Solar Engine Privacy Policy

March 13, 2024

Solar Engine entities (for purpose of applicable data protection laws, Solar Engine entities providing Solar Engine Service which are subject to applicable disclosure requirements can be viewed HERE collectively, “Solar Engine”, or “we”, “us”, “our”) provide this privacy policy to explain how we collect, use, and share information. This privacy policy (“Policy”) covers Solar Engine’s handling of two types of information:

1.Information we receive when we provide our service, including: (1) device information about end Users we collect through our software development kit (“SDK”), application programming interface (“API”), our platforms, services or technologies from data supply partners such as mobile application developers, ad attribution platforms, mediation platforms, ad networks; (2) information about end Users’ interaction with ads collect through our SDK, API or other technologies, or collected and transferred to us by our Business Partners (e.g. mobile app developers, hereinafter referred to as “Business Partners”) or any third party designated by them; (3) device information generated during end Users’ use of our Business Partners’ mobile apps, websites, platforms or services and information collected and transferred to us by our Business Partners or any third party designated by them; (4) information provided by Business Partners when they use Solar Engine’s platforms, technologies, services. In the Privacy Policy of the Solar Engine Services, the end Users mentioned in this section are collectively referred to as “User”, “you” or “your”; the SDK, API, any technology, platform or service provided by Solar Engine mentioned in this section are referred to as “Solar Engine Service”. Please click on the following link to access detail about Protection for Minors under the process of collecting this type of information.

2.Information we receive through the following websites from website visitors (hereinafter referred to as “Visitors”, “you” or “your”) in the Privacy Policy of Solar Engine Website: (1) our website at: https://www.solar-engine.com/ or any other website on which this Policy is posted, as well as (2) any website we provide to Business Partners or potential clients in order to provide our services. Please click on the following link to access detail about Protection for Minors under the process of collecting this type of information.

This Policy is subject to any service agreement between Solar Engine and you. By using the Solar Engine Service or Solar Engine Site, you acknowledge that you have read, understood and agreed to this Policy. Please review this Policy before using the Solar Engine Service or the Solar Engine Site.

We evaluate this Policy and procedures to implement improvements and refinements from time to time.

Data protection and ensuring our Business Partners’ and your trust is at the core of Solar Engine’s business principles. Accordingly, being compliance with applicable data protection laws is our top priority and this Policy is updated to be compliance with the applicable data protection laws, including but not limited to the EU General Data Protection Regulation (“GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the California Customer Privacy Act (“CCPA”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Utah Consumer Privacy Act (“UCPA”) and any personal information protection law announced by Chinese governments(“PIPL”).

For the purpose of this Policy, “Processor” means an “entrusted handler” under the PIPL, a “processor” under the GDPR,VCDPA,CPA,CDPA and UCPA, and a “service provider” under the CCPA. “Controller” means a “personal information handler” under the PIPL, a “controller” under the GDPR,VCDPA,CPA,CDPA and UCPA, and a “business” under the CCPA.

Privacy Policy of the Solar Engine Services

1.Introduction

This Policy describes Solar Engine’s information collection and use while (1) Users view ads provided by Business Partners; (2) Users interact with platforms, applications, websites or other services provided by Business Partners; (3) Business Partners interact with Solar Engine Services.

Solar Engine provides Business Partners with Attribution, ROI Analysis, User Analysis, A/B Testing, Live-ops and other advertising data statistical analysis and strategy validation related services. For the purpose of providing Solar Engine Services to our Business Partners, our Business Partners will entrust us to collect and use information related to Users. We understand how important it is to keep such User’s personal information confidential and discrete, especially in today’s online world. To this end, we have designed this Policy in a format that is easy to navigate and read so that our privacy practices can be clearly understood.

Unless explicitly stated otherwise in this Policy, we act as a Processor when providing Solar Engine Services. We strictly adhere to the processing purposes and methods entrusted to us by our Business Partners when processing your personal information. As Controller, our Business Partners independently determine the purposes and methods for processing your personal information.

The Solar Engine Services may link to third party websites, Apps or other third party content. Please note that we cannot control the treatment of a User’s information by such third parties, and that the privacy practices of third parties likely differ from those described in this Policy.

2.How We Collect Users’ Information

Depending on the nature of a User’s interaction with the Solar Engine Services, or any service provided by our Business Partners, we may collect information directly from such User or from our Business Partners. For example: (1) when we embed SDKs in our Business Partners' mobile applications, we may collect information about Users using such mobile applications through the SDKs Business Partner; (2) our Business Partners may share User information with us; (3)when we access third-party platforms (e.g. ad networks,, mediation platforms, monetization platforms, attribution platforms) based on the authorization and/or delegation of our Business Partners, the third-party platform may share with us information about the Users related to our Business Partners with us.

In the process of providing Solar Engine Services, we have no direct contact with Users and are not involved in determining the purpose or method of the handling of Users’ personal information. Our Business Partners (e.g. mobile application developers who use our SDKs, as Personal Information Processors, shall be solely responsible for obtaining valid consent from Users for the collection and use of personal information.

In order to provide Solar Engine Services to our Business Partners, we may collect information from their business representatives through our Business Partners. Our Business Partners will be responsible for obtaining valid consent from their business representatives regarding our collection and use of their personal information as a Personal Information Processor.

With respect to the collection of personal information and the obtaining of valid consent as described above, we have required in our cooperation agreements with Solar Engine's Business Partners that they commit to and guarantee the legitimacy of the data source, and they will inform Users of the specifics of our processing of personal information as required by applicable law and obtain valid consent from Users (obtaining separate consent as required by applicable law if necessary), and guarantee that Users can revoke such consent at any time.

3.Information We May Collect From Users

When you use the Solar Engine Services as a representative of our Business Partner, we, as a Controller, may collect your name, contact phone number, e-mail address, contact address, as well as your user name, password, and IP address when you visit the Solar Engine website for the purposes of business relationships, direct marketing (e.g., to send marketing emails), and to verify your identity when you log in to the Solar Engine website and our affiliates' websites.

When you browse the advertisements or use the services provided by our Business Partners, we may collect your personal information and/or receive your personal information from our Business Partners on their behalf. The types of personal information required and the system permissions needed to implement various modules of the Solar Engine services are listed below: When you browse the advertisements provided by Solar Engine's Business Partners or use the services provided by Solar Engine's Business Partners, we may collect your personal information on behalf of our Business Partners and/or receive your personal information from our Business Partners. The following is the types of personal information that may be collected and the system permissions that may be required to implement each of the functional modules of Solar Engine Services.

(1) Attribution Service

a.When our Business Partners integrate the Solar Engine SDK into their application or use the Solar Engine API, our Business Partners' applications will collect and transmit relevant personal information to us via the Solar Engine SDK or API through technical means. This may include the following types: IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/ts/account id/IMEI2/OAID/UA/language/time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device type/network type/application version/application version code/package name/application name/channel name/browser/browser version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ADServiceToken/device screen density/install referrer /referrer click timestamp seconds/install begin timestamp seconds/ referrer click timestamp server seconds/install begin timestamp server seconds/install version/google play instant, etc. The specific types are subject to actual transmission by our Business Partners. Solar Engine acts as a Processor in the Attribution Service and does not determine the specific type of information being collected.

b.When our Business Partners connect Solar Engine to their designated third-party platforms (e.g.ad networks, mediation platforms, monetization platforms) via APIs or other similar means, their designated third-party platforms will transmit your relevant personal information to us. This may include the following types: OAID/IMEI1/IMEI2/GAID/AMAZONID/MAC/AndroidID/device brand/activation time/IDFV/IDFA/operating system/device model/IPV4/IPV6/UA, etc. The specific types are subject to actual transmission by the designated third-party platforms by our Business Partners. Solar Engine acts as a Processor in the Attribution Service and does not determine the specific type of information being collected.

c.System permissions that Solar Engine Attribution Service may need to request from you include: internet/access network state/access wifi state/write external storage/read external storage/read phone state/ATT, etc.

(2) ROI Analysis Service

a.When our Business Partners integrate the Solar Engine SDK into their application or use the Solar Engine API, our Business Partners' applications will collect and transmit relevant personal information to us via the Solar Engine SDK or API through technical means. This may include the following types: IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/ts/account id/IMEI2/OAID/UA/language/time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device type/network type/application version/application version code/package name/application name/channel name/browser/browser version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ADServiceToken/device screen density, etc. The specific types are subject to actual transmission by our Business Partners. Solar Engine acts as a Processor in the ROI Analysis Service and does not determine the specific type of information being collected.

b.When our Business Partners connect Solar Engine to their designated third-party platforms (e.g. ad networks, mediation platforms, monetization platforms, attribution platforms) via APIs or other similar means, their designated third-party platforms will transmit your relevant personal information to us. This may include the following types: operating system/package name/IMEI/GAID/AMAZONID/AndroidID/OAID/IDFV/IDFA/IPUA/device brand/country code/device model/language/operating system version, etc. The specific types are subject to actual transmission by the designated third-party platforms by our Business Partners. Solar Engine acts as a Processor in the ROI Analysis Service and does not determine the specific type of information being collected.

c.System permissions that Solar Engine ROI Analysis Service may need to request from you include: internet/access network state/access wifi state/write external storage/read external storage/read phone state/ATT, etc.

(3) User Analysis Service

a.When our Business Partners integrate the Solar Engine SDK into their application or use the Solar Engine API, our Business Partners' applications will collect and transmit relevant personal information to us via the Solar Engine SDK or API through technical means. This may include the following types: IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/ts/account id/IMEI2/OAID/UA/language/time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device type/network type/application version/application version code/package name/application name/channel name/browser/browser version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ADServiceToken/device screen density, etc. The specific types are subject to actual transmission by our Business Partners. Solar Engine acts as a Processor in the User Analysis Service and does not determine the specific type of information being collected.

b.When our Business Partners connect Solar Engine to their designated third-party platforms (e.g.ad networks, mediation platforms, monetization platforms, attribution platforms) via APIs or other similar means, their designated third-party platforms will transmit your relevant personal information to us. This may include the following types: OAID/IMEI1/IMEI2/GAID/AMAZONID/MAC/AndroidID/device brand/activation time/IDFV/IDFA/operating system/device model/IPV4/IPV6/UA/country code/language/operating system version, etc. The specific types are subject to actual transmission by the designated third-party platforms by our Business Partners. Solar Engine acts as a Processor in the User Analysis Service and does not determine the specific type of information being collected.

c.System permissions that Solar Engine User Analysis Service may need to request from you include: internet/access network state/access wifi state/write external storage/read external storage/read phone state/ATT, etc.

(4) A/B Testing Service

a.When our Business Partners integrate the Solar Engine SDK into their application or use the Solar Engine API, our Business Partners' applications will collect and transmit relevant personal information to us via the Solar Engine SDK or API through technical means. This may include the following types: IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/ts/account id/IMEI2/OAID/UA/language/time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device type/network type/application version/application version code/package name/application name/channel name/browser/browser version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ADServiceToken/device screen density, etc. The specific types are subject to actual transmission by our Business Partners. Solar Engine acts as a Processor in the A/B Testing Service and does not determine the specific type of information being collected.

b.When our Business Partners connect Solar Engine to their designated third-party platforms (e.g.ad networks, mediation platforms, monetization platforms, attribution platforms) via APIs or other similar means, their designated third-party platforms will transmit your relevant personal information to us. This may include the following types: OAID/IMEI1/IMEI2/GAID/AMAZONID/MAC/AndroidID/device brand/activation time/IDFV/IDFA/operating system/device model/IPV4/IPV6/UA/country code/language/operating system version, etc. The specific types are subject to actual transmission by the designated third-party platforms by our Business Partners. Solar Engine acts as a Processor in the A/B Testing Service and does not determine the specific type of information being collected.

c.System permissions that Solar Engine A/B Testing Service may need to request from you include: internet/access network state/access wifi state/write external storage/read external storage/read phone state/ATT, etc.

(5) Live-ops Service

a.When our Business Partners integrate the Solar Engine SDK into their application or use the Solar Engine API, our Business Partners' applications will collect and transmit relevant personal information to us via the Solar Engine SDK or API through technical means. This may include the following types: IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/ts/account id/IMEI2/OAID/UA/language/time zone/manufacturer/operating system version/screen height/screen width/device model/device name/device type/network type/application version/application version code/package name/application name/channel name/browser/browser version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ADServiceToken/device screen density, etc. The specific types are subject to actual transmission by our Business Partners. Solar Engine acts as a Processor in the Live-ops Service and does not determine the specific type of information being collected.

b.When our Business Partners connect Solar Engine to their designated third-party platforms (e.g.ad networks, mediation platforms, monetization platforms, attribution platforms) via APIs or other similar means, their designated third-party platforms will transmit your relevant personal information to us. This may include the following types: OAID/IMEI1/IMEI2/GAID/AMAZONID/MAC/AndroidID/device brand/activation time/IDFV/IDFA/operating system/device model/IPV4/IPV6/UA/country code/language/operating system version, etc. The specific types are subject to actual transmission by the designated third-party platforms by our Business Partners. Solar Engine acts as a Processor in the Live-ops Service and does not determine the specific type of information being collected.

c.System permissions that Solar Engine Live-ops Service may need to request from you include: internet/access network state/access wifi state/write external storage/read external storage/read phone state/ATT, etc.

4.About Sensitive Personal Information

Sensitive personal information refers to personal information that, once leaked or illegally used, will easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person. The scope of sensitive personal information may vary pursuant to different applicable data protection law.

We will not collect your sensitive personal information without your consent. Our Business Partner will transmit or authorize us to process your sensitive personal information after notifying you the necessity of processing your sensitive personal information and the impact of your rights and interests with your consent.

5.How We Use Users’ Personal Information

We use your personal information in the following manner:

Type of Personal Information		Usage
User Information	Including all types of personal information described in paragraphs (1) of Article 3 of this Policy	Solar Engine Attribution Service: As a Processor, we assist our Business Partners in understanding the source of each conversion within their applications by matching and analyzing advertising impressions, clicks, and other data from media channels designated by our Business Partners with conversion performance data from the Business Partners so that they can further optimize the effectiveness of advertising campaigns.
	Including all types of personal information described in paragraphs (2) of Article 3 of this Policy	Solar Engine ROI Analysis Service: As aProcessor, we assist our Business Partners in data management, calculation, analysis, and optimization operations by integrating campaign, monetization, attribution, and key behavior data.
	Including all types of personal information described in paragraphs (3) of Article 3 of this Policy	Solar Engine User Analysis Service：As a Processor, we present data conclusions derived from analytical models in the form of visualized reports, assisting our Business Partners in achieving real-time metric monitoring and data-driven business operations.
	Including all types of personal information described in paragraphs (4) of Article 3 of this Policy	Solar Engine’s A/B Testing Service：As a Processor, we analyze user feedback data by providing multiple control groups for our Business Partners, assisting them in optimizing product strategies.
	Including all types of personal information described in paragraphs (5) of Article 3 of this Policy	Solar Engine’s Live-ops Service：As a Processor, we assist our Business Partners by providing the capability to dynamically modify application content on the server side, helping them reduce development costs.
Business Representative Information	name/contact phone number/e-mail address/contact address/user name, password, and IP address used when accessing Solar Engine website	As a Controller, we use this personal information for the purposes of business relationships, direct marketing (e.g., to send marketing emails), and to verify your identity when you log in to the Solar Engine website and our affiliates' websites.
Sensitive Personal Information	/	We will not collect your sensitive personal information without your consent. Our Business Partners will transmit or entrust us to process your sensitive personal information after notifying you the necessity of processing your sensitive personal information and the impact of your rights and obtaining your consent.

6.The Legal Basis for Our Processing of Users' Personal Information

(1)Consent. Where required by applicable laws, We have contractually agreed that our Business Partners (e.g. developer of mobile applications integrated with Solar Engine’s SDK) will obtain consent of a User or their employees for and on our behalf for our processing of his/her personal information described in this Policy. A data subject can withdraw their consent at any time.

(2)According to the laws and regulations, the following are exceptions to obtaining the consent of the User:

a.Necessary for the conclusion and performance of a contract with the data subject;

b.Necessary to fulfill our legal obligations;

c.Necessary to respond to a public health emergency, or to protect the life, health, and property of the data subject in an emergency;

d.For the implementation of news reporting, public opinion monitoring and other acts in the public interest, within a reasonable range of the handling of end-user personal information;

e.In accordance with the provisions of applicable laws within a reasonable range to process the personal information disclosed by the data subject himself/herself or other personal information which has been lawfully disclosed.

(3)If you are located in the European Economic Area, we may use your personal information based on the "legitimate interests" set forth in the GDPR, in necessary cases. Our legitimate interests include: monitoring and preventing fraudulent activity, remove technical obstacles to system operation and ensuring systems and processes work properly and securely.

7.How We Share, Entrust the Processing, Transfer, Disclose And Transmit Users’ Personal Information

(1)Sharing

We may share personal information collected by us with third parties for the following purposes and scenarios：

Solar Engine Service Modules	Type of Third Parties	Type of Information	Processing Purpose and Processing Method	Information of Third Parties
Attribution Service	Our Business Partners and their designated third-party platforms such as ad networks	IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/TS/ Account ID/IMEI2/OAID/UA/ Language/Device Time Zone/Manufacturer/Operating System Version/Screen Height/Screen Width/Device Model/Device Name/Device Type/Network Type/Application Version/Application Version Code/Package Name/Application Name/Channel Name/Browser/Browser Version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ ADServiceToken/Device Screen Density, etc. The specific information types are subject to the actual requirements of our Business Partners.	Used for settlement purposes and optimization algorithms on behalf of our Business Partners and their designated third-party platforms such as ad networks. The specific purposes are determined independently by our Business Partners.	See the List of Third Parties for details
User Analysis Service	our Business Partners	IMEI/Android ID/IDFA/IDFV/GAID/AMAZONID/TS/ Account ID/IMEI2/OAID/UA/ Language/Device Time Zone/Manufacturer/Operating System Version/Screen Height/Screen Width/Device Model/Device Name/Device Type/Network Type/Application Version/Application Version Code/Package Name/Application Name/Channel Name/Browser/Browser Version/ page title/ page name/referrer title/referrer name/distinct id/upt/out/lat status/ ADServiceToken/Device Screen Density, etc. The specific information types are subject to the actual requirements of our Business Partners.	Used for data accuracy verification, internal analysis, etc. The specific purposes are determined by our Business Partners.	See the List of Third Parties for details
All functional modules	Solar Engine Affiliates	Name, e-mail address, and contact address of representatives of our Business Partners	Used for promoting products or services of our affiliates to business representatives of our Business Partners, as well as for identity verification when our Business PartnerBusiness Partners log in to the Solar Engine website and our affiliates’ websites.	See the List of Solar Engine Affiliates for details.

Except as expressly stated in this Policy, we will not disclose Users’ personal information to any third-party without Users’ consent.

We have agreed with the Business Partners who have direct access to the User that the Business Partners will inform the User of the above-mentioned third-party information and obtain the User's separate consent.

We may also share aggregate or anonymous information with other third-parties in accordance with the terms of this Policy.

(2)Entrusted Processing

Type of Third Parties

Information of Third Parties

Type of Information

Processing Purpose and Processing Method

Cloud Service Providers

See the Cloud Service Providers for details

including all types of personal information described in Article 3 of this Policy

①for purpose of data storage.

②for responding to data computation and storage requests;

③for ensuring systems and processes work properly and securely

Except as expressly stated in this Policy, we do not entrust other third-parties with the processing of Users' personal information.

(3)Assignment

We will not transfer the User's personal information to any company, organization or individual, except in the following cases:

a.We inform the User in advance of the type, purpose, manner and scope of the transfer of personal information and obtain the User's separate consent;

b.In the event of a merger, separation, dissolution, bankruptcy, etc. that requires the transfer of personal information, we will inform the User of the name and contact information of the recipient and request the recipient to continue to perform the obligations of the processor of personal information. If the recipient changes the original purpose or method of processing, we will ask the recipient to obtain the User's consent again.

(4)Public Disclosure

We do not publicly disclose the personal information of end users, except in the following cases:

a.After informing the User of the type, purpose, manner and scope of the personal information to be publicly disclosed and obtaining the User's separate consent;

b.When compelled by laws, regulations, legal proceedings, litigation or government authorities.

(5)International Transfers

a.When you are located in the European Economic Area (“EEA”), personal information collected about you will be transferred to recipients in countries located outside the EEA or can be remotely accessed in countries located outside the EEA, including in countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. We have followed requirements as set out in applicable law to provide adequate protection to your personal data. To the extent as required by applicable law, our Business Partners will obtain your valid consent to the extent for us to transfer your personal information to recipients including Solar Engine’s affiliates and any other recipients as described in this Policy, which are located outside the EEA. You are entitled to withdraw your consent at any time.

Solar Engine has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information to its affiliates. You can request a copy of these Model Contracts by submitting your request via email to privacy@solar-engine.com

b.If you are located in the mainland of the People's Republic of China, the personal information we collect about you under this Policy will be stored in the mainland of the People's Republic of China. We will not transfer your personal information outside of the mainland of the People's Republic of China. If our Business Partners transfer your personal information overseas, they shall be solely responsible for fulfilling the compliance obligations related to data transfer. They should inform you of the name or identity, contact information, processing purposes, processing methods, types of personal information, and the ways and procedures for exercising your legal rights towards the overseas recipients. They should obtain your separate consent, fulfill the evaluation process as required by laws and regulations, and meet other conditions specified by applicable laws and regulations.

8.Your Data Rights

(1)If you are in the EEA, you have a right to (subject to a limited number of exceptions as permitted by GDPR):

a.request access to and rectification or erasure of your personal information;

b.obtain restriction of processing or to object to processing of your personal information; and

c.ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

(2)If you are residents of the State of California in the United States, you can request the following information about how we have collected and used your personal information during the past 12 months:

a.The categories of Personal Information we have collected.

b.The categories of sources from which we collected the Personal Information.

c.The business or commercial purpose for collecting, selling or sharing Personal Information.

d.The categories of third parties to whom we disclose the Personal Information.

e.The categories of Personal Information that we sold, shared or disclosed for a business purpose.

f.The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose.

Your Rights:

a.Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

b.You can ask us to correct inaccuracies of your Personal Information.

c.You can ask us to delete the Personal Information that we have collected from you.

You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

You may (i) submit requests to exercise your California privacy rights described above by writing to us at: privacy@solar-engine.com or send a written document to the following address: Legal Department, 10th Floor, Building A, Beichen Century Center, No. 8 Tianchen West Road, Chaoyang District, Beijing, China; (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA and (iii) submit requests to restrict the use of your sensitive personal information by writing to us at: privacy@solar-engine.com.

(3)If you are a resident of the State of Virginia in the United States, effective January 1, 2023, you may exercise the following personal information rights with us.

a.To confirm whether we are processing your personal information and to access that personal information;

b.To correct any inaccuracies in your personal information;

c.To delete your personal information;

d.To obtain a copy of the personal information you have provided to us; and

e.To request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has significant legal or similar implications for you.

As set forth in the VCDPA, you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@solar-engine.com and (ii) click on the following link DO NOT SELL MY DATA to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@solar-engine.com.

(4)If you are a resident of the State of Colorado in the United States, effective July 1, 2023, you may exercise the following personal information rights with us.

a.To confirm whether we are processing your personal information and to access that personal information;

b.To correct any inaccuracies in your personal information;

c.To delete your personal information;

d.To obtain a copy of the personal information you have provided to us; and

As set forth in the Colorado, you have the right to exercise the above rights without discrimination.

(5)If you are a resident of the State of Connecticut in the United States, effective July 1, 2023, you may exercise the following personal information rights with us.

a.To confirm whether we are processing your personal information and to access that personal information;

b.To correct any inaccuracies in your personal information;

c.To delete your personal information;

d.To obtain a copy of the personal information you have provided to us; and

As set forth in the CDPA, you have the right to exercise the above rights without discrimination.

(6)If you are a resident of the State of Utah in the United States, effective December 31, 2023, you may exercise the following personal information rights with us.

a.To confirm whether we are processing your personal information and to access that personal information;

b.To delete your personal information;

c.To obtain a copy of the personal information you have provided to us; and

d.To request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information.

As set forth in the UCPA, you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@solar-engine.com. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@solar-engine.com.

(7)If you are in the mainland areas of China, you have the following rights related to your personal information except when laws and administrative regulations otherwise provide.

a.Right to be informed, right to decide and right to restrict or refuse processing of your personal information.

b.Right to access and copy your personal information except in special circumstance provided by law.

c.Right to request to transfer your personal information to another data handler.

d.Right to request to revise and supplement your personal information when you notice that the personal information we process is inaccurate or incomplete.

e.Right to delete your personal information in the following circumstances:

(ⅰ)Where the purpose of processing has been achieved or is unable to be achieved, or the personal information is no longer necessary for achieving the purpose of processing;

(ⅱ)Where Solar Engine ceases the provision of its product or service involved, or the retention period has expired;

(ⅲ)Where consent is withdrawn by the User;

(ⅳ)Where the processing of personal information by Solar Engine is in violation of any law, administrative regulations or any agreement; or

(ⅴ)Any other circumstance as provided by law or administrative regulations.

(ⅵ)If it is technically difficult to delete the personal information, Solar Engine shall cease the processing of the personal information, except for the storage and any necessary measure taken for security protection.

f.You have the right to request an explanation of this Policy.

You can contact us via privacy@solar-engine.com and request your data rights.

When you revoke your consent, we will cease the processing of your personal information. It is important to note that this decision will not retroactively impact the processing of personal information that occurred prior to the revocation of your authorization.

9.Security of Users’ Personal Information

The security of User’s information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User’s information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means. We will establish a dedicated security team, security management system, and data security process to safeguard the security of your personal information. We adopt a strict data use and access system to ensure that only authorized personnel have access to your personal information, and conduct security audits of data and technology when appropriate. We will develop emergency handling plans and activate them immediately in the event of a User information security incident, in an effort to prevent the expansion of the impact and consequences of such security incidents. Once a User information security incident (leakage, loss, etc.) has occurred, we will promptly inform you in accordance with the requirements of laws and regulations.

We also protect User’s privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of User data.

At present, Solar Engine has passed the national information security level protection (Level 3) assessment and record, and passed the international authoritative ISO27001 information security certification and the independent third-party audit on SOC 2 Type 2, which means that Solar Engine provide comprehensive privacy protection for customers and end-device Users.

Solar Engine may retain the information relating to you collected from our Business Partners as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). We will only retain your personal information for as long as necessary and the personal information retention periods shall be the shortest period necessary to realize the purpose of the personal information handling. We generally retain personal information collected in accordance with this Policy for a period not exceeding 2 years. The criteria used to determine the retention periods include: (1) how long the personal data is needed to provide the services and operate the business; (2) the type of personal data collected; and (3) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, data that must be retained for the purposes of litigation or disputes, or data retention periods contractually required by our Business Partners).

10.Protection for Minors

Solar Engine’s service is not mainly for minors. If a User is deemed as minor under applicable law, please make sure that before the use of the application which integrates Solar Engine’s product or service, parents or other guardian and such User have together read the application’s privacy policy and this Policy with the guardianship and guiding of parents or other guardian, and their consent have been provided for using the application or processing of personal information.

We process minor’s personal information according to requirements of related laws and regulations. Except as otherwise provided by law, we will only collect, use, store, share, or publicly disclose the personal information where permitted by law, with consent of parents or other guardians, or for the necessity of protection of the minors. If we notice the collection of personal information of minors without verifiable consent of parents, we will take measures to delete related information as soon as possible.

If you are parents or other guardian of minors, please contact us via privacy@solar-engine.com, when you have any question regarding to the protection of minors.

If you are Users in the U.S., we ensure that we comply with COPPA. If our Business Partners (such as mobile application developers) operate apps directed to children under the age of thirteen [13] or knowingly collect, use or disclose personal information of children under the age of thirteen [13] during our cooperation, they will obtain verifiable parental consent for Solar Engine to collect, use or disclose such personal information according to this Policy. This allows Solar Engine to ensure that any personal information collected about such applications will be processed according to the requirements of COPPA. In addition, we will not knowingly collect any other personal information (such as the precise geo-location of Users’ devices) from Users of Apps that we know to be directed to children under the age of thirteen [13].

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

11.Marketing

If you are our Business Partners, we or our affiliates may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to privacy@solar-engine.com.

12.Contact Us

If you are located in mainland China, you can (i) send a written request to privacy@solar-engine.com or （ii）send written documents to the following address: Legal Department, 10th Floor, Building A, Beichen Century Center, No. 8 Tianchen West Road, Chaoyang District, Beijing, China.

If you are located outside mainland China, you can contact our DPO by sending a written request to privacy@solar-engine.com.

Due to the rapidly evolving technologies on the Internet, we may occasionally update this Policy. All revisions will be posted to this website https://www.solar-engine.com/

Privacy Policy of Solar Engine Website

1.Introduction

This Privacy Policy of Solar Engine Website applies to information collection and use including while you are visiting and using the Solar Engine Site. Solar Engine is the Personal Information Processor of your personal information.

2.What Information We Collect

As you navigate through this Solar Engine Site, we may collect information include:

(1)personal information you voluntarily provide (for example, names, telephone numbers, E-mail addresses, industry, company name, position, regions and other related information);

(2)some information that are not voluntarily provided such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, Cookies, Internet Tags and navigational data collection.

Solar Engine is entitled to take measures to validate the authenticity of personal information you provide.

If you give us personal information of somebody else, you should warrant that you have gained their permission to do so.

If you are located in mainland China, we may use the Baidu Statistics Service provided by Baidu.com to help us analyze our website usage and help improve the quality of our website services. For more information about the information collected by Baidu's statistical services and its data processing activities, please visit: Here.

If you are located outside of mainland China, We may also use Google Analysis that assists us with analyzing the usage of our website and help to improve the service quality of our website. For the personal information that may be collected by Google Analysis and its processing activities, please visit: Here.

3.How We Use Your Information

Based on your consent or based on our legitimate interests, we may use your personal information for the following purposes:

(1)to provide you with Solar Engine’s products or services or information;

(2)to sign you up for an event or training;

(3)to contact you and respond to your requests and enquiries;

(4)for business administration, including statistical analysis;

(5)to personalize your visit to the Solar Engine Site and to assist you while you use the Site;

(6)to improve the Solar Engine Site by helping us understand who uses the Site; or

(7)to periodically provide you with information about our products and services and content that may be of interest to you by email.

If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the emails or request to be opted-out of receiving such communications via email to privacy@solar-engine.com.

4.How We Share, Entrust the Processing, Transfer, Disclose And Transmit Personal Information

Subject to compliance with applicable laws and regulations, we may disclose User’s personal information to Solar Engine’s Affiliates or other third parties.

We may use third-party technology service providers to provide us with services who may have access to your personal information, including companies that assist with programming and technical aspects of hosting and operating the Solar Engine Site (e.g. Website Cloud Service Providers), technical service provider that assists with analyzing the usage of our website (Refer to Solar Engine’s Cookies Policy for details).

Except as expressly stated in this Policy, according to the Personal Information Protection Law of the People's Republic of China, we will not disclose User’s personal information to any third party without User’s consent.

We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.

We may disclose Users' personal information to our affiliates for the purposes set out in this Policy or to promote the products or services of our affiliates to Users.

The servers used in the operation of the Solar Engine Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the Solar Engine Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

5.International Transfers

When you are located in the European Economic Area (“EEA”), personal information collected about you, including information collected from the Solar Engine website, may be transferred to recipients in countries located outside the EEA, including the United States and other countries which may not be decided by the European Commission that it provides an adequate level of protection to personal information. By you agreeing to this Policy, we will obtain your valid explicit consent for your personal information to be transferred to recipients outside of the EEA, including Solar Engine, Solar Engine's affiliates, and other recipients mentioned in this Policy. You are entitled to withdraw your consent at any time.

If you are located in the mainland areas of China, we store your personal information inside the mainland areas of China. We will not transfer your personal information outside of the mainland areas of China.

6.Your Data Rights

You have the right to access, modify, correct or delete any personal data which we may have collected. To exercise this right please contact privacy@solar-engine.com.

(1) If you are in the EEA, you have a right to (subject to a limited number of exceptions):

a.request access to and rectification or erasure of your personal information;

b.obtain restriction of processing or to object to processing of your personal information; and

(2) If you are residents of the State of California in the United States, you can request the following information about how we have collected and used your personal information during the past 12 months:

a.The categories of Personal Information we have collected.

b.The categories of sources from which we collected the Personal Information.

c.The business or commercial purpose for collecting, selling or sharing Personal Information.

d.The categories of third parties to whom we disclose the Personal Information.

e.The categories of Personal Information that we sold, shared or disclosed for a business purpose.

f.The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose.

Your Rights:

a.You can request a copy of the Personal Information that we have collected about you during the past 12 months.

b.You can ask us to correct inaccuracies of your Personal Information.

c.You can ask us to delete the Personal Information that we have collected from you.

You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

You may (i) submit requests to exercise your California privacy rights described above by writing to us at: privacy@solar-engine.com or send a written document to the following address: Legal Department, 10th Floor, Building A, Beichen Century Center, No. 8 Tianchen West Road, Chaoyang District, Beijing, China; (ii) opt out of selling of your data by clicking on the following link: DO NOT SELL MY DATA and (iii) submit requests to restrict the use of your sensitive Personal Information by writing to us at: privacy@solar-engine.com.

(3) If you are a resident of the State of Virginia in the United States, you may exercise the following personal information rights with us.

a.to confirm whether we are processing your personal information and to access that personal information;

b.to correct any inaccuracies in your personal information;

c.to delete your personal information;

d.to obtain a copy of the personal information you have provided to us; and

e.to request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or (iii) user profiling that has significant legal or similar implications for you.

As set forth in the VCDPA, you have the right to exercise the above rights without discrimination.

You may (i) exercise your rights to personal information as described above by sending email to privacy@solar-engine.com and (ii) click on the following link: DO NOT SELL MY DATA to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to privacy@solar-engine.com.

(4)If you are a resident of the State of Colorado in the United States, effective July 1, 2023, you may exercise the following personal information rights with us.

a.To confirm whether we are processing your personal information and to access that personal information;

b.To correct any inaccuracies in your personal information;

c.To delete your personal information;

d.To obtain a copy of the personal information you have provided to us; and

e.To request a refusal to allow us to process your personal information for the purposes of (i) personalized advertising, (ii) selling your personal information, or or (iii) user profiling that has significant legal or similar implications for you.