ENERAI Technology PTE. LTD. (“EnerAI”, “Company”, “we” or “us”) attaches great importance to the protection of personal data. This Privacy Policy describes how we collect, use, disclose and otherwise process (collectively, “process” or “processing”) your personal data when you access or use the EnerAI website available at [www.eneraitech.com] (the “Website”), register for an account, submit an inquiry, request or download materials, subscribe to marketing communications, or otherwise interact with us through the Website.

This Policy applies to personal data relating to Website visitors, registered users, and other individuals who interact with us through the Website. For the purposes of this Policy, the relevant data controller is ENERAI Technology PTE. LTD., a company incorporated in Singapore.

Where certain jurisdictions impose specific or additional requirements on the processing and protection of personal data, we address such requirements in the Appendix: Jurisdiction-specific Notices of this Policy.

This Policy will help you understand the following content:

I. How we collect and use your personal data

II. Cookies and Similar Technologies

III. How we share and disclose your personal data

IV. International transfer of your personal data

V. How we protect your personal data

VI. Your personal data rights

VII. Scope of Application

VIII. How we update this Policy

IX. How to contact us

I. How We Collect and Use Your Personal Data

Personal data refers to any data that can directly or indirectly identify a specific natural person (“data subject”).

A. Collection of Personal Data

We may collect your personal data from the following sources in connection with the Website:

1. information you voluntarily provide through registration forms, inquiry forms or other submission forms on the Website;

2. information automatically collected by our systems (including cookies, access logs, and analytics tools); and

3. information imported through third-party login services (such as LinkedIn), where you choose to use such services.

The categories of personal data collected and processed by us may include the following. Certain information underlined may be deemed sensitive personal data in certain jurisdictions. We will only collect and process sensitive personal data where necessary for the relevant purposes described in this Policy and will apply appropriate safeguards to such processing. Where required by applicable law, we will obtain your separate consent or otherwise comply with applicable requirements before processing sensitive personal data.

1. Basic Information:

When you register for an account, submit an inquiry, request materials, or otherwise interact with the Website, EnerAI may process basic information, where applicable, including your name, email address, company name, and country/region.

2. Account Information:

When you register for an account on the Website, EnerAI may process account information that you provide or that is automatically generated, including, where applicable, your username and password, registration time, last login time, preferred language, and areas of product interest.

3. Inquiry and Business Information:

Where you submit a product inquiry or request materials through the Website, EnerAI may process information relating to your inquiry, including the content of your inquiry, products in which you are interested and descriptions of your project or business requirements.

4. Technical and Usage Information:

When you use the Website, EnerAI may automatically collect certain technical and usage information, including your IP address, browser and device information, Website access, navigation and download records, access time, and traffic source information.

The specific types of personal data processed may vary depending on the Website function you use. Not all fields listed above apply to every Website visitor or user. If you would like to know more about the personal data processed through the Website, you may contact us through the contact details set out in Section IX of this Policy.

B. Purposes for Collecting and Processing Personal Data

We may collect and use your personal data for the following purposes. If certain personal data is not provided, we may not be able to provide the relevant Website functions or respond to your requests. The data categories referenced in this Section are defined in Section I.A.

1. To Create and Manage Website Accounts

We may process your Basic Information and Account Information to register and manage your account, verify your login credentials, manage access to Website functions and provide an appropriate Website experience.

2. To Respond to Product Inquiries, Requests and Event Registrations

We may process your Basic Information and Inquiry and Business Information to respond to your inquiries, provide requested product or technical materials, process event registrations through the Website, follow up on potential business opportunities, and understand your product or project requirements.

3. To Send Marketing Communications

Where you have subscribed to or otherwise agreed to receive marketing communications, we may use your Basic Information to send newsletters, product updates, event invitations and other marketing communications. You may opt out of such communications at any time using the unsubscribe mechanism provided in the relevant communication or by contacting us through the contact details set out in Section IX of this Policy.

4. To Conduct Website Analytics and Support Advertising and Marketing Activities

We may process your Technical and Usage Information to understand how visitors use and interact with the Website, analyze Website traffic and performance, improve Website functions, content and user experience, and measure and improve the effectiveness of our advertising and marketing activities.

5. To Operate, Maintain and Secure the Website

We may process relevant personal data where necessary to operate and maintain the Website, prevent and investigate security incidents, protect the Website and our information systems, and provide technical support.

6. Other Purposes

If we intend to process your personal data for a purpose that is materially different from those described in this Policy, we will provide any additional notice required by applicable law and, where necessary, obtain your consent or otherwise ensure that such further processing is permitted under applicable law.

C. Legal Basis for Processing Personal Data

Applicable laws and regulations in different jurisdictions may provide for different legal bases for processing personal data. We will rely on the applicable legal basis depending on the relevant jurisdiction, processing purpose and type of personal data. Where certain jurisdictions impose specific requirements, we will address such requirements in the Appendix of this Policy. The commonly used legal bases include the following, but may differ in your jurisdiction: 

1. Consent

Where consent is required under applicable laws or is otherwise an appropriate legal basis for the relevant processing, we will seek your consent before processing your personal data. Where our processing is based on your consent, you may withdraw your consent in accordance with applicable laws and this Policy.

2. Conclusion and Performance of a Contract

We may process your personal data where necessary to perform a contract with you or to take steps at your request before entering into a contract. This may include, where applicable, providing Website functions or materials requested by you, responding to requests submitted by you in connection with a potential contractual relationship, and otherwise taking steps requested by you in preparation for entering into a contract.

3. Legitimate Interests Pursued by the Company or a Third Party

We may process relevant categories of personal data described in Section I.A where the processing is necessary for the Company’s or a third party’s legitimate interests, provided that such interests are not overridden by your interests, rights or freedoms. Such legitimate interests may include operating and securing the Website, managing business relationships, improving the Website and user experience, preventing misuse and protecting our legal rights.

4. Compliance with Legal Obligations

We may process relevant personal data where necessary to comply with applicable legal or regulatory obligations.

D. Retention Period and Deletion of Personal Data

This Section describes retention periods by reference to the data categories set out in Section I.A rather than individual data types. Please refer to Section I.A for the specific data types associated with each category.

1. Basic Information: Where Basic Information is collected in connection with your Website account, it will generally be retained for the duration of your account and for 30 days after the account is closed. Where Basic Information is collected through an inquiry form, it will generally be retained for two years.

2. Account Information: Account Information will generally be retained for the duration of your account and for 30 days after the account is closed.

3. Inquiry and Business Information: Inquiry and Business Information submitted through the Website will generally be retained for two years. Where such information contains sensitive personal data, the relevant sensitive personal data will generally be retained for one year.

4. Technical and Usage Information: Website access and log information will generally be retained for six months and will be automatically deleted upon expiry of the applicable retention period. The retention periods applicable to Cookies and similar technologies are described in our Cookie Policy.

Upon expiry of the applicable retention period, personal data will be deleted or, where appropriate, anonymized. Where a longer retention period is required by applicable laws and regulations, we may retain the relevant personal data for such longer period in accordance with applicable legal requirements.

II. Cookies and Similar Technologies

We use cookies and similar technologies (“Cookies”) on the Website to support Website functionality, remember user preferences, analyze Website usage, and support advertising and marketing activities.

Where required by applicable law, we will obtain your consent before using non-essential Cookies. You may manage or withdraw your Cookie preferences through the Cookie settings available on the Website.

For more information about the Cookies used on the Website, please refer to our Cookie Policy: [ ]

III. How We Share and Disclose Your Personal Data

EnerAI may make your personal data available to relevant EnerAI affiliated companies and their authorized personnel in China where necessary for the purposes described in this Policy, including operating and maintaining the Website, managing user accounts, responding to product inquiries, following up on business opportunities, providing requested materials, supporting marketing communications, and conducting internal analysis and reporting.

We may also disclose your personal data to third-party service providers that support the operation of the Website and related activities, including providers of cloud hosting and infrastructure services, cybersecurity and other technical services, website analytics services, and advertising, marketing and email delivery services.

We will only share or disclose personal data that is necessary for the relevant purpose and will take reasonable steps to ensure that the recipient protects the confidentiality and security of your personal data. Where applicable laws require separate consent or impose other specific requirements for sharing or disclosing certain personal data, we will comply with such requirements.

IV. International Transfer of Your Personal Data

Your personal data processed through the Website is primarily stored on servers located in Singapore.

Depending on where you are located and the relevant processing activity, your personal data may be transferred to, stored in, or accessed from jurisdictions outside your country or region, including Singapore, China and the United States. Such transfer or access may constitute an international transfer of personal data under applicable data protection laws and regulations.

The data protection laws in the receiving jurisdiction may differ from those in your jurisdiction. Where required by applicable data protection laws, we will take measures to comply with applicable requirements for international transfers of personal data, which may include relying on an adequacy decision or similar mechanism, entering into applicable data transfer agreements or standard contractual clauses, conducting transfer impact assessments where required, and implementing appropriate technical and organizational measures.

If you have any questions or need more information, you can contact us by following the instructions in Section IX “How to Contact Us” of this Policy.

V. How We Protect Your Personal Data

The Company takes appropriate technical and organizational measures to protect your personal data processed through the Website against unauthorized access, disclosure, alteration, loss or misuse.

Such measures may include role-based access controls, multi-factor authentication, encryption in transit and encryption of sensitive data at rest, password hashing, Web Application Firewall (WAF) protection, access logging, regular data backups, and other appropriate security measures.

Please note that no system or transmission method can be guaranteed to be completely secure. The Company will continue to review and improve its security measures in accordance with applicable laws, Website operation requirements and internal security practices.

VI. Your Personal Data Rights

Under applicable data protection laws, you may have all, or part of, the following rights to your personal data. The availability of these rights may vary depending on your jurisdiction and the legal basis for processing. You may exercise your rights by contacting us as indicated in Section IX “How to Contact Us” of this Policy.

A. Know / Be Informed

You have the right to receive clear information about how we process your personal data, which we provide through this Policy.

B. Access Your Personal Data

You have the right to access your personal data, except as otherwise provided by applicable laws or regulations.

C. Correct or Supplement Your Personal Data

You can request correction of inaccurate personal data and completion of incomplete information.

D. Delete Your Personal Data

You may request deletion of your personal data in accordance with applicable laws and regulations. Please note that we may decline or be unable to fulfill a deletion request where continued retention is required or permitted by applicable laws, or where the data is needed for legal, regulatory, record keeping or dispute handling purposes.

E. Restrict Processing

Where provided by applicable laws, you may have the right to request that we restrict the processing of your personal data in certain circumstances. Where processing is restricted, we may continue to process such personal data to the extent permitted by applicable laws, including, where applicable, for the establishment, exercise or defense of legal claims.

F. Data Portability

Where provided by applicable laws, you may request to receive a copy of certain personal data in a structured, commonly used and machine-readable format, or request that we transfer such personal data to another party, where technically feasible and where doing so does not adversely affect the rights and freedoms of others.

G. Object

Where provided by applicable laws, you are entitled to object to our processing of your personal data when such processing is grounded on our legitimate interests. You may also have the right to object to the processing of your personal data for direct marketing purposes.

H. Automated Individual Decision-making

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.

I. Withdraw Your Consent

Where our processing of your personal data is based on your consent, you may withdraw your consent at any time. Your withdrawal of consent will not affect the lawfulness of processing conducted before the withdrawal.

J. Lodge a Complaint with a supervisory authority

Where provided by applicable laws, you may have the right to lodge a complaint with the competent data protection or supervisory authority if you believe that our processing of your personal data violates applicable data protection laws.

VII. Scope of Application

This Policy applies to the processing of personal data through or in connection with the Website, including Website browsing, account registration and management, product inquiries, requests for and downloads of materials, Website analytics and marketing subscriptions.

Certain Website functions, services or jurisdictions may be subject to additional privacy notices or specific data protection requirements. Where such additional notices or requirements apply, they will supplement this Policy.

This Policy does not apply to third-party websites, platforms or services that are not operated by us, even if such websites, platforms or services may be accessed through links, interfaces or integrations on the Website. Such third parties process personal data in accordance with their own privacy policies and practices.

VIII. How We Update This Policy

We may update or modify this Policy from time to time to reflect changes in the Website, Website functions, applicable laws and regulations, or our personal data processing practices.

Where required by applicable laws and regulations, we will notify you of material changes through appropriate means, such as Website notices, email notices or other reasonable methods.

Where changes to our processing activities require us to obtain your consent under applicable laws and regulations, we will seek your consent as required by applicable laws.

IX. How to Contact Us

If you have any questions or concerns about this Policy, our processing of your personal data through or in connection with the Website, or if you wish to exercise your personal data rights, you may contact us through the contact details set out below.

We will respond to your request within the period required by applicable laws and regulations. Where permitted by applicable laws, we may need to verify your identity before processing your request.

Appendix: Jurisdiction-Specific Notices

A. For Users in the European Economic Area (“EEA”) and the United Kingdom (“UK”)

This Appendix applies to users in EEA and UK whose personal data is processed in connection with the Website.

1. Legal Basis for Collecting and Processing Personal Data

For each processing purpose specified in Section I.B of this Policy, the legal bases we rely on are as follows:

2. Cross-border Transfer of Personal Data

Your personal information is hosted or stored on servers located in Singapore. Your personal information may be accessed by overseas recipients, including our affiliated companies in China and, where applicable, third-party service providers located in China and the United States.

Where personal data is transferred outside the EEA or the UK, we will rely on an appropriate transfer mechanism as required by applicable data protection laws. Depending on the circumstances, such transfers may be based on an adequacy decision, applicable standard contractual clauses or other legally recognized safeguards or transfer mechanisms.

You may contact us as described in Section IX “How to Contact Us” of this Policy to obtain further information about the safeguards applicable to such transfers. Should we adopt the Standard Contractual Clauses (“SCCs”) for cross-border data transfers, you may contact us to obtain a copy of the SCCs as executed, subject to the protection of our business secrets or other confidential information.

3. EU and UK Representatives

EU Representative:

Sungrow Deutschland GmbH

Address: Balanstr. 59, 81541 Munich, Germany

Contact: data-protection-officer@sungrow-emea.com

UK Representative:

Sungrow Power UK Ltd

Address: Moorgate House, 201 Silbury Boulevard, Milton Keynes, MK9 1JL, United Kingdom

Contact: data-protection-officer@sungrow-emea.com

B. For Users in Australia

This Appendix applies to users in Australia whose personal information is processed in connection with the Website. We collect, use and disclose your personal information for the purposes described in this Policy and in accordance with applicable Australian privacy laws.

For the purposes of this Appendix, references in this Policy to “personal data” mean “personal information” under applicable Australian privacy laws. References to the “data controller” mean the entity responsible for handling your personal information under those laws.

1. Your Personal Data Rights

Subject to applicable Australian privacy laws, you may request access to the personal information we hold about you and request correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

 You may also opt out of receiving direct marketing communications from us at any time through the unsubscribe mechanism provided in the relevant communication.

If you wish to exercise any of these rights, or have any questions, concerns or complaints about how we handle your personal information, you may contact us using the contact details set out in Section IX of this Policy. We will review and respond to your complaint within a reasonable period in accordance with applicable Australian privacy laws.

2. Cross-border Transfer of Personal Data

Your personal information is hosted or stored on servers located in Singapore. Your personal information may be accessed by overseas recipients, including our affiliated companies in China and, where applicable, third-party service providers located in China and the United States.

 When we disclose personal information to overseas recipients, we will take reasonable steps, as required by applicable Australian privacy laws, to ensure that such recipients handle the personal information in accordance with applicable privacy requirements.

C. For Users in Brazil

This Appendix applies to users in Brazil whose personal information is processed in connection with the Website.

1. Legal Basis for Collecting and Processing Personal Data

For each processing purpose specified in Section I.B of this Policy, we rely on the corresponding legal bases available under applicable Brazilian data protection laws, which are generally aligned with those described in Appendix A Section 1. To keep this section concise, the details of Appendix A Section 1 are not repeated herein, and you may refer to it for further details.

2. Your Data Subject Rights

In addition to the applicable rights described in Section VI of this Policy, data subjects in Brazil have the right to request confirmation of whether we process their personal data; request the anonymization, blocking or deletion of personal data that is unnecessary, excessive or processed in violation of applicable law; receive information regarding the public and private entities with which we have shared their personal data; and obtain information about the possibility of refusing consent and the consequences of such refusal.

You may exercise these rights through the contact methods described in Section IX of this Policy.

3. International Transfer of Personal Data

Where your personal data is transferred outside Brazil, we will rely on a legally recognized transfer mechanism and comply with applicable requirements under Brazilian data protection laws. Depending on the circumstances, such transfers may be based on an adequacy decision, applicable standard contractual clauses, global corporate norms or other legally recognized transfer mechanisms.

Where applicable contractual safeguards are used for such transfers, you may contact us as described in Section IX of this Policy to obtain further information or a copy of the relevant clauses, subject to the protection of our trade secrets or other confidential business information.

D. For Users in the United States

This Appendix applies to users in the United States whose personal information is processed in connection with the Website.

1. Collection of Personal Information

Within the past 12 months, the categories of personal information we have collected and the categories of sources from which the personal information is collected are detailed in Section I.A of this Policy. For purposes of applicable California privacy law, such personal information may fall within the following categories:

· Identifiers, such as name, email address, username and IP address;

· Commercial Information, such as information regarding products or services considered and related business inquiries;

· Professional or Employment-Related Information, such as company name and business affiliation;

· Internet or Other Electronic Network Activity Information, such as browser and device information, Website access, navigation and download records, access time and traffic source information; and

· Sensitive Personal Information, such as account log-in information in combination with a password or other credentials allowing access to an account.

The categories of sources from which such personal information is collected are described in Section I.A of this Policy, and the business or commercial purposes for collecting and using such personal information are described in Section I.B of this Policy. Depending on how and to what extent you use the Website, the actual categories of personal information collected may vary.We use Sensitive Personal Information only for purposes such as identity verification, account authentication and security, and do not use such information for the purpose of inferring characteristics about you.

2. Disclosure, Sale and Sharing of Personal Information

We do not sell your personal information for monetary consideration. However, we have disclosed certain Identifiers and Internet or Other Electronic Network Activity Information to advertising or analytics providers in ways that may be considered a “sale” or “sharing” under applicable state privacy laws. Such disclosures may be made for Website analytics, advertising and marketing measurement and, where applicable, cross-context behavioral advertising or targeted advertising. Where applicable, you may opt out of such sale or sharing as described below.

3. Your Personal Information Rights

In addition to the types of rights listed in Section VI of this Policy, residents of certain US states may have the following rights regarding your personal information, subject to applicable state privacy laws and relevant exceptions.

· Right to opt out: Where provided by applicable law, you may have the right to opt out of:

· the sale of your personal information;

· the sharing of your personal information for cross-context behavioral advertising; and

· the processing of your personal information for targeted advertising.

You may exercise your applicable opt-out rights through the “Your Privacy Choices” link available on the Website. Where required by applicable law, we also recognize and process applicable universal opt-out preference signals, such as Global Privacy Control (“GPC”).

· No Retaliation Following Opt Out or Exercise of Other Rights: We will not discriminate against you because you exercise any of your rights.

Authorized Agent Requests: Where permitted by applicable law, you may designate an authorized agent to submit a privacy rights request on your behalf. We may take reasonable steps permitted by law to verify the agent’s authority.

 Appeals: Where applicable law provides a right to appeal our decision regarding a privacy rights request, you may submit an appeal using the contact information in Section IX of this Policy. We will process your appeal in accordance with applicable law.

4. Protection of Minors

The Website is intended for business and professional users and is not directed to children or minors. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

5. Cross-Border Transfer and Access for US Users

Your personal information is primarily hosted or stored on servers located in Singapore. Your personal information may be accessed by our affiliated companies in China and, where applicable, processed by third-party service providers located in China and the United States.

Please refer to Sections III and IV of this Policy for further information regarding our sharing and cross-border processing of personal information.

6. California Notice at Collection

The following table describes the categories of personal information we may collect from California residents, the purposes for which such information may be collected and used, whether such information may be sold or shared, and the applicable retention periods.

We do not sell your personal information for monetary consideration. Where applicable, you may opt out of the sale or sharing of your personal information through the “Your Privacy Choices” link available on the Website.

For more information about our privacy practices, including your rights, please see this Privacy Policy.

E. For Users in Canada

This Appendix applies to users in Canada whose personal information is processed in connection with the Website.

 For the purposes of this Appendix, references in this Policy to “personal data” mean “personal information” under applicable Canadian privacy laws. References to the “data controller” mean the organization responsible for handling your personal information under those laws.

1. Consent

Under applicable Canadian privacy laws, we generally collect, use and disclose personal information with your knowledge and consent. We may also collect, use or disclose personal information without consent where permitted or required by applicable law.

 2. Your Personal Information Rights

Subject to applicable Canadian privacy laws, you may be informed about the purposes for which your personal information is collected, used or disclosed, request access to your personal information and, where applicable, information about its use or disclosure, request correction of inaccurate or incomplete personal information, or withdraw your consent.

 Where Quebec privacy law applies, you may also request that certain computerized personal information collected from you be provided to you, or communicated to another person or organization authorized by law, in a structured and commonly used technological format.

 You may exercise your rights through the contact details set out in Section IX of this Policy.

3. Cross-Border Processing and Transfer of Personal Information

Your personal information is primarily hosted or stored on servers located in Singapore. Your personal information may be accessed by our affiliated companies in China and, where applicable, processed by third-party service providers located in China and the United States.

 When we disclose personal information to, or allow access by, third-party service providers or EnerAI affiliates outside Canada, we will use contractual or other appropriate means to help ensure a comparable level of protection is maintained while the personal information is being processed by the third party, as required by applicable Canadian privacy laws. To access information about our policies and practices with respect to service providers outside Canada, please contact us through the contact details set out in Section IX of this Policy.

 When we disclose your personal information to, or allow access by, EnerAI affiliates outside Canada, your personal information may be subject to the laws of the jurisdiction in which it is processed. We take appropriate measures to safeguard such personal information in accordance with this Policy and applicable data protection laws.

4. Complaints and Privacy Breaches

If you have any questions or complaints regarding our handling of your personal information, you may contact us using the contact details set out in Section IX of this Policy. We will review and respond to your complaint in accordance with applicable Canadian privacy laws. If you are not satisfied with our response, you may have the right to submit a complaint to the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.

 In the event of a privacy breach involving your personal information, we will take appropriate steps to investigate and address the breach and, where required by applicable Canadian privacy laws, notify affected individuals and the relevant privacy regulator.

F. For Users in Mexico

This Appendix applies to users in Mexico whose personal data is processed in connection with the Website.

1. Consent

Under applicable Mexican data protection law, personal data is generally processed with the consent of the data subject. We may also process personal data without consent where permitted by applicable law, including where the processing is necessary to comply with obligations arising from a legal relationship between you and EnerAI.

2. Your Personal Data Rights

Subject to applicable Mexican data protection laws, you may be informed about the processing of your personal data, including the purposes for which it is processed, request access to your personal data and information relating to its processing, request rectification or correction of inaccurate, incomplete or outdated personal data, request cancellation of your personal data, object to the processing of your personal data where the applicable legal conditions are satisfied, and withdraw your consent to the processing of your personal data at any time.

 You may exercise your rights through the contact details set out in Section IX of this Policy.

 3. Cross-border Transfer of Personal Data

Where the processing activities described in Sections III and IV of this Policy involve the transfer of your personal data to EnerAI affiliates or other third parties outside Mexico, or the processing of your personal data outside Mexico by service providers acting on our behalf, we will comply with applicable Mexican data protection laws and apply appropriate measures to protect your personal data.

Where consent is required for a transfer, we will obtain your consent as required by applicable law. Your consent may not be required where an applicable legal exception applies, including, where applicable, where the transfer is made to an EnerAI parent company, subsidiary or affiliate operating under the same processes and internal policies, or where the transfer is necessary to maintain or fulfil a legal relationship between you and EnerAI.

Where a service provider processes personal data on our behalf, such processing will be subject to appropriate contractual, confidentiality and security requirements in accordance with applicable law.

G. For Users in India

This Appendix applies to users in India whose personal data is processed in connection with the Website. We process your personal data for lawful purposes connected with the functions and activities described in this Policy and in accordance with applicable Indian data protection laws.

1. Processing of Personal Data

Under applicable Indian data protection laws, we may process your personal data based on your consent or for other purposes permitted by law, including certain legitimate uses recognized under applicable law. Where you voluntarily provide personal data to us for a specified purpose, we may process such personal data for that purpose where permitted by applicable law.

2. Your Personal Data Rights

Subject to applicable Indian law, you may have the right to obtain information about how we process your personal data, access or review your personal data, request the correction, completion, updating or erasure of your personal data, withdraw your consent where processing is based on consent, raise questions or grievances regarding our processing of your personal data, and, where applicable, nominate another individual to exercise your rights in the event of your death or incapacity.

You may exercise your rights through the contact details set out in Section IX of this Policy.

3. Cross-border Transfer of Personal Data

Where we transfer your personal data outside India, we will take appropriate measures to protect your personal data and ensure that such transfers are carried out in accordance with applicable Indian data protection laws, including any applicable restrictions or requirements relating to such processing.

H. For Users in Singapore

This Appendix applies to users in Singapore whose personal data is processed in connection with the Website.

1. Consent

Under applicable Singaporean personal data protection law, we generally collect, use or disclose your personal data with your consent or where you are deemed to have consented in accordance with applicable law.

 We may also collect, use or disclose personal data without consent where permitted or required. This may include processing for legitimate interests, such as preventing misuse and protecting the security of the Website and our information systems, or for permitted business improvement purposes, such as improving our Website, services, subject to the conditions required under applicable law.

2. Your Personal Data Rights

Subject to applicable Singaporean personal data protection laws, you may be informed of the purposes for which your personal data is collected, used or disclosed, request access to your personal data held by us and information about the ways in which such personal data has been or may have been used or disclosed during the period prescribed by applicable law, request correction of inaccurate or incomplete personal data, and withdraw any consent given or deemed to have been given for the collection, use or disclosure of your personal data.

You may exercise your rights through the contact details set out in Section IX of this Policy.

3. Cross-border Transfer of Personal Data

Where the processing activities described in Sections III and IV of this Policy involve the transfer of your personal data outside Singapore, we will take appropriate steps to ensure that the transferred personal data is protected to a standard comparable to that required under applicable Singaporean data protection laws, including through contractual arrangements or other legally recognized measures.

I. For Users in Thailand

This Appendix applies to users in Thailand whose personal data is processed in connection with the Website.

 1. Cross-border Transfer of Personal Data

Where the processing activities described in Sections III and IV of this Policy involve the transfer of your personal data outside Thailand, such transfer will be carried out in accordance with applicable Thai personal data protection laws, including, where applicable, where necessary for the performance of a contract, through appropriate contractual or other safeguards, or on another basis permitted under applicable law.

J. For Users in Indonesia

This Appendix applies to users in Indonesia whose personal data is processed in connection with the Website.

 1. Your Personal Data Rights

In addition to the applicable rights described in Section VI of this Policy, data subjects in Indonesia may have the right to bring a claim and seek compensation for violations involving the processing of their personal data, in accordance with applicable Indonesian personal data protection laws.

 You may exercise your rights through the contact details set out in Section IX of this Policy.

2. Cross-border Transfer of Personal Data

Where the processing activities described in Sections III and IV of this Policy involve the transfer of your personal data outside Indonesia, we will comply with applicable Indonesian personal data protection laws and implement appropriate contractual or other binding safeguards to provide adequate protection for your personal data.

K. For Users in Vietnam

This Appendix applies to users in Vietnam whose personal data is processed in connection with the Website.

1. Legal Basis for Processing Personal Data

Under applicable Vietnamese personal data protection laws, consent is the primary legal basis for processing personal data. Where consent is required, we will obtain and manage your consent in accordance with applicable Vietnamese personal data protection laws.

Where permitted by applicable Vietnamese laws, we may process your personal data without consent in limited circumstances, including where processing is necessary to perform an agreement between you and EnerAI, or where other statutory exceptions apply.

2. Rights and Obligations of Data Subjects

In addition to the applicable rights described in Section VI of this Policy, data subjects in Vietnam also have the following rights under applicable Vietnamese personal data protection laws: (i) to complain, denounce, initiate lawsuits, and claim compensation for damages in accordance with applicable Vietnamese laws; and (ii) to request that competent authorities and relevant agencies, organizations and individuals implement measures to protect their personal data in accordance with applicable Vietnamese laws.

Data subjects in Vietnam also have obligations under applicable Vietnamese personal data protection laws, including protecting their own personal data, respecting and protecting the personal data of others, providing complete and accurate personal data where required, and complying with applicable personal data protection laws.

You may exercise your rights by contacting us as described in Section IX of this Policy.

3. Cross-Border Transfer of Personal Data

Where the provision, disclosure or transfer of your personal data described in Sections III and IV of this Policy involves a transfer outside Vietnam, we will take steps required by applicable Vietnamese personal data protection laws and apply appropriate safeguards to protect your personal data.

L. For Users in Malaysia

This Appendix applies to users in Malaysia whose personal data is processed in connection with the Website.

1. Legal Basis for Processing Personal Data

Under applicable Malaysian personal data protection laws, we generally process personal data with the consent of the data subject. Where permitted by law, we may process personal data without consent, including where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request with a view to entering into a contract (including to create and manage your Website account, respond to product inquiries or other business requests, and provide information or materials you have requested).

Where consent is required under applicable Malaysian personal data protection laws, we will seek to obtain such consent accordingly.

2. Data Subject Rights

Subject to applicable Malaysian personal data protection laws, you may request access to or correction of your personal data, withdraw your consent, limit the processing of your personal data, or request data portability where applicable and technically feasible.

You may exercise your rights, or contact us with inquiries or complaints regarding the processing of your personal data, by using the contact details set out in Section IX of this Policy.

3. Cross-Border Transfer of Personal Data

Where the provision, disclosure or transfer of your personal data described in Sections III and IV of this Policy involves a transfer outside Malaysia, such transfer will be carried out in accordance with applicable Malaysian personal data protection laws, including where necessary for the performance of a contract, with your consent, or through appropriate contractual safeguards recognized under applicable Malaysian data protection guidance.

M. For Users in Saudi Arabia

This Appendix applies to users in the Kingdom of Saudi Arabia whose personal data is processed in connection with the Website.

1. Legal Basis for Processing Personal Data

For each processing purpose specified in Section I.B of this Policy, the legal bases we rely on are as follows:

2. Data Subject Rights

Subject to applicable Saudi personal data protection laws, you may have the right to be informed of the legal basis and purpose for collecting your personal data, access your personal data, request that your personal data be provided to you in a clear and readable format, request the correction or destruction of your personal data, and withdraw your consent.

You may exercise these rights, or contact us with any inquiries or complaints regarding the processing of your personal data, using the contact details set out in Section IX of this Policy.

3. Cross-Border Transfer of Personal Data

Where the provision, disclosure or transfer of your personal data described in Sections III and IV of this Policy involves a transfer outside the Kingdom of Saudi Arabia, such transfer will be carried out in accordance with applicable Saudi personal data protection laws, including the Standard Contractual Clauses (SCCs) issued by the Saudi Data & AI Authority (“SDAIA”).

N. For Users in the United Arab Emirates

This Appendix applies to users in the United Arab Emirates whose personal data is processed in connection with the Website.

1. Legal Basis for Processing Personal Data

Where permitted by law, we may process personal data without consent, including where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request with a view to entering into a contract (including to create and manage your Website account, respond to product inquiries or other business requests, and provide information or materials you have requested).

Where the DIFC Data Protection Law or the ADGM Data Protection Regulations apply, for each processing purpose specified in Section I.B of this Policy, the legal bases we rely on are as follows:

2. Data Subject Rights

Where the UAE Federal Decree-Law concerning the Protection of Personal Data applies, subject to applicable law, you may receive information about the processing of your personal data, withdraw your consent, request the transfer, correction or erasure of certain personal data, request the restriction of, or object to, processing in specified circumstances, and object to certain automated decisions, including profiling.

Where the DIFC Data Protection Law or the ADGM Data Protection Regulations apply, you may have rights corresponding to the categories of data subject rights identified in Section VI of this Policy. The scope of, conditions applicable to, and any limitations or exemptions relating to each right will be determined in accordance with the applicable data protection regime.

You may exercise your rights, or contact us with inquiries or complaints regarding the processing of your personal data, by using the contact details set out in Section IX of this Policy.

3. Cross-Border Transfer of Personal Data

Where the provision, disclosure or transfer of your personal data described in Sections III and IV of this Policy involves a transfer outside the United Arab Emirates or, where applicable, outside the DIFC or the ADGM, such transfer will be carried out in accordance with the applicable data protection regime. Depending on the applicable jurisdiction and circumstances of the transfer, this may include transfers to jurisdictions recognised as providing an adequate level of protection, transfers necessary for the performance of a contract, or transfers supported by appropriate contractual safeguards or other legally recognized transfer mechanisms. Where the DIFC Data Protection Law or the ADGM Data Protection Regulations apply, such safeguards may include Standard Contractual Clauses (SCCs) issued by the relevant data protection authority.

O. For Users in South Africa

This Appendix applies to users in South Africa whose personal information is processed in connection with the Website.

For the purposes of this Appendix, references in this Policy to “personal data” will be understood as references to “personal information”, and references to the “data controller” will be understood as references to the “responsible party”, as those terms are used under applicable South African data protection laws.

1. Legal Basis for Processing Personal Information

Under applicable South African personal information protection laws, we may process your personal information on one or more lawful grounds, including where you have consented to the processing; where the processing is necessary to carry out actions for the conclusion or performance of a contract to which you are a party (including, where applicable, to create and manage your Website account, respond to product inquiries or other business requests, and provide information or materials you have requested); where the processing is necessary to comply with an obligation imposed by law on us; or where the processing is necessary for pursuing the legitimate interests of the Company or a third party (including conducting Website analytics and improving the Website, and operating, maintaining and securing the Website and our information systems).

2. Data Subject Rights

Subject to applicable South African personal information protection laws, you may have rights corresponding to certain categories of data subject rights identified in Section VI of this Policy, including the rights to be informed, access and correct your personal information, request its deletion or destruction or the restriction of processing in specified circumstances, object to certain processing, withdraw your consent where processing is based on consent, and exercise applicable rights in relation to automated decision-making. The scope of, conditions applicable to, and limitations or exemptions relating to these rights will be determined in accordance with applicable South African law. South African law does not provide a general right to data portability equivalent to the right described in Section VI.F of this Policy.

3. Cross-Border Transfer of Personal Information

Where the provision, disclosure or transfer of your personal information described in Sections III and IV of this Policy involves a transfer outside South Africa, such transfer will be carried out in accordance with applicable South African personal information protection laws, including, where the applicable conditions are met, where necessary for the performance of a contract with you or a contract concluded in your interest, or through a binding agreement that provides an adequate level of protection.

P. For Users in Republic of Korea (“South Korea”)

This Appendix applies to users in Republic of Korea whose personal information is processed in connection with the Website.

1. Legal Basis for Processing Personal Data

Under applicable South Korean laws, we collect and process your personal data with your consent or on other grounds permitted by applicable law, including:

· where processing is necessary to perform a contract with you or to take steps at your request in the course of entering into a contract;

· where processing is necessary to pursue our legitimate interests, provided that such interests clearly override your rights and the processing is substantially related to such legitimate interests and does not exceed a reasonable scope.

The categories of personal data we process and the specific purposes for such processing are described in Sections I, III, IV of this Policy. You may contact us using the contact information in Section IX of this Policy for additional information.

2. Your Data Subject Rights

In addition to the rights described in Section VI of this Policy, and subject to applicable South Korea laws, you may have the following rights:

· Right to Suspension of Processing: Subject to statutory exceptions under applicable law, you have the right to request that we suspend the processing of your personal data.

You may exercise your rights through the contact methods described in Section IX of this Policy.

3. International Transfer of Personal Data

Where personal information is transferred outside South Korea, including through overseas access, entrusted processing or storage, we will comply with applicable South Korean personal data protection laws. Such transfers will be carried out with your separate consent where required, or on another basis permitted under applicable law.

Details of applicable overseas transfers are set out below.

The purposes for which the relevant overseas recipients process personal information are described in Sections I.B and III of this Policy, and the applicable retention periods are described in Section I.D.

Where you have the right to refuse an overseas transfer, you may do so using the contact details set out in Section IX of this Policy. The effect of refusing a transfer, if any, will depend on the relevant processing activity and will be communicated to you as required by applicable law.

Q. For Users in Japan

This Appendix applies to users in Japan whose personal information is processed in connection with the Website.

1. Third-Party Provision

Where we provide your personal data to third parties as described in Section III of this Policy, we will obtain your prior consent where required under applicable Japanese personal data protection laws, or otherwise make such provision as permitted by applicable law.

2. Cross-border transfer of personal data

Where personal data is provided to a third party located outside Japan, we will comply with applicable Japanese personal data protection laws, including by obtaining your prior consent where required or by relying on another mechanism permitted under applicable law.

The personal data protection laws in China, Singapore and where applicable, the United States may differ from those in Japan. You can learn about the personal data protection legal systems in these countries through the following information published by the Personal Information Protection Commission of Japan:

· China: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_china

· Singapore: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_singapore

· United States:  https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america

We take appropriate steps to ensure that relevant overseas recipients protect your personal data. Such measures may include contractual protections, access controls, encryption, confidentiality and security requirements, and other appropriate technical and organizational measures.