., Ltd (hereinafter referred to as "Inventronics New Energy", "we") takes your privacy very seriously. Therefore, in accordance with the current laws and regulations and related policies, we have formulated the "Energy Storage Pro Privacy Policy" (hereinafter referred to as the "Privacy Policy").When you use our cloud services through the websites dealer.inventronics-ne.cloud, monitor.inventronics-ne.cloud (hereinafter referred to as the "Websites") or through the Energy Storage Pro App (hereinafter referred to as the "Energy Storage Pro App",the "Website and App" collectively "Energy Storage Pro"), we as the data controller, will process your personal data in accordance with this Privacy Policy.This Privacy Policy also informs you how to exercise your rights as a data subject (including the right to object to our processing of certain data). For more information about your rights and how you can exercise them, please see the section "Your Rights and Choices" below.

In addition to this Privacy Policy, we have embedded data and privacy information in our products for certain features that require the use of your personal data. Before enabling these features, you can review the privacy information associated with these features in your Privacy Settings. When you use Energy Storage Pro Cloud related services, you may need to authorise Storable to process your personal data within the scope of this Privacy Policy. Please be sure to read and fully understand this Privacy Policy, and use the foregoing features only after confirming that you fully understand and agree to them.

If you have any questions, please contact us as described in the "Contact Us" section below.

1. Collection and use of personal data

Personal data is any information relating to an identified or identifiable natural person ("data subject"). The following provides some examples of the types of personal data we may collect and how we use such information.

2. What personal data we collect

(1) When you visit the Energy Storage Pro Cloud Service, your visit will be logged as it would be on any other website and application. Initially, we primarily record the following automatically logged data that your browser/device transmits to us ("Logged Data"):

IP address currently used by your device or router

Requested time zone, date and time (including time difference from Greenwich Mean Time (GMT))

Type, version and language of browser

Operating system of your device

The page you are viewing

Access status/HTTP status code

Name and size of the requested file

And, if applicable, the web address of the referenced web page.

We only collect this data for the purposes of data security, improvement of our website and error analysis.

(2) We may collect the following data when you register for an account with Energy Storage Pro: If you are an owner/end-user of a power station ("Owner") or a dealer/installer ("Installer"), we may collect your country, time zone, phone number, email, company name, and the code of the previous dealer/installer. Required data in the registration form will be marked with an asterisk and registration will not be possible if you do not provide the relevant data. Upon account creation, your account will be assigned a unique user ID ("User ID") created by Energy Storage Pro.

(3) When you use Energy Storage Pro, you may provide data relating to the plant you have added, such as the name of plant, the status of plant, the type of plant, the installed capacity, the power of plant, the azimuth, the inclination, the longitude and latitude of the plant, and other data. We will also process your photo when you upload it as an avatar to your account. We will process the data according to your personalised preferences for Energy Storage Pro(e.g. default language, theme, background colour).

(4) When you use the application (APP) to log in to Energy Storage Pro, we can additionally process your device virtual ID, which is the only ID that identifies your device and is automatically generated when you install the application, and will not be associated with your mobile phone number or mobile device hardware information. This ID is mainly used in the application to receive messages pushed by Energy Storage Pro, such as push messages for some plant alarms, and notifications of device offline messages. If you don't need to use the push service, you can click the reject button when the app authorises you, or find the settings of the Energy Storage App in your phone's settings and turn off the push settings.

(5) When you download an application, the required information is transmitted to the respective app shop, in particular the user name, e-mail address and your account name, the time of download and the assigned number of the personal device. Energy Storage Pro does not acquire and store this data and your data will be protected by the respective app shop.

(6) When you connect your home inverter to Energy Storage Pro, we may collect the following data about your inverter: current operating status of the inverter, PV data, grid connection data, load connection data, battery operation data, etc.

(7) Transmission of personal information involving third-party code or plug-ins

l Firebase SDK:

Application purpose or scenario: for statistics, analysis of data, equipment application performance monitoring services, push services

Type/Scope of Personal Information Collected and Shared: Collects information about your device (including Android ID, MAC address), information about what is running when the app crashes.

SDK Service Provider: Google

Privacy Policy Link: https://firebase.google.cn/support/privacy

3How we use your personal data according to the legal basis

The personal data collected will be processed for the purposes set out below, on the basis of the legal grounds set out below:

(1) As may be necessary for the performance of the Energy Storage Pro Cloud Services or in order to take steps in response to your request prior to the provision of any of the Services (legal basis for EU/EEA: Art. 6 (1) (b) GDPR), and in particular: to provide the information that you have requested under the Energy Storage Pro User Manual services that you need and/or request (e.g. creation of a plant, viewing of plant, viewing of the operational status of the device, alarm lists, maps, etc., communication with you (and in the case of faults or other service information, notification to you) about the services);

(2) It is necessary for our legitimate business interests (Art.6 (1) (f) GDPR), in particular:

For the safety of Energy Storage Pro and its users, improvement of Energy Storage Pro and error analysis;

Provide you with product upgrades, perform power generation analyses, prepare progress reports and/or provide repairs and maintenance for our products;

For the purposes of legal claims, compliance, regulation, investigations, etc. (including disclosure of information in connection with legal proceedings or litigation).

(3) It is necessary to comply with the applicable law governing us (Art. 6 (1) (c) GDPR):

(4) Based on your consent (Art. 6 (1) (a) GDPR): We will ask you for your consent and inform you that we wish to process your personal data on the basis of such legal grounds. An example is given below:

Please note that all personal data relating to you collected by Energy Storage Pro is treated as absolutely confidential. If transmission is required by applicable law, we may need to obtain your prior express consent before transferring your data to third parties.

4. Location-based services

In order to provide location-based services on the Energy Storage Pro Products, we may collect and process accurate location data, including the geographic location of your mobile device at the time of the construction of the plant. When you use Energy Storage Pro's mapping features, we will need to call the map vendor's SDK or API in order to obtain it, so that we can provide you with location-based services. Where available, location-based services use GPS, Bluetooth and your IP address, as well as crowdsourced WLAN hotspot and base station locations and other technologies to determine the approximate location of your device. Some of the location-based services offered by Energy Storage Pro (such as the "plant map" feature) require you to provide information about the location of your plant before it can be used.

In this respect, the installer/operator or the user can create the location of the plant with the help of the mobile phone's positioning via Energy Storage Pro and transfer the information to us. We only use the location data for the maintenance and management of plant.

We will process such data where this is necessary to protect our legitimate interests (Art. 6 (1) (f) GDPR) or where this is necessary to provide you with our services (Art. 6 (1) (b) GDPR).

5. Services based on camera and album permissions

When you turn on the camera and album permissions (such as creating a plant, album import, modifying profiles, personal information, etc.), we may carry out the function of scanning QR codes or uploading pictures on the device. If you don't need such service, you can turn off the permission at any time, which will not affect the use of other services.

When you turn on the Bluetooth permission (e.g. WLAN configuration, logging in to the device, etc.), we may debug the device locally. If you do not need such a service, you can turn off the permission at any time, which will not affect the use of other services.

6. Services based on storage permissions

When you use the services of storage (such as log download, upgrading files, etc.), we may turn on the permission to delete and create files in the SD card to enable the file download function. If you don't need such a service, you can turn off the permission at any time, which will not affect the use of other services.

7. Services based on clipboard permissions

When you may need to copy and paste text during use (e.g. organisation code, device SN, etc.), we may request that the clipboard copy/paste function be invoked and collect text information from your device's clipboard. The clipboard information will only be processed on your device and we will not store your clipboard information for use in other ways.

8. Cookies

When you visit the Energy Storage Pro website, we may use "cookies", which are small text files that are saved by your browser and stored on your computer. Cookies are small text files that are saved by your browser and stored on your computer. The use of cookies makes a website more user-friendly. These cookies do not cause any damage to your computer and are usually deleted at the end of the session, with the exception of persistent cookies.

We only use cookies when absolutely necessarythey are required so that you can browse the website and use its functions. Without these cookies, it would not be possible to ensure that their functionality is utilised, for example to save actions performed during your visit (e.g. text input) or to remember the information you have entered when navigating through the various pages of the website. The cookies we use help us to display valid and meaningful search results in the Energy Storage Pro based on language and time zone settings.

If you wish to disable cookies, you can do so through your browser's settings function. For other browsers, please contact your provider for information on how to disable cookies. For information relating to deleting or controlling cookies, you can visit www.allaboutcookies.org. Please note that deleting our cookies (or disabling them at a later date) will result in the possibility that you may not be able to visit Energy Storage Pro or use certain features of Energy Storage Pro.

We will carry out the processing activities described above in relation to your personal data where this is necessary to safeguard our legitimate interests (Art. 6 (1) (f) GDPR).

9. Disclosure to third parties and transfer of data outside the EEA

When you use Energy Storage Pro's "fault push messaging" feature in our applications or authorise in-app push notifications, we may share your virtual device ID with our service provider (Firebase) so that they can send push messages to your device on our behalf. You have the right to unsubscribe from receiving informational messages from Inventronics New Energy via our email marketing platform and other cloud-based marketing platforms.

In addition, Inventronics New Energy may share personal data with third-party service providers (as our data processors) only if it is necessary to provide you with Energy Storage Pro Cloud Services (i.e., hosted service providers) and information technology and maintenance support, or to improve our products and services (e.g., for faster response times to on-site service providers). We do not share personal user data with third parties for any marketing purposes.

If you are the owner, your email information will not be visible to others after registration in order to protect your privacy. However, if you are an installer or operator or administrator, then please note that your mobile phone or email information will be visible to others so that your customers can find your contact information and get in touch with you.

When you use Energy Storage Pro's "Plant Sharing" feature and share your plant with other end-users/owners, the data and content of the plant that you share (e.g., status of the plant, name of the plant, type of the plant, installed capacity, real-time power), as well as the data and content of the device under the plant (PV data, grid data, load data, battery data) can be accessed by these sharers. data, load data, battery data) can be accessed by these sharers.

Your personal data may be shared with other Inventronics New Energy entities in order to fulfil the processing purposes set out in this policy (e.g. to answer your questions or to provide the services you have requested requires the participation of other entities). We may also share your personal data with our head office (Zhejiang Inventronics New Energy Technology Co., Ltd.) as a data processor (hosting, IT services and maintenance).

We may share personal data with government agencies and/or law enforcement officials if required to do so by applicable law or if it is necessary to lawfully protect our legitimate interests and in compliance with applicable law.

If our business is sold or merged with another business, your details may be disclosed to our advisers and the advisers of any prospective buyer and may be transmitted to the new owner of the business.

We will carry out the processing activities described above when it is necessary to do so in order to safeguard our legitimate business interests (Art. 6 (1) (f) GDPR).

If personal data are transferred outside the EEA and such data are transferred to an Inventronics New Energy affiliate or supplier located in a country that is not subject to a European Commission Due Diligence Decision, such data are subject to the standard contractual clauses approved by the European Commission (for more information, please visit https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/model-contracts- transfer-personal-data-third-countries_en ), appropriate Privacy Shield certifications (for more information, visit https://www.privacyshield.gov ), or binding corporate rules for a vendor's processors (for more information, please visit https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/binding-corporate- rules_en ) for adequate protection.

10. Protection of personal data

(1) Energy Storage Pro attaches great importance to the security of your personal data and has taken appropriate technical and organisational measures. The Energy Storage Pro online services (e.g. the Energy Storage Pro website) will use encryption technologies, such as the 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 rights and these are deployed in facilities protected by physical security measures.

(2) If you wish to cancel your account, you can do so through the "My Account - Account and Security - Cancel Account" section of the Energy Storage App. After cancelling your account, we will stop providing products and services to you and delete or anonymise your personal information, unless otherwise provided by laws and regulations.

11. Our commitment to your privacy

To ensure the security of your personal data, we have communicated privacy and security guidelines to the entire Energy Storage Pro team and strictly enforce privacy safeguards within the team.

12. Your Rights and Choices

You can log in to your Energy Storage Pro account and help us ensure that your contact information and preference settings are accurate, complete and up-to-date.

In addition, you have the right to ask us:

l Provide access to and copies of your personal data held by us (Art. 15 GDPR).

l Providing you with or sending some of your personal data to other data controllers in a commonly used, machine-readable format (Art. 20 GDPR).

l Updating or correcting your personal data to make it accurate (Art. 16 GDPR).

l Deletion of your personal data from our records under certain circumstances (Art. 17 GDPR).

l Restriction of the processing of your personal data in certain cases (Art. 18 GDPR).

l You also have the right to object to the processing of your personal data by us in certain circumstances (Art. 21 GDPR).

In some cases, these rights may be restricted. For example, we may be able to demonstrate that we are required by law to process your data, or that providing you with this information would compromise the personal data of others, or that we are legally prohibited from disclosing such information. In some cases, this may mean that we are able to retain the data even if you withdraw your consent.

We would like to address any concerns you may have about the way we process your data. If you have any questions about how we process your data, please contact us as set out below.

If you still have unresolved concerns, you also have the right to lodge a complaint with the supervisory authority, in particular with the data protection authority of the Member State in which you have your habitual residence or place of work.

Finally, please note that if we require personal data in order to comply with a legal obligation or to provide you with the Energy Storage Pro Services, then you must provide such data: if such data is not provided, we may not be able to manage our relationship with you or fulfil our obligations. In all other cases, providing the requested personal data is optional.

13. Period of reservation

Energy Storage Pro will retain the data relating to your access to the Energy Storage Pro Cloud Platform and your account data until you delete your account/account data or you request the deletion of your personal data, unless we have a legitimate reason to retain your data further.

Energy Storage Pro will retain your information for as long as possible during any relationship you may have with us and for as long as permissible after the relationship has ended to fulfil the purposes stated in the notice. We will delete your IP address at the end of the session.

Energy Storage Pro may be required by law to retain certain information for a specific period of time (e.g. 6 to 10 years for tax and bookkeeping purposes). In other cases, Energy Storage Pro may retain data for an appropriate period of time after the end of any relationship with you for the purpose of responding to legal proceedings or managing its business (e.g. the standard limitation period is three years from the end of the year in which the relevant data was processed).

14. Special precautions for minors

Our Energy Storage Pro Cloud service is intended for use only by persons of legal age. Users are therefore required not to provide any personal data of minors.

15. Updates to this policy

Energy Storage Pro may update its Privacy Policy from time to time. If we make material changes to our Privacy Policy, we will post a notice and the updated Privacy Policy on the Energy Storage Pro website and app.

16. Contact Us

If you have other complaints and suggestions, please contact us at https://www.inventronics-ne.com. You can also send your questions to Zhejiang Inventronics New Energy Technology Co., Ltd.

Address: Inventronics Technology Park, No.459 Jianghong Road, Binjiang District, Hangzhou, Zhejiang, China

Postcode: 310051

E-mail address: energystoragepro@inventronics-co.com