Maxeon UK Privacy Policy

Effective Date (Last Updated): 26 August 2020

This Global Privacy Policy ("Privacy Policy" or "Policy") applies to Maxeon Solar Technologies, Ltd. and Maxeon Solar Pte. Ltd. and their international subsidiaries, which are referred to collectively as "Maxeon", "SunPower", "we", "our" or "us", regarding your personal data. In markets outside of the United States of America, our international subsidiaries may use the SunPower brand or a SunPower company name.

In the United Kingdom, we operate through SunPower Corporation UK Limited ("SunPower UK"). This privacy policy tells you how SunPower UK and its affiliates collect, use, and share personal information about you, including on its website, www.sunpower.maxeon.com/uk, as well as any interactions you have with us, including through mobile applications and digital services (collectively, the "Digital Platforms") that link to or post this Policy, unless otherwise indicated. It also explains how you can contact us and exercise your legal rights.

To the extent that we use your personal data in ways not set out in this privacy policy, we will provide a specific notice at the time of collection, and obtain your consent, where required by applicable law.

To the extent your Personal Data or other personal information is covered by the Personal Data Protection Act ("PDPA"), refer to the Maxeon Data Protection and Privacy Policy, which discloses our basis and purpose for collecting, processing, disclosing and otherwise using your Personal Data in accordance with the PDPA.

We may change this Policy from time to time. The "Last Updated" date at the top of this page will let you know when it was last revised. Any changes to this Policy will become effective when we post the revised Policy on the Digital Platforms. If you have concerns about this Policy, please contact us via the contact information provided in the "Contact Us" section below.

Click below to jump to a specific section of this Privacy Policy:

1. Minors
2. Our collection of information about you
3. Our use of your personal information
4. Marketing
5. Use of interactive features and copyright infringement notices
6. Disclosures to group companies and other third parties
7. Security
8. Storage and use of information about you outside the European Union
9. Changes to the Privacy Policy
10. Cookies
11. Your rights of access, rectification, deletion and objection
12. Contact Us

1. Minors

The Digital Platforms are not directed to and should not be used by minors. We do not knowingly collect personal information on the Digital Platforms from minors. In certain limited instances, e.g. where a minor is included in an advertising campaign, this will be done with the express, written consent of the minor's parent or legal guardian.

2. Our collection of personal information

The personal information we directly collect from you
When you visit and interact with our Digital Platforms, we collect information about you, including personal data that may directly or indirectly identify you.

The following explains the categories of personal data we collect from you and how we collect such data:

• Online Forms: When you complete an online form to allow SunPower, or a SunPower authorized independent distributor or installer, to contact you or to submit a request for a system design proposal, we collect identifiers in the form such as your name, address, zip code, telephone number, and email address. We may also collect information relating to your energy consumption, geolocation information, and images of your home publicly available sources as Google Earth. This information will be used to provide you information about our products, services and, where applicable, opportunities with us. We may also collect information at the time the form is submitted, e.g. IP address, operating system, device identifiers, and location, to allow us to validate the authenticity/validity of the consents obtained through online forms and prevent fraud and abuse.

• Communications with SunPower: When you contact SunPower by telephone, email or other electronic means such as online chat, or social media accounts, including through private message features, we collect identifiers as set out above and any other personal data you choose to provide, as explained below.
  • Telephone: When you contact SunPower by telephone, we will collect the telephone number that you use to call SunPower. During a call, SunPower may additionally collect your name, address, email address, and information about your energy needs and usage, as well as information about your SunPower system and any issues you may be experiencing. If you are representing a business contact for a commercial client or prospect, this may include business personal information. SunPower records its telephone calls for training and quality assurance purposes. You have the option to proceed on a recorded or non-recorded line.
  • Email and Electronic Means: When you communicate with SunPower via email or other electronic means, including through any virtual assistant, we will collect identifiers as set out above, including your screen name, email address, location, name and any personal data you voluntarily choose to include in the communication, so that we can respond to your inquiry and provide you with quality service.

• Business Contacts: SunPower collects the personal or business contact information, including your title, business email and telephone number, you provide to us at trade shows or similar events, including through business card scans or drops, to allow us to contact you or to receive information about us, opportunities with us, or our product or services, either by email or telephonically to the telephone numbers you provide us.

• Testimonials, Marketing Content, Case Studies: When you provide testimonials to or participate in the production of marketing materials or case studies for SunPower to publish on the Digital Platforms or in marketing or promotional materials, with your consent, we collect and may publish identifiers that may include your name (in full or in part), contact information, and information about your experience with SunPower products and services, including the performance of your system.

• Product Warranty Registrations: If you register a product warranty with SunPower or authorize an independent distributor/installer to do so on your behalf, we will collect your name, address, information about products purchased, and contact information, including telephone number and email address. To the extent that your warranty is registered through a third party, e.g. an independent distributor or installer, our records will reflect this relationship. This information will be used by us to implement our warranty obligations, including, notifying you about any product quality or safety issues, such as product recalls, and for surveys to you about your product purchase and installation experiences and your overall satisfaction with our products.

• Social Media, Online Forum, Blogs, Message Boards, Chat Rooms: You may choose to interact with SunPower via social media platforms on which SunPower is active, including, but not limited to Facebook, LinkedIn, Instagram or the SunPower Blog, chat or messaging features available through the Digital Platforms. Relating to these interactions, SunPower may collect your screen name, real name and any information that you choose to provide such as posts, "likes", "follows", comments or feedback that you post or leave on pages, feeds or inboxes belonging to SunPower. There are areas of the Digital Platforms and social media platforms that are visible to other users or the general public, e.g., blogs. We recommend that you do not post personal details to these areas of the Digital Platforms. YOU ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR HARM RESULTING FROM YOUR VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION OR POSITIONS TAKEN BY YOU IN PUBLIC AREAS, ON SOCIAL MEDIA OR FORUMS. YOU RECOGNIZE THAT SUNPOWER MAY HAVE A LIMITED ABILITY TO DELETE OR OTHERWISE MODIFY/OBSCURE POSTS THAT YOU HAVE MADE TO SOCIAL MEDIA ACCOUNTS, WHICH ARE SUBJECT TO THE TERMS OF USE FOR THOSE VARIOUS SOCIAL MEDIA PLATFORMS.

• Applications: When you sign up or use a SunPower application or service, we collect the Personal Information you provide to create a profile or account. This may include identifiers such as your name, address, zip code, telephone number, and e-mail address. For security and the prevention of fraud, we may collect additional information about you when you log into a Digital Platform or service, including IP address, length of session, activities performed, and device information.

• Surveys: If you respond to surveys issued by SunPower, we will collect your e-mail address, name, and any information you provide in response to or relating to the survey. Generally, if we disclose information relating to the survey to third parties, including to independent distributors or installers, we will do so in non-identifying, aggregated form. We may disclose your feedback about the performance of an independent distributor or installer to that independent distributor or installer in an identified fashion, either with your consent or without your consent, if we deem doing so is necessary to facilitate the resolution of a service quality issue with that independent distributor or installer.

• Consent: We may use your Personal Information for any other purpose for which you consent.

• Combining Information We Collect: We may combine any of the information we collect from or about you and use it in the manner described in this Policy.

We do not seek sensitive information about you (such as health or medical history, ethnicity, political leanings, religious beliefs, trade union membership, sexual preferences, etc.) and you should not provide such information to us.

Personal information that we collect on the Digital Platforms
The Digital Platforms uses cookies, pixel tags, analytics tools, and other similar technologies to collect information about your equipment, browsing actions and patterns to help our Digital Platforms to function effectively and to improve the services we provide. These technologies collect the following information about you from your browser whenever you access or use the Digital Platforms: your IP address, your computer's operating system, your browser name, and language preferences the web pages that you viewed before, during and just after visiting our website. This browsing information is processed anonymously but may we may link it to your personal details if you have provided these, including for the purpose of documenting or validating the submission of online forms and consents.

Data Analytics
We may use third-party data analytics service providers such as Google Analytics to measure the web traffic on different parts of our Digital Platforms in order to improve them. Google Analytics, which anonymously tracks users who have JavaScript enabled, uses technical tools like first-party cookies and JavaScript code to collect information about your interactions with our Digital Platforms. The tracking information may include detailed data about what you do on our Digital Platforms, such as the web pages you visit and for how long and the websites you visited directly before and after coming to our Digital Platforms. In addition, first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) are used to report how your ad impressions, uses of ad services, and other interactions are related to visits to our Digital Platforms. We use information from Google Analytics to administer and update our Digital Platforms, assess whether our users match the expected demographics, and determine how key audiences are navigating the content. Google may retain and use, subject to the terms of its privacy policy, information collected in your use of the Google Analytics Information Disclosures and Sharing. Google Analytics offers website visitors the ability to prevent Google from recording, processing, and using the data generated by the Google Analytics cookie. You may opt-out by downloading and installing the browser plug-in available through Google at the following link: http://tools.google.com/dlpage/gaoptout.

To learn more, including about how to control our use of cookies and similar technologies, please review our Cookies Policy.

The Digital Platforms contains links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and practices. SunPower does not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to any third-party websites.

Personal Information SunPower receives from third parties

• Third Parties with Whom We Have a Relationship – SunPower may receive your personal data from third parties with whom we have a relationship, including our authorized independent distributors or installers, in connection with your purchase of a SunPower system, e.g. a warranty registration, and our parent and affiliate companies, including in connection with sales referral opportunities.

• Purchase of Data from Unaffiliated Third Parties – Where permitted by applicable law, SunPower may choose to purchase your personal data from third parties, e.g. lead generators, and will process your data in accordance with applicable law (and with your consent, where required), to determine whether you are interested in purchasing a SunPower product or service, whether that product or service is right for you, or whether the opportunity to become a SunPower installer or distributor is of interest to you.

• Third-Party Site Information: Some of our applications leverage data, including images, from third-party sites or databases, including Google Earth images included in our design a system or estimator functionalities or utility information provided to us by your utility company with your consent. Where required, we will seek your consent to receive this data.

• Links to Third-Party Sites: If you follow a link to any third-party sites or use sites of a third-party service provider, please note that they may have their own privacy policies and practices. SunPower does not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any Personal Information to any third-party sites.

3. Our use of your personal information

We use the Personal Information or non-identifiable information we collect to facilitate the business relationship we have with you, to comply with our legal and financial obligations, and to pursue our legitimate business interests, which include the business purposes and in accordance with the legal basis set out below:

4. Marketing Communications and Unsubscribe or Opt-Out

We may send you marketing communications, including email communications about our products and services, invite you to our events, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with applicable law, including any consent requirements.

We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you, which includes a method to access your Preferences Center, or you may also opt out by contacting us as set out in paragraph 12 below. You may unsubscribe at any time.

5. Use of interactive features and copyright infringement notices

The Digital Platforms may use interactive forums, blogs, message boards, chat rooms, etc. Unless clearly indicated to the contrary, any information that you post may be viewed by others and/or the general public. We urge you to use good judgment, to adhere to the Terms of Use and not disclose any information about you that you do not want other users to know. We are not responsible for the use of that information by other users.

Copyright infringement notices submitted to us by you will be forwarded to the person responsible for the alleged infringement. Other complaints about the content of our Website may also be forwarded to any persons referred to in the complaint.

6. Disclosures of your information

We may share your Personal Information with trusted third parties or in other instances, including where required by law. We will use contractual or other means to protect Personal Information disclosed to third parties where required to ensure that the recipient keeps the Personal Information confidential and does not use it for any other purpose except performing the services.

We share the personal data with our parent and affiliated companies in order to provide our products and services and for our internal business purposes.

We share information we collect about you with our employees, partners, parent companies, affiliates, independent distributors, installers, partners, service providers, vendors and suppliers that:

• process information on our behalf;
• provide infrastructure, products or services to us or on our behalf or help us operate or improve our business;
• participate with us in the provision, maintenance, or operation of the Digital Platforms;
• provide you with information, products and/or services relating to your SunPower system, experience or when it is necessary to provide information, products or services to you.

Corporate Transactions - In the event we enter into or intend to enter into a transaction that alters our business structure, such as a sale, reorganization, merger, joint venture, change of control or other disposition of all or any portion of our business, assets or stock, we may share personal information with third parties for the purpose of facilitating and completing the transaction. In the event that we (or a part thereof) are subject to such an event, you agree that any of your personal information which we hold may be transferred to that reorganised entity or third party and used for the same purposes without further notice to you.

Surveys - If you choose to complete a customer experience survey, information you provide to us may be disclosed to other companies. Your information may be provided in identifiable format to your authorized independent SunPower distributor/installer; for other non-affiliated third parties, it will be anonymised and/or aggregated.

Compliance with Law - We may disclose information we collect about you if required, or authorised, in our sole discretion, to do so by applicable law (domestic or overseas) or in response to a court order or its equivalent and/or regulators anywhere in the world. We may also disclose your information in order to protect against fraud or to protect our contractual, property or other rights.

Prevention of Harm - We may disclose information we collect about you to the necessary authorities if we believe you have abused a service offered by us via the Digital Platforms or otherwise by using it to attack other computer systems or to gain unauthorised access to any other computer system, to engage in spamming or otherwise to act in an unlawful manner or to breach the terms of use of the service or the Digital Platforms.

7. Security

We take all reasonable precautions and implement appropriate technical and organizational measures to ensure a level of security to protect the security and the confidentiality of your personal information against unauthorized access, disclosure, alteration or destruction. However, no data transmission over the Internet or any website can be guaranteed to be secure from intrusion. Therefore, while we use reasonable efforts to protect your personal information in accordance with data protection legislation requirements, we cannot guarantee its absolute security. Any unauthorised access to or use of the Digital Platforms or the information stored by us should be reported to us immediately by sending an email to: data-protection@maxeon.com.

All information you provide to us is stored on our secure servers or cloud environments and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

8. Storage and use of information about you outside the European Union

Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. We store the information we collect via the Digital Platforms and other sources (such as our customer call centres) on centralised computer systems hosted by or on behalf of Maxeon Solar Technologies, Ltd. These are located outside of the EEA, including in the United States, Singapore, and the Philippines.

Please be aware that data protection laws in the United States, Singapore and the Philippines do not currently offer the same level of protection as in European Union and you may have fewer statutory rights in respect of information stored and processed by Maxeon Solar Technologies, Ltd. about you. In such instances, Maxeon Solar Technologies, Ltd. has engaged suppliers who are US Privacy Shield certified and/or have otherwise agreed to protect such information in accordance with European data protection laws.

In addition, each of SunPower's operating subsidiaries have entered into an intra-group data transfer agreement that implements Standard Contractual Clauses; such intra-group data transfer agreement provide adequate protection to the flows of personal information within SunPower's group entities all over the world, even in case where SunPower undertakings are established in countries where the level of data protection is not considered commensurate with the level offered by data protection offered by data protection laws in the European Union. The Standard Contractual Clauses that have been implemented can be obtained upon request by sending us an email at data-protection@maxeon.com.

In accordance with applicable data protection legislation, we will retain your personal information for as long as is necessary for the processing purpose for which they were collected. Certain transaction details and services and correspondence, such as those relating to your purchase of SunPower products or the warranty on your SunPower products, may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data, and then archived in accordance with legal requirements, i.e. with statutory limitation requirements. Certain data, including those of individuals who provide personal data to SunPower, but who do not purchase SunPower products or services within two years of initial contact with SunPower, will be deleted or otherwise archived after two years from the initial date of contact with SunPower.

9. Changes to the Privacy Policy

Due to changes in technology, applicable law and our activities or due to other business reasons, we may need to modify this privacy policy. We will put the new version of this privacy policy on this website and on the Digital Platforms without a notice advising of the change. It is therefore important that you regularly check this website and the Digital Platforms for any changes affecting this policy.

10. Cookies

Our website uses "web cookies" that it places on your computer whenever you visit the website in order to distinguish between and to log access by each visitor's browser. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy.

11. Exercise of your rights

Under the General Data Protection Regulation ("GDPR") you may have the following rights with regards to the personal information we hold about you:

• Access – You can ask to see the personal data SunPower holds about you. SunPower may validate your identity and access rights. SunPower may charge you a fee to access your personal information. We will advise you of a fee in advance. Applicable law or regulatory requirements may prevent us from disclosing some or all the personal data we hold about you. Some personal data may have been destroyed, erased or made anonymous. Where we cannot provide you with your personal data, we will tell you why, subject to any legal or regulatory restrictions.

• Correction or Deletion of Personal Information –You may request correction or deletion of the data we hold about you. SunPower reserves the right not to change or delete personal data it considers to be accurate or necessary to be maintained. We reserve the right to request legal confirmation of changes. If personal data is inaccurate, we will revise it and, unless it proves impossible or involves disproportionate efforts or cost, inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may be updated.

• Withdrawal of Consent – If you consented to the processing of your data, you may (in certain instances) withdraw that consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.

• Objection to processing – You may (in certain instances) have the right to object to the processing of your personal data, including profiling, on grounds relating to your particular situation. When profiling is related to direct marketing you always have a right to object.

• Limitation to processing – You have the right to obtain a restriction of processing in certain instances as provided by data protection law.

• Data portability – You have the right to receive the personal data, which you have provided to us, in a structured, commonly used and machine-readable format when the processing is based on your consent or on a contract. Where technically feasible, you also have the right to ask us to transmit it to another data controller.

• Complaints – You have the right to lodge a complaint to the data protection authority, if you believe that SunPower has not complied with the requirements of the GDPR with regard to your personal data.

You can exercise these rights by writing to us at SunPower Corporation UK Ltd., Vienna House, International Square, Birmingham International Park, Solihull, B37 7GN, or by sending an email to data-protection@maxeon.com, including your full name, contact details, the details of your request, and a copy of your identity document.

12. Contact Us

SunPower Corporation UK Ltd. is the Data Controller in respect of your personal information processed by us under this Privacy Policy.

We can be contacted about this Privacy Policy or our processing of your personal information at the following addresses:

SunPower Corporation UK Ltd.
Vienna House
International Square
Birmingham International Park
Solihull, B37 7GN

Email: customers@maxeon.com