Effective Date (Last Updated): 26 August 2020
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.
- Our collection of information about you
- Our use of your personal information
- Use of interactive features and copyright infringement notices
- Disclosures to group companies and other third parties
- Storage and use of information about you outside the European Union
- Your rights of access, rectification, deletion and objection
- Contact Us
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.
- 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 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:
To provide you, either individually or in your professional capacity as an authorized representative of a business or organization, with the information, products or services you have requested from us, including through the Digital Platforms, such as a consultation/quote with SunPower or an approved SunPower installer or independent distributor (where available), blog or newsletter subscription, or our energy savings calculation/ estimators, to process your order, and to supply and/or install such products and related services, including product maintenance, product safety notices and warranty servicing, where applicable.
To provide you requested information, including information about SunPower independent distributor or installer opportunities.
To respond to your queries, including where you have provided us your contact information at a trade show or similar event.
To recover any payments due to us.
To keep in contact with you regarding your purchase of our products and services, your Digital Platforms registrations and compliance with the terms and conditions of use of the Digital Platforms.
To send periodic customer experience surveys about your experience with our company, our products, approved SunPower independent distributors or installers, and their services.
To execute the terms and conditions of use of the Digital Platforms.
To enter into and perform pre-contractual and contractual obligations that we have with you.
To enter into and perform pre-contractual and contractual obligations that we have with you. Our legitimate interest to answer your questions and develop and maintain our relationship with you.
To perform and enforce contractual obligations and our legitimate interest in protecting our assets.
Our legitimate interest to develop our business and ensure the quality and safety of our goods and services.
Our legitimate interest to ensure a high-quality level of customer service and product performance and to improve these levels.
If we communicate with you by telephone (for instance, if we call you to conduct a consultation you have requested via the Digital Platforms or if you call our customer service center with a query about one of our products or services), we may record and monitor our call to help train our staff and to ensure a high quality of customer service.
Our legitimate interest to ensure a high-quality level of customer service and to improve this level.
Our legitimate interest and legal obligation to validate your identity, including for security and fraud prevention purposes.
Where you have submitted your personal data relating to a job application, to process and evaluate your application.
The need to execute the terms and conditions of use.
Our legitimate interest to evaluate your application and to take the necessary measures prior to concluding a contract with you.
To directly market our products, services and, where relevant, installer opportunities or distributorships, to you.
Our legitimate interest to develop our business.
Where we obtain your information from unaffiliated third parties, your consent.
If you are interested in purchasing our products and services, to provide independent distributors/ installers of our products in your area with your information so they can contact you with purchasing and pricing details. Or if you have provided your information to an independent distributor/installer that chooses to register this information with us, including for warranty registration and servicing purposes.
Our legitimate interest to develop our business and comply with your request for services or information.
The need to comply with our legal and contractual obligations.
To better understand how you use the Digital Platforms and to produce statistical reports of aggregate website activity.
To identify patterns and trends related to your use of the Digital Platforms to enable us to improve the design and operation of the Digital Platforms and your browsing experience.
To improve our products and services.
From time to time, we may release in aggregate the browsing information we have gathered from visitors, such as by publishing a report on trends in the usage of the Digital Platforms which may be anonymous.
To validate/corroborate your identity in connection with any consents obtained from you via the Digital Platforms.
Our legitimate interest to improve the quality of the Website and of our products and services and to better communicate with you concerning our services and products.
Our legitimate interest and legal obligation to secure the Digital Platforms and validate the authenticity and ensure the security of lead forms generated thereon.
To gather further information about you from third party sources. For instance, we may use your email address to gather information about which social networks and other web services you subscribe to for analytical or personalization purposes to improve our products and our Website for users.
Our legitimate interest to evaluate your personal interests and your behavior in order to improve our products and our website.
To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business and to improve the effectiveness of our marketing activities.
Our legitimate interest to analyze and understand the performance of our business and report on same.
To allow you to participate in interactive features of our service, when you choose to do so.
Where you have agreed, we may use your information to send you information promoting selected third parties' products and services by post, fax, telephone, email, text and/or via social networks and other web-based services you subscribe to, and where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.
If you agree to receive marketing from other companies, we may disclose your email address and other contact details to other companies so that they can contact you directly about their products and services.
We use personal information to comply with international laws applicable to publicly traded companies, including those relating to the detection, prevention and monitoring of fraud, anti-corruption, and money-laundering, which including obligations like Know-Your-Customer and reporting obligations.
Our obligation to comply with laws, regulations and applicable industry standards.
Our legitimate interest in monitoring, detecting and preventing fraud.
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
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.
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: email@example.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 firstname.lastname@example.org.
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.
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.
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 email@example.com, including your full name, contact details, the details of your request, and a copy of your identity document.
SunPower Corporation UK Ltd.
Birmingham International Park
Solihull, B37 7GN