Data Privacy and Cookie Policy

1.     Changes to this policy

Delixi Electric can modify this privacy and cookie policy as needed.

Delixi Electric reserves the right to modify this policy as needed, for example, to comply with laws, regulations, Delixi Electric specifications and procedures or regulatory requirements.

In this case, Delixi Electric will inform the affected personnel about the major changes to this privacy policy. Delixi Electric will release new versions on relevant internal and external websites and digital platforms.


2.Why implement this privacy and cookie policy?

Delixi Electric is committed to protecting your privacy and personal information. This privacy policy will inform you of our privacy regulations and how to protect your personal information. You should read this privacy policy before accessing Delixi Electric digital content.

Delixi Electric strongly supports the fundamental rights to privacy and data protection as well as compliance with national and international privacy laws.

This Privacy Policy describes how Delixi Electric processes and protects personal information of individuals who use our websites and other digital platforms as well as in the context of our offline business activities.

For the collection, processing, use, dissemination, transmission and storage of personal information, Delixi Electric has implemented a data privacy policy internally, which is applicable to our subsidiaries. This policy sets out general rules for all our subsidiaries to ensure the high protection of personal information within Delixi Electric.

As the data controller, Delixi Electric has decided to publish this privacy policy as our binding company regulation

3.What is the scope of this policy? Who is in charge of data processing?

This Privacy Policy applies to all Delixi Electric subsidiaries and digital content, unless a specific privacy notice has been released to supplement it or to replace it. You should check the privacy notices made available to you on each digital platform such as websites or applications.

This privacy policy is applicable to all Delixi Electric data processing activities carried out by subsidiaries controlled by us, including products, services and digital content (such as event registration, websites, applications, tutorials, e-training, newsletters, advertisements and other communications). However, it can be supplemented by a very specific privacy notice/statement/policy, or even replaced by another policy specific to a specific plan, product, service, content or entity of Delixi Electric. Be sure to read the statement we provided to you for complete information. For example, the processing of job applications is subject to the privacy statement posted on our career portal.This privacy policy is applicable to all Delixi Electric data processing activities carried out by subsidiaries controlled by us, including products, services and digital content (such as event registration, websites, applications, tutorials, e-training, newsletters, advertisements and other communications). However, it can be supplemented by a very specific privacy notice/statement/policy, or even replaced by another policy specific to a specific plan, product, service, content or entity of Delixi Electric. Be sure to read the statement we provided to you for complete information. For example, the processing of job applications is subject to the privacy statement posted on our career portal.

The data controllers of data processing activities are the subsidiaries of Delixi Electric, which are responsible for determining the method and purpose of data processing. Specific practices may vary depending on the situation. In many cases, Delixi Electric Co., Ltd. (Delixi High-tech Industrial Park, Liushi Town, Yueqing City, Zhejiang Province) is the data controller of data processing activities. For relevant information, you can contact us by email at the following address: security.info@delixi-electric.com

This Privacy Policy binds all Delixi Electric controlled subsidiaries, and their employees.

Any order made by you online is also subject to the terms and conditions provided on the relevant sites. You must read them.

4.Why do we collect and use personal information?

We use personal information for various purposes, including to fulfill orders and requests, to manage customer and prospect relationships, conduct surveys, improve our products, services, digital content as well as user journeys, manage user accounts and programs, analyze activities on our digital platforms, run marketing activities, provide user with contextual and relevant information, ensure the security of our activities, protect against fraud, and, more generally, run our business activities.

Our primary goal in collecting information is to provide you with superior service and a smooth, efficient and personalized experience while using our digital content.

Delixi Electric collects personal information for the following purposes:
- To fulfill orders of product, services and digital content. We collect this information to deliver your order, to obtain payment, to provide the functionalities of our applications, to communicate with you about the status of your order and for contract management purposes;
- To better address future requests for information and support. We keep record of exchanges including personal information to provide an optimized service on contacting us for support;
- For relationship management purposes which includes communicating about the products, services and digital content including email communications and messaging;
- To conduct surveys and polls. We may collect personal information to complete surveys and contact you for follow-up. We use this information to measure satisfaction, get to know our customers better and improve products, services and digital content;
- To improve our products, services and digital content; for instance, we analyze the use of our applications and websites in order to identify areas and functionalities where users have difficulties, and we improve them;
- To learn about your browsing and searching activity. We collect navigation information when you visit our digital content or click on links for products and services. We collect this information to improve user experience for next visits (e.g., country selection or profile-focused content), help our websites run more efficiently, to gather broad demographic information to analyze the websites’ activity and performance, and to evaluate the relevance and effectiveness of our advertising to better serve our customers. We may use cookies and other identifiers or similar technologies (referred to hereinafter as "Cookies") to obtain information on the referring website, type of browser used, the content viewed, as well as the date and time of access to the digital content. You may read our Cookie Notice for more information on our use of Cookies and your options for managing Cookies;
- To manage user digital accounts. We collect personal information at registration on our digital platforms (e.g. partner portal, ordering platform, mobile apps) to authenticate you, manage credentials to enable you to navigate through several digital platforms without having to re-authenticate (cf. single sign-on) and to interact with you;
- To run promotional programs and activities: we collect personal information when you join a promotional or reward program or activity. We use this information to administer the program or activity, to send relevant e-mails about the program and activity, notify winners, and make the winners' list publicly available in accordance with applicable regulations and laws;
- To send you marketing information by mail, fax, phone, text messages, email and electronic communications about promotions, news and new products or services that we think may be of interest to you in compliance with applicable opt-in and opt-out requirements. This can be conducted by Delixi Electric, its subsidiaries or selected third-parties acting on our behalf;
- To provide you with certain communications and/or targeted information about our products and services (or of our subsidiaries) through pop-ups, banners, videos, emails and any other advertising format. For instance, we may provide you with contextual advertising or other content, based on browsing information. We may also use location data to inform you about local promotions and activities. Please read our Cookie Notice for more information on the use of Cookies and your options for managing them;
- To combine information obtained online from different digital platforms and the information we collected about you offline to create a profile of you that we may use for giving you personalized services. For example, a user that we believe is an electrician (due notably to information provided at the time of registration and other information obtained from third-party sources), may see profile related advertising and/or on third-party websites and apps that a user with another energy-related specialty would not see. Similarly, users may see different content or receive different emails containing different advertisements or surveys. We may also use Cookies to geographically target users;

5.What type of personal information do we process?

Delixi Electric processes various types of personal information including identity and contact related information, professional related information, information about preferences, interactions with us, financial related information, online traffic data and the content you provide to us. In most instances this information is obtained from customers, partners and users. We also purchase lists from marketing agencies and obtain information from our partners, through Cookies and social networks.

Personal information (also called personal data) is any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

The types of personal information we process about you may include:
- Identity and contact related information, such as name, company, email address, phone number, photo, age range, contact addresses;
- Professional information, such as customer type, purchasing authority, purchasing timeframe; acquisition and use of Delixi Electric products, services and digital content;
- Information (e.g. energy consumption) which is specific to the digital platform you use;
- Your preferences such as product and service preferences, contact preferences, marketing preferences;
- Your interactions with us such as queries, orders, claims, survey answers;
- Online traffic data such as IP address, device and system identifiers, your Delixi Electric user ID and password, referring website, type of browser used, consulted content, and location, based either on your IP address or on information transmitted by your mobile device;
- Content that you have provided via online forums or otherwise (see section 6 “Your content” below).

This Privacy Policy does not cover personal information rendered anonymous, that is if individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or labor. If anonymized data becomes identifiable, then this Privacy Policy shall apply.

6.Your content

You may choose to contribute content, including photos or comments, to online forums, applications or other digital platforms operated by Delixi Electric. Your content must be harmless. It must respect the law, the rights and interests of others. You need to have obtained consent before sharing someone else’s data. You should apply caution before sharing information in a forum.
The content provided to us must respect the rights and interests of others, including their rights to protection of personal information and privacy. It should not be offensive, disrespectful or be harmful in any way.
Any provision of personal information to Delixi Electric about another individual must be compliant with privacy laws, including with notice and consent requirements for the disclosure of that information.
While Delixi Electric strives to protect your personal information, providing it online on shared forums is not risk-free. If you post, comment, indicate interest, or share personal information, including photographs, to any forum, social network or blog, please be aware that any personal information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor Delixi Electric have control over. Delixi Electric is not responsible for the personal information you choose to submit in these forums. You should apply caution before deciding to share information about yourself or another person.

7.Who do we share personal information with?

We share personal information with the Delixi Electric subsidiaries and the service providers involved in our activities, with advertising and marketing agencies, with social networks if you use their login credentials, with third-party websites if you register with Delixi Electric credentials, competent regulatory bodies and authorities and business successors.

Delixi Electric is a group company in the low-voltage power transmission and distribution, industrial control, and home appliance industries, which works as one. To provide the best service to customers, prospects and users, personal data may be shared amongst personnel working for different entities. It may be the case, for example, for customer relationship management, sales or product support, marketing, product development purposes, improvement of the products, services and digital content, data quality checks, or security, finance, regulatory and compliance purposes.

We resort to service providers to carry out data processing activities and to provide our products, services and online content to you. These service providers include, without limitation, providers of hosting facilities, information systems, advertising and marketing agencies, IT support, security services, financial services, carriers who deliver products, outside accounting firms, lawyers and auditors.

We ensure all service providers working under contract for Delixi Electric are compliant with data privacy laws and aligned with Delixi Electric guidelines.

We also share the information as follows:
- In connection with the provision of advertising, we may share some limited personal information (e.g. device identifiers, Cookie identifiers) with ad exchanges or agencies that manage advertising on third-party websites and apps on which you may see advertising.
- You may access our digital content and/or register through login credentials of third-party websites (such as Facebook and LinkedIn). If you do so, we will be able to access some of the information you registered on these social networks, to assist you to pre-fill the registration form for Delixi Electric digital content. By using the login credentials of these third-party websites, you may at the same time inform your contacts on these sites that you have created an account with Delixi Electric. If you want to know more about the information accessible by your contacts on these sites and how to restrict their communication, we encourage you to read their terms of use and privacy policies.
- Delixi Electric may disclose your personal information as necessary to potential buyers and successors in title, to facilitate a merger, consolidation, transfer of control or other corporate reorganization in which Delixi Electric participates.
- Where required by law or court orders or to protect our legal rights, we will disclose your personal information to government agencies, regulators and competent authorities.
- In other ways described in this Privacy Policy or to which you have otherwise consented.
- Aggregated with other information, in such a way that your identity cannot reasonably be determined (for example, statistical compilations).

We will not sell or rent your personal information to a third party without your permission.

8. How do we protect personal information?

Delixi Electric complies with widely recognized key data protection principles (fairness, purpose limitation, data quality, data retention, compliance with individuals’ rights, security) and takes reasonable measures for the security of personal information.

Delixi Electric respects the privacy rights and interests of individuals. Delixi Electric and its subsidiaries observe the following principles when processing personal information:

1. Processing personal information fairly and lawfully;
2. Collecting personal information for specified, legitimate purposes and not processing it further in ways incompatible with those purposes;
3. Collecting personal information which is relevant to and not excessive for the purposes for which it is collected and used. We may render information anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
4. Maintaining accurate personal information, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete information that is inaccurate or incomplete;
5. Keeping personal information only as long as it is necessary for the purposes for which it was collected and processed;
6. Processing personal information in accordance with individuals’ legal rights;
7. Taking appropriate technical, physical, and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal information;
8. When processing sensitive personal information, ensuring appropriate notice and consent or that the processing otherwise complies with applicable law;

Delixi Electric and all its subsidiaries must ensure that the above principles are complied with.

Delixi Electric and its subsidiaries are committed to taking commercially reasonable technical, physical, and organizational measures to protect personal information against unauthorized access, unlawful processing, accidental loss or damage, and unauthorized destruction. We offer the use of secure servers to enable you to place orders or to access your account information. We implement access control measures for our internal systems that hold personal information. Authorized users are given access to such systems through the use of a unique identifier and password. Access to personal information is provided to our staff for the sole purpose of performing their job duties. We sensitize our employees on proper use and handling of personal information. We also require our service providers to maintain compliant security measures. We implement security measures to determine the identity of registered users, so that appropriate rights and restrictions can be enforced for these users. In case of a registered user, we use both log ins and passwords for authentication. You are responsible for maintaining the security of your log-in credentials.

By using our digital content or providing personal information to us, you agree that we may communicate with you electronically or otherwise about related security, privacy, use and administrative activities.
In spite of our efforts to implement appropriate security measures, online browsing carries inherent risks and we cannot guarantee that it is risk-free.

9. Third-party websites and social media

You should read the privacy policy of third-party websites and social media and adjust privacy settings as you see fit. Non-Delixi Electric websites and platforms are not covered by this Privacy Policy.

Delixi Electric digital platforms may provide links to third-party applications, products, services, or websites for the user convenience and information. If you access those links, you will leave the Delixi Electric digital platform. Delixi Electric does not control those third-party sites or their privacy practices, which may differ from Delixi Electric’s practices. We do not endorse or make any representations about third-party sites. The personal information you choose to provide or that is collected by, these third parties are not covered by the Delixi Electric Privacy Policy. We encourage you to review the privacy policy of any site you interact with, before allowing the collection and use of your personal information.

We also provide social media links that enable you to share information with your social networks and to interact with Delixi Electric on various social media sites. The use of these links may result in the collection or sharing of information about you. We encourage you to review the privacy policies and the privacy settings of the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites and to adjust these settings as you see fit.

10. What are your rights?

Delixi Electric will comply with your data protection rights, including your rights to request access to your personal information and to request that it be deleted or amended. You can always opt out of any direct marketing activity performed by Delixi Electric.

Delixi Electric will comply with your data protection rights, including your rights to access and correct your personal information. You may inquire about the nature of the personal information stored or processed about you by any Delixi Electric entity. You will be provided access to your personal information, regardless of the location of the data processing and storage.

You can request access to your personal information and request that it be deleted or amended at any time.

Individual Rights Requests can be sent to: security.info@delixi-electric.com

You always have the right to opt out of our marketing communications. Your prior consent is sought, when required by any applicable law. To opt out of marketing emails, simply use the functionality provided at the bottom of any email we send.

Country-specific sections may supplement this section.

11. What is the legal basis for Delixi Electric to use personal information?

For the purposes described in Part 3 above, personal information must be used to perform the following:

- In the case of using our products, services or digital content, execute the contract signed between Delixi Electric and you. The performance of the contract includes knowing your identity, your expertise, and the interaction with you to understand the performance. It also includes processing your information, support, your work application, managing your account and your request to enroll in our program, and ensuring compliance with the terms and conditions and this privacy statement.

- Abide by our legal obligations. For example, mandatory tax and accounting obligations, or processing filing obligations and requests made by competent regulatory bodies and authorities.
- When the following situations are involved:
o Surveys, some of which are based on our legitimate rights and interests, because they are used to measure your satisfaction with the services you require. For other investigations, we will ask your consent. You have the right not to respond.
o We provide you with marketing communication and interest-based advertising. These activities carried out by us and our subsidiaries are in line with our legal rights and interests. We allow you to opt out at any time, and we will obtain your prior consent if required by applicable laws.
o If you use your mobile device to transmit location data, we will obtain your prior consent under the requirements of applicable laws.

We can also process your personal information according to our legal rights and interests, provided that such processing will not infringe your rights and freedoms, especially:
- Protect you, us or others from threats (such as security threats or fraud),
- Comply with the laws applicable to us on a global basis,
- Improve our products, services and digital content,
- Conduct profile analysis to provide targeted content and interest-based advertising,
- The information is shared between Delixi Electric subsidiary and the service provider according to the provisions of Part 7,
- Understand and improve our online activities, business, customer base and relationships as a whole.
- Support or manage our business, such as quality control and integrated reporting
- Manage company affairs, such as mergers or acquisitions.

12. Will we conduct an overview analysis and make automated decisions for you?

We will use analysis tools to provide you with online content that we think is in line with your interests. We combine registration information, such as your work expertise and information about your online activities, so as to fully understand you and provide you with online content corresponding to your personal data.
We will not make automated decisions that may have a significant impact on you unless:

-This decision is a necessary part of the contract we signed with you;

-We have your explicit consent;

-Or the law requires us to use this technology.

In this case, we will provide relevant notice.

13. How long will personal information be retained?

As long as the information needs to be used for the purposes specified in this privacy policy, we will continue to retain personal information and will retain it for any additional period required or permitted by law. The privacy statement for specific digital content provides very accurate information. In general, the following situations will be considered when determining the data retention period:

-The duration of our relationship (for example, the duration of contract performance, account closure, and your legal needs confirmed when we contact you)

-Legal requirements for data retention

-Limitation of action

For marketing purposes, we will retain relevant customer data for three years after the termination of the relationship or since the last interaction with us.

14. What are cookies and similar technologies?

A cookie is a piece of information placed on the hard disk of Internet users in the form of a very small text file. It is generated by a web server, which is basically the computer running the website.

The information contained in cookies is set by the server and can be used by its hosting server when users visit the website.

Cookies can be divided into two categories:

-Session cookies, which allow websites to identify and link users' actions for a browser session (for example, cookies used to remember users adding shopping cart content when browsing websites);

-Persistent cookies allow websites to remember user preferences and choices (for example, cookies for targeted advertising).

Similar technologies are technologies and tools that use certain features to identify devices and analyze the behavior of accessing websites. Similar technologies include HTML5 local storage, local shared objects, fingerprint technology, pixel tracking and plug-ins.

For ease of reference, cookies and similar technologies are called "cookies".

Cookies have many uses. Cookies enable us to provide users with certain functions and provide us with website visitor information.

Cookies can also make our website more user-friendly, let us better understand our existing and potential customers, and enhance our relationship information, including establishing links between users and different devices and browsers that may use online positioning and advertising.

15. How can you set cookies?

 You can use our cookie privacy settings panel to manage unnecessary cookies set by Delixi Electric. Many of our websites will only place marketing cookies when you click "Accept all cookies" when you first visit the website. If you have accepted cookies, you can use this link to adjust your preferences.

You can also use browser settings to manage and delete cookies. Browsers such as Chrome, Internet Explorer, Firefox, and Safari enable you to accept, reject, or delete cookies. Visit your browser's Help Center to learn more. Please note that your browser settings cannot manage some types of cookies, such as Adobe Flash cookies or Microsoft Silverlight cookies. To manage Adobe Flash Cookies, please visit the Flash Player help page. To manage Microsoft Silverlight cookies, please visit the Silverlight section of the Microsoft Privacy Statement.

You can also use some industry projects to control the way we provide you with advertisements.

The Network Advertising Initiative (NAI) manages many opt-out projects of third-party advertising companies. visit https://www.networkadvertising.org/consumer/opt_out.asp , you can choose not to be a member of the NAI.

On some websites, you may see the AdChoices icon, which may appear on specific target advertisements. You can click the AdChoices icon to learn more about collecting and using your information, or choose to exit such information collection behavior. To learn more about the Digital Advertising Alliance Consumer Choice, please visit http://optout.aboutads.info. In most cases, your selections will be linked to your browser. If you use different browsers or devices, you need to set your preferences on each browser or device. Even if you choose to exit, you may still receive non-personalized advertisements.

 Although our website currently does not have a mechanism to identify the Do Not Track flag of various web browsers, as mentioned earlier, we do provide customers with the option of managing cookie preferences. To learn more about browser tracking and Do Not Track, visit https://www.allaboutdnt.org.