Privacy Policy | Solar Systems Philippines, Inc.

SSPI’s Privacy Policy

outlines how we collect, use, disclose, and protect your personal information in accordance with applicable data protection laws. By engaging with our services, you agree to the terms set forth in this policy.

SSPI’S PRIVACY POLICY
- 1.1 Our Commitment to Your Privacy. SSPI, including its subsidiaries, brands, and related entities where applicable (collectively referred to as “SSPI,” “we,” “us,” or “our”), values your privacy and is committed to safeguarding your personal data in line with applicable data protection and privacy laws. This Privacy Policy (the “Policy”) outlines how SSPI collects, uses, and processes personal data when you engage with our digital services, which include mobile apps, products, features, software, and technologies offered by SSPI from time to time (collectively, the “Platforms”). The services delivered through these Platforms are referred to as the “Services.”
- 1.2 What This Policy Covers. This Policy explains the types of personal data we collect and how we handle it. We encourage you to read this Policy carefully to understand:
  - (a) what information we collect and the reasons for collecting it;
  - (b) how we use that information;
  - (c) how we protect your information; and
  - (d) how you can manage, update, or restrict the use of your data.
- 1.3 Applicability. In this Policy, “you” and “your” refer to the user of our Services or Platforms. If you are using our Services on behalf of a business, organization, or other legal entity:
  - (a) “you” refers to both you and the entity;
  - (b) you confirm that you are authorized to represent and bind the entity to this Policy; and
  - (c) your organization assumes responsibility for your use of our Services and any related accounts, including those used by employees, agents, or contractors.
- 1.4 Consent and Acknowledgment. By using our Platforms, interacting with us, or accessing our Services, you acknowledge and agree to the practices detailed in this Policy (as may be updated from time to time). You also consent to our collection, use, disclosure, and processing of your personal data as described.
- 1.5 Policy Updates. SSPI may revise this Policy occasionally to reflect legal, technological, or operational changes. If significant changes occur—such as sharing your data in ways not previously consented to—we will notify you via our Platforms. We encourage you to check our Platforms regularly for the latest updates.

INFORMATION WE COLLECT
- 2.1 Definition of Personal Data. “Personal Data” or “Personal Information” refers to data that can identify an individual, either:
  - (a) directly from that data, or
  - (b) from that data combined with other accessible information.
- 2.2 Types of Data Collected. We collect personal data through direct interactions and automatically during your use of our Services and Platforms. This includes:
  - (a) Data You Provide. When you create an account, purchase Services, or interact with our Platforms.
  - (b) Data from Platform Usage. Information collected includes, but is not limited to:
    - (i) Device Information (e.g., model of your device, OS version, unique identifiers, mobile network details).
    - (ii) Log Data (e.g., how long you used our Services, bandwidth used, IP address, error reports, cookies).
    - (iii) Payment Information (e.g., transactions and purchase history).
    - (iv) Customer Support (e.g., forms and communication regarding support or inquiries).
    - (v) Location Data (e.g., real-time GPS-based location when using location-enabled features).
- As we continuously improve our Services, we may introduce new features that involve additional data collection. We will update this Policy accordingly and inform users as needed.
- 2.3 Children’s Data. SSPI does not knowingly collect data from individuals under the age of 18. If you are a parent or guardian aware that your child has submitted personal data without your consent, please contact our Data Protection Officer. We will take appropriate steps to delete such data.

HOW WE USE YOUR PERSONAL DATA
- 3.1 Collection Methods. We collect data when:
  - (a) you access or use our Services;
  - (b) you request information or subscribe to our communications;
  - (c) you fill out forms related to our Services;
  - (d) you voluntarily submit personal data for any reason.
- Ensure your submitted data is accurate to help us provide our Services effectively.
- 3.2 Purpose of Use. We use your data for legitimate business reasons, including:
  - (a) verifying your identity;
  - (b) managing your requests and feedback;
  - (c) analytics and system reporting;
  - (d) fulfilling Services and operational needs;
  - (e) compliance with laws and regulations;
  - (f) tailoring our content to your preferences;
  - (g) sending relevant updates and marketing (where consented);
  - (h) fulfilling contractual obligations;
  - (i) handling disputes and enforcing rights;
  - (j) notifying you of service or policy changes;
  - (k) processing payments;
  - (l) enhancing security and safety;
  - (m) conducting market research;
  - (n) marketing and promoting SSPI and its services;
  - (o) personalizing your experience based on preferences.
- 3.3 Non-Exhaustive. The above list is representative but not exhaustive.
- 3.4 Aggregate Data Use. We may share anonymized or aggregated user data with partners, advertisers, or affiliates for analysis or marketing purposes.
- 3.5 Continued Use. Even if you cease using our Services, we may retain and use your data for a reasonable period for legal or operational reasons.

DATA STORAGE AND TRANSFER
- 4.1 Data Locations. Personal Data may be stored and processed in Singapore or other jurisdictions where SSPI or its service providers operate.
- 4.2 Third-Party Storage. Data may be stored or processed by third-party providers under SSPI’s instructions, located in or outside Singapore.
- 4.3 Cross-Border Transfers. Transfers will be conducted with safeguards in place, including contractual clauses and adherence to data protection laws.
- 4.4 Your Consent. By using our Services, you consent to such transfers and processing of your data.
- 4.5 Retention. Your data will be retained only as long as necessary for its intended purpose, unless required by law. Once no longer needed, it will be deleted or anonymized.

YOUR RIGHTS
- 5.1 Access and Correction. You may request access to or correction of your personal data. We may charge a fee for access, and some requests may be lawfully declined. If so, we will inform you of the reason.
- 5.2 Withdrawing Consent. You may withdraw consent for the use of your data. However, this may affect your ability to access our Services.
- 5.3 External Policies.
  - (a) When using our Services in conjunction with third-party charging stations, you agree to the respective third-party privacy policies.
  - (b) Our Platforms may link to third-party sites. We are not responsible for their privacy practices. Please review their policies before sharing data.

DISCLOSURE OF DATA
- 6.1 Who We Share With. Subject to applicable laws, your data may be disclosed to:
  - (a) SSPI Affiliates
  - (b) Service Providers (e.g., hosting, IT, support)
  - (c) Business Partners (e.g., platform or service operators)
  - (d) Advertisers (e.g., to serve relevant ads)
  - (e) Within Our Group (e.g., parent companies, subsidiaries)
  - (f) In Business Transactions (e.g., M&A, restructuring)
  - (g) Legal Authorities (e.g., in compliance with legal obligations)
  - (h) Other Legitimate Uses tied to business operations.

DATA SECURITY
- 7.1 Safeguarding Measures. We implement appropriate security protocols to prevent unauthorized access or breaches. If a breach occurs, we will notify affected users promptly.
- 7.2 Internet Risks. While we work to secure your data, internet transmissions are inherently risky. Use of our Services involves such risks.
- 7.3 Complaints. We address data protection complaints promptly. You may also raise concerns with local data protection authorities.

COOKIES
- 8.1 Use of Cookies. SSPI may use cookies or similar technologies to enhance functionality, performance, and personalization.
- 8.2 What Are Cookies. These are small files stored on your device to improve navigation and track usage.
- 8.3 Why We Use Cookies. Cookies help us understand usage trends, deliver tailored content, and troubleshoot technical issues.
- 8.4 Your Choices. You can manage cookies through browser settings. However, disabling them may limit your access to some features.
- 8.5 Transparency. We aim to give you control and clarity over your data. Review your browser settings to adjust your cookie preferences as needed.