mySunPan Privacy Policy

Last Updated: September 20, 2026 Effective Date: September 20, 2026

Preamble

The mySunPan (hereinafter referred to as "we", or "Sunwoda") is a PV Power Plant Monitoring Platform for new energy assets provided by Sunwoda Europe GmbH.

We are committed to protecting and maintaining your privacy. This Privacy Policy explains how we collect, store, and use your personal information through the app and applies to all services we provide. By using our services, you agree to the terms of this Privacy Policy and consent to our use of the information you provide as outlined herein.

Registered Address: Obenhauptstr.7, 22335 Hamburg, Germany

Phone: 49 0911/748992-30

Email: Service.de@sunwoda.com

To explain how mySunPan collects, uses, and stores your personal information and what rights you have, we will explain relevant matters to you through this Privacy Policy.

  1. We will explain in detail the types of your personal information we collect and their corresponding purposes, so that you can understand the specific types of personal information collected for particular functions, the reasons for use, and the methods of collection.
  2. When you use certain functions, we will collect your personal information after obtaining your consent. Unless it is mandatory to collect such information according to relevant laws and regulations, refusing to provide this information will only prevent you from using the corresponding specific function, but will not affect your normal use of other functions of mySunPan.
  3. You have the right to access, modify, copy, and delete your personal information. You can also withdraw your consent, delete your account, file complaints and reports, and use other privacy functions.
  4. In order to collect your information or provide services to you, optimize our services, and protect the security of your account, we need to request relevant permissions; sensitive permissions (such as location, camera, and photo album) will not be enabled by default, and we will only use them within the scope of your explicit consent.
  5. We will not intentionally collect personal information from children under the age of 16. You must be 16 years of age or older to create an account on the app and website.

Definitions and Terms:

Personal Information: Refers to information recorded electronically or by other means that can identify the identity of a natural person alone or in combination with other information, or reflect the activities of a specific natural person, including but not limited to name, phone number, IP address, location information, etc.

Sensitive Personal Information: Refers to personal information that, once leaked or illegally used, may cause harm to personal reputation, personal or property safety, including ID numbers, bank account numbers, travel trajectories, etc.

Processing: Refers to operations such as the collection, storage, use, transmission, provision, disclosure, and deletion of personal information.

Anonymization: Refers to the irreversible erasure or deletion of personal information to ensure that the identity of the information owner cannot be identified. Any anonymized information will not be regarded as personal information.

1. Information We Collect and Use

1.1 Registration and Login

1.1.1 When you register for mySunPan, we will collect and use your username, avatar, phone number and/or email address, and country/region. The purpose of collecting this information is to help you complete the registration and login of mySunPan, as well as to protect the security of your account.

1.2 Provision of Products and/or Services

1.2.1 Basic Functions: During your use of mySunPan, to ensure the normal operation of services, optimize user experience, and protect the security of your account, we will collect basic information required for mySunPan to provide services to you. This includes your device model, operating system, device MAC address, Bluetooth MAC, unique device identifiers, WIFI status, login IP address, mySunPan version number, network connection method, type and status, network conditions, device accelerators, operation logs, service logs, installation list, clipboard content, and other information.

1.2.2 Monitoring Function: When you use the monitoring function, to allow you to view complete monitoring data, we need to collect the serial number of the data collector installed under the power station and the serial numbers of its sub-devices (such as inverters, electric meters, etc.). At the same time, our monitoring system will collect data uploaded by the data collector and its sub-devices every 5 minutes to complete necessary data statistics and analysis functions.

1.2.3 Power Station Creation Function: When you create a power station, you need to enter information such as the power station name, region, capacity, address, and GPS location. If GPS positioning is unavailable, base station positioning may be used to obtain the grid identifier of the base station location.

1.2.4 After-Sales Service: When you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account.

1.2.5 Permission Calls

a) Location Information Permission: Allow the app to obtain the terminal's geographic location information. Required for creating a power station, navigating to the power station location, and enabling Bluetooth scanning on specific versions of Android systems.

b) Bluetooth Permission: Allow the app to discover and connect to Bluetooth devices for WiFi configuration, and connect to Bluetooth devices via Bluetooth in local mode.

c) Phone Permission: Allow the app to make phone calls. The phone permission will be invoked when using the App's direct call function.

d) Media and File Storage Permission: Allow the app to read and write data in the mobile phone's storage space. The external storage permission is required when you upload photos from storage and record crash log information locally.

e) Notifications Permission: Allow the app to send notifications. The notification permission is required when enabling push notifications for device alarms.

f) Camera Permission: Allow the app to activate the camera for taking photos. Required when you upload a power station cover, upload power station photos, upload photos for work order processing reports, upload/replace your avatar, upload/replace your merchant logo, or scan the collector's QR code.

1.3 According to Article 6(1) of the GDPR, we may collect and use your personal information without your consent in the following circumstances:

a) where it is necessary for the performance of a contract to which the data subject is party;

b) where it is necessary for compliance with a legal obligation to which the controller is subject under EU or Member State law;

c) where it is necessary for the performance of a task carried out in the public interest;

d) where it is necessary in order to protect the vital interests of the data subject;

e) where it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

1.4 In order to ensure the security of our services, we may record information such as your frequency of using the application, crash data, overall usage, performance data, and the source of the application. We will not combine the information stored in the analytics software with any personally identifiable information you provide within the application.

1.5 If we use your personal information beyond the authorized purposes, we will notify you again and obtain your explicit consent before using your personal information.

1.6 Please understand that the functions and services we provide to you are constantly being updated and developed. If a function or service does not specify the rules for collecting and using your information in the above description, we will inform you separately of the scope, purpose, and method of information collection through page prompts, interactive programs, website announcements, or other means, and obtain your consent.

2. Cookie Usage Instructions (applicable to the official website)

2.1 What are Cookies

Cookies are small text files stored in your browser or device when you visit our website or use our services. They usually contain the website name, a unique identifier, and certain information, which can be read by the website or third-party services upon your subsequent visits.

2.2 What cookies we use

We use cookies and similar technologies to implement the basic functions of the website, including multi-language settings, login type determination, third-party login, and device history data retrieval. Some cookies are set by third-party service providers for analyzing access conditions.

3. Information Storage

3.1 Location of information storage

To better comply with data protection laws and safeguard personal data, we have established multiple data centers worldwide for data storage. We will access and store your information and data based on the country/region you select. For example, if you are located in the European Economic Area, your data will be stored in our data center in Germany. If personal data from the European Economic Area, Switzerland, or the United Kingdom is transferred to a country or region that has not been recognized by the European Commission as providing an adequate level of data protection, we will ensure that such transfers are appropriately safeguarded through the European Commission's approved Standard Contractual Clauses and, where necessary, other suitable technical measures.

3.2 Retention period of information

In general, we will retain your personal information for a period necessary to achieve a specific purpose, for example:

Phone number or email address: During your use of the mySunPan services, we will retain your phone number or email address to ensure your normal use of the services. Such information will be deleted along with the deletion of your mySunPan account.

Plant information: When you create a plant, we need to retain your plant information to ensure that you can normally use the monitoring function. When you delete your plant information, we will delete the corresponding information simultaneously.

If we cease to provide our products or services, we will notify you and delete or anonymize your personal information within a reasonable period, generally within 30 days and no later than 60 days.

4. Information Security

We are committed to protecting users' information against theft, misuse, unauthorized access, or disclosure.

We will use various security protection measures within a reasonable security level to safeguard the security of information. For example, we will use encryption technologies (such as SSL/TLS), de-identification, and anonymization to protect your personal information.

In terms of information security, the mySunPan version has met and obtained ISO27001 and ISO27701 information security management system certifications.

We will take all possible technical and organizational measures to protect your information, but we cannot guarantee that our measures will eliminate all security risks.

5. Explanation of Cross-Border Data Usage

To better serve our global users, we connect to the corresponding data centers based on the user's region to ensure the security and compliance of data access.

1. Purpose of connection: To ensure the security of storage and transmission of overseas users' data, the data of overseas users will be processed through data centers intelligently selected according to their location.

2. Method of connection: The application will connect to the corresponding servers through encrypted channels to safeguard data security.

3. Scope of connection: Overseas IP connections are used solely to meet the data needs of overseas users.

6. Information Sharing

In order to ensure the realization of certain independent functions and enable you to use and enjoy more services and functions, we will embed third-party SDKs in the application. For more information on the purposes, methods, and scope of personal information processing by SDKs, please refer to the Third-Party Sharing List.

As our business continues to develop, Sunwoda may undergo mergers, divisions, or other transactions. If this involves the transfer of personal information, we will inform you of the relevant situation and continue to protect, or require the new processor to continue protecting, your personal information.

7. Your Rights

7.1 Right of Access: You have the right to request access to your personal data held by us at any time and to understand how we collect, use, and process your information.

7.2 Right to Data Portability: You have the right to obtain a copy of your personal data held by us and receive such data in a structured, commonly used, and machine-readable format.

7.3 Right to Erasure: You have the right to request us to delete your personal data.

7.4 Right to Rectification: You have the right to request us to correct any inaccurate or incomplete personal data.

7.5 Right to Withdraw Consent: You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

7.6 Right to Lodge a Complaint: If you are dissatisfied with any of our actions, you can choose to lodge a complaint with Sunwoda, and you also have the right to lodge a complaint with the relevant data protection supervisory authority.

7.7 Right to Restrict Processing: Under certain circumstances, you have the right to request us to restrict the way we process your personal information.

7.8 Right to Object: You have the right to object at any time, on grounds relating to your particular situation, to our processing of your personal data based on legitimate interests.

8. Revisions

This policy may be updated, revised, modified, or changed periodically as needed. If any terms are updated, changed, or revised in this policy, we will display the modified policy to you via push notifications, pop-up windows, or other means when you log in to mySunPan or when the application version is updated.

9. Other Matters

In certain specific services or functions of mySunPan, we may inform you of the purpose, method, or scope of personal information processing through interactive texts, product interfaces, or pop-up windows.

10. Contact Us

We have established a dedicated personal information protection team. If you have any questions, complaints, or suggestions about this Privacy Policy or personal information protection, you can contact us through any of the following methods:

(1) Phone: +49 911 748992-30

(2) Email: Service.de@sunwoda.com

(3) Data Protection & Compliance Department: compliance@sunwoda.com

We will review the issue as soon as possible and respond within 30 days upon receipt of your request or complaint feedback. The subsequent processing period usually does not exceed 90 days.