Note:

We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This privacy policy describes how [Star Charge Europe GmbH] (hereinafter referred to as "we") process your personal data through low-voltage energy storage devices and device management, installation, and maintenance applications. By using services, you are consenting to the practices described in this Privacy Policy. Please read and understand this Privacy Policy carefully before using our products or services. Our Privacy Policy explains the following issues：

1. HOW DO WE COLLECT DATA

2. HOW DO WE USE DATA

3. HOW DO WE SHARE DATA

4. HOW DO WE ENSURE DATA SECURITY

5. HOW DO WE RETENTION YOUR DATA

6. YOU RIGHTS

7. TRANSFER OF PERSONAL DATA OUTSIDE OF YOUR JURISDICTION

8. ARE CHILDREN ALLOWED TO USE SERVICES

9. UPDATES TO THE PRIVACY POLICY

10. CONTACT US

1. HOW DO WE COLLECT DATA

We collect your personal information in order to provide and continually improve our products and services.

Here are the types of personal information we collect:

• Information You Give Us

Account login. When you use our app, you need to complete the account login function. During the process, we need to collect your user account name, system settings message, email, and device identifier (UUID).

When you install an operator user for your device, we provide you with additional functional services:

Create a power station. Based on the needs of creating and matching power stations, we need to collect the owner's username and current location information of the device, and during the process, we need to apply for precise location permissions from you.

Add device. During the website construction process, our feature allows you to add devices to the power station by scanning the code, and we need to collect your camera permissions during the process.

Operation and maintenance installation assistant. For the purpose of device connection and debugging, we need to collect the WLAN list, WiFi status, WLAN name, WLAN password, device name, device model, device MAC address, and IP address of the owner's devices. In this process, we need to collect the device location permissions of the installer users.

Service management. Based on the needs of after-sales management, we need you to upload pictures of the on-site power station, and during the process, we need to collect the camera permissions and photo album access permissions of your mobile device.

• Automatic Information

Power station monitoring and management. To ensure the after-sales service of the equipment, we need to monitor and manage the operation status of the power station and equipment when the equipment is connected. During the process, we need to collect your power generation, real-time power, energy storage charging and discharging capacity, power grid buying and selling capacity, etc.

APP version update. Based on detecting whether the corresponding app store has been installed, we need to collect the device model and app installation list you are using.

Message push function. Based on providing message push notifications, we need to collect your username, device identifier, and operating system type.

• Information from Other Sources

We currently do not have any situation of collecting data from third parties.

2. HOW DO WE USE DATA

We use your personal information to operate, provide, develop, and improve the products and services that we offer our customers. These purposes include:

• Provide, troubleshoot, and improve our services. We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of Services.
• Provide location, image and camera services. When you use our location, image and camera services, we use your location, images, videos, and other personal information to respond to your requests, provide the requested service to you, and improve our services.
• Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws. For instance, we collect emails for authentication purposes.

3. HOW DO WE SHARE DATA

Information about our customers is an important part of our business, and we are not in the business of selling our customers' personal information to others.

• C-P：We collaborate with Hoymiles and entrust them to store our data.

You will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

4. HOW DO WE ENSURE DATA SECURITY

At present, we have passed international ISO27001 ISO27701, ISO37301, TISAX industry certifications. We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

The data security lifecycle includes the following stages: data collection, data storage, data usage, data transmission, data backup, and data destruction. Here is an introduction to each stage:

• Data Collection: In the data collection stage, compliance with privacy protection regulations is followed, and only the necessary fields for business purposes are collected. Measures such as TLS encryption for transmission and frontend input encryption (e.g., for credential information) ensure the security of the information collection and input process.
• Data Storage: The storage stage primarily ensures security through mechanisms such as data encryption, backup, and access control. For more details, refer to the sections on "Data Storage Mechanisms," "Data Encryption Mechanisms," and "Data Backup Mechanisms."
• Data Usage: The main security mechanisms during the data usage process include permission control, page watermarking, and data anonymization. Permission control involves functional and data-level permissions, both following the principle of least privilege. The scope of data usage is strictly limited to within the scope of business functions and is not used for any purposes outside of the business. During data transmission, TLS encryption is employed to ensure the security of data during the usage process.
• Data Sharing: Data is not shared with any third party without the authorization of the tenant.
• Data Backup: A mechanism combining full backups and incremental backups is used, and data is regularly synchronized with the disaster recovery center, following the principle of having data backed up in two locations.
• Data Destruction: When a tenant contract terminates, if there are no additional data retention requirements, the data deletion mechanism is triggered upon the termination of the business process, and the data is deleted within the time frame specified by legal or regulatory requirements.

5. HOW DO WE RETENTION YOUR DATA

We retain your personal information as long as we have an ongoing legitimate business need to do so, for example, to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

For your personal data storage location, please refer to Section 7.

6. YOU RIGHTS

As a user, you may have the following data protection rights, which you can exercise pursuant to applicable laws at any time by contacting us using the contact details provided under section “CONTACT US” below:

• The right to access, correct, update or request deletion of your personal information.
• The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
• The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
• The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section “HOW TO CONTACT US” below.
• If we have collected and processed your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. If you live in a jurisdiction that provides for a right to appeal a denial of your request to exercise such rights, you may submit your appeal using the contact details provided under section “CONTACT US” below.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

7. TRANSFER OF PERSONAL DATA OUTSIDE OF YOUR JURISDICTION

Your personal data is stored in the UK and is protected by Amazon for storage security. We will not transfer your data across borders.

8. ARE CHILDREN ALLOWED TO USE SERVICES

We does not sell products for purchase by children. We sell children's products for purchase by adults. If you are under 18, you may use StarCharge Services only with the involvement of a parent or guardian. We do not knowingly collect personal information from children under the age of 13 without the consent of the child's parent or guardian.

9. UPDATES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time including in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to notify you, consistent with the significance of the changes we make. We will obtain your consent if and when we materially change this Privacy Policy in a way that reduces the protection of your personal information collected in the past. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Platform. Once posted on the Platform, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

10. CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating that we collect, use or disclosure of your personal data, please contact us at the address below referencing "Privacy Policy":

• Company Name: [Star Charge Europe GmbH]
• Address:[Am Prime Park 17, 65479 Raunheim, Germany]
• Data Protection Officer email: [guoyu.zhao@wbstar.com]

Thank you for taking the time to understand our Privacy Policy!