SOLARMAN Business Privacy Policy

Last Updated: September 2, 2025
Effective Date: September 2, 2025

Preamble

The SOLARMAN Business (hereinafter referred to as “we”, or “IGEN”) is a PV Power Plant Monitoring Platform for new energy assets provided by Wuxi IGEN Technology Co., Ltd.

We are committed to protecting and maintaining your privacy. This Privacy Policy explains how we collect, store, and use your personal information through the app and applies to all services we provide. By using our services, you agree to the terms of this Privacy Policy and consent to our use of the information you provide as outlined herein.

Registered Address: Building H4, China IoT International Innovation Park, No.6 Jingxian Road, Wuxi City

Phone: 4001810512

Email: customerservice@solarmanpv.com

To explain how SOLARMAN Business collects, uses, and stores your personal information, and what rights you have, we will explain relevant matters through this Privacy Policy. The main contents are as follows:

In this Privacy Policy, unless otherwise stated, the following terms have the following meanings:
Personal Information: Refers to information recorded electronically or in other ways that can identify the identity of a natural person alone or in combination with other information, or reflect the activities of a specific natural person, including but not limited to name, phone number, IP address, location information, etc.
Sensitive Personal Information: Refers to personal information that, once leaked or illegally used, may cause damage to personal reputation, or harm to personal and property safety, including ID number, bank account number, whereabouts, etc.
Processing: Refers to operations on personal information such as collection, storage, use, transmission, provision, disclosure, and deletion.
Anonymization: Refers to the irreversible erasure or deletion of personal information to ensure that the identity of the information owner cannot be identified. Any information that has been anonymized will not be regarded as personal information.

If you want to know more detailed information, please read the corresponding chapters according to the following index:

1. Information We Collect and Use

During your use of SOLARMAN Business , we will collect and use the information you voluntarily provide or the information generated during the use of services in the following ways:

1.1 When you register with SOLARMAN Business , we will collect and use your username, phone number, or email address. The purpose of collecting this information is to help you complete the registration of SOLARMAN Business and protect the security of your account. If you do not provide such information, you may not be able to use our services normally. You may also choose to fill in other information according to your needs.

Legal Basis: According to Article 6(1)(b) of the GDPR, processing is necessary for the performance of a contract with you. Processing your email and username is necessary for completing account registration and identity verification.

1.2 During your use of SOLARMAN Business , in order to ensure the normal operation of the services, optimize user experience, and protect the security of your account, we will collect the basic information required for SOLARMAN Business to provide services to you, including your device model, operating system, device MAC address, unique device identifiers (such as IMEI/MEID/IMSI/Android ID/IDFA/IDFV/OAID/UAID, SIM card IMSI, ICCID information, etc.), WIFI status (such as SSID, BSSID), the string assigned to your device by the manufacturer for unique identification, login IP address, SOLARMAN Business number, method, type, and status of network connection, network condition, device sensors (such as accelerometer), operation logs, service logs (such as your searches and browsing in SOLARMAN Business , service failures, referral links, etc.), installation list, and other information.

Legal Basis:Article 6(1)(a) GDPR: The data subject has given explicit consent for their personal data to be processed. Uploading data to the cloud is based on your consent, and you have the right to refuse or withdraw consent.Article 6(1)(b) GDPR: Processing is necessary for the performance of a contract with you. Processing your device data is necessary to provide core functions such as device binding and station information uploading.Article 6(1)(f) GDPR: Processing is necessary for the purposes of our legitimate interests in ensuring service security, maintaining system functionality, and optimizing product experience.

1.3 When you use the monitoring function, in order to allow you to view complete monitoring data, we need to collect the serial number of the data collector installed under the power station and the serial numbers of its sub-devices (such as inverters, meters, etc.). At the same time, our monitoring system will collect data uploaded by the data collector and its sub-devices every 5 minutes to complete necessary data statistics and analysis functions. In addition, in order to diagnose problems for equipment manufacturers in case of equipment failure, provide timely support and services to you, and quickly resolve issues, we will also collect the following telemetry data, including device serial number, device status, and alarm codes.

Legal Basis: Article 6(1)(b) GDPR: Processing is necessary for the performance of a contract with you, to display complete monitoring information and perform statistical analysis.

1.4 When you create a power station, you need to enter information such as the power station name, region, capacity, address, and GPS location. This information will be uploaded and stored on our servers, so that you can use it when logging into SOLARMAN Business on other devices. You can also modify this information at any time. During the subsequent device networking process, the device itself will store the account and password used for device management, which are used for credential verification when you manage the device. The account and password are only stored in the device, and the password is stored in an irreversible encrypted manner.

Legal Basis: Article 6(1)(b) GDPR: Processing is necessary for the performance of a contract with you. This data is used for you to create a power station and subsequent management.

1.5 When you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. In order to provide services according to your request, within your authorization, customer service staff may need to inquire about or verify your relevant information. We will take technical and management measures to ensure the security and confidentiality of your information as much as possible and use this information within the necessary scope. We may also retain your contact information (such as the phone number, WeChat account, QQ number, or other contact methods you use or provide), communication records and content with us, and other necessary information in order to provide and record customer service.

Legal Basis:Article 6(1)(b) GDPR: Processing is necessary to fulfill your request as a data subject.Article 6(1)(f) GDPR: Processing is necessary for our legitimate interests in optimizing services. We retain and analyze relevant data for this purpose.

1.6 According to Article 6(1) GDPR, we may collect and use your personal information without obtaining your consent in the following cases:
a) Processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
b) Processing is necessary for compliance with a legal obligation to which the controller is subject under EU or member state law;
c) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;
d) Processing is necessary to protect the vital interests of the data subject or another person (e.g., emergency medical situations);
e) Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, provided that it does not override the fundamental rights of the data subject.

1.7 To ensure the security of our services and help us better understand operational conditions, we may record information such as your usage frequency of the application, crash data, overall usage, performance data, and application source. To optimize display and performance, we collect screen resolution and RAM (memory) information of the user’s device. We will not combine information stored in our analytics software with any personally identifiable information you provide in the application.

1.8 If we use your personal information beyond the authorized purposes, we will notify you again and obtain your explicit consent before using your personal information.

1.9 Please understand that the functions and services we provide to you are constantly being updated and developed. If a function or service does not specify the rules for collecting and using your information in the above description, we will inform you separately of the scope, purpose, and method of information collection through page prompts, interactive programs, website announcements, or other means, and obtain your consent.

2. Cookie Usage Instructions (Applicable to Official Website)

2.1 What are Cookies

Cookies are small text files stored on your browser or device when you visit our website or use our services. They typically contain the website name, a unique identifier, and certain information that can be read by the website or third-party services during subsequent visits.

2.2 What Cookies We Use

We use cookies and similar technologies to enable basic website functions, including announcement read status, guide read status, system layout, large-screen resolution notification, language switching, assisted login, etc. Some cookies are set by third-party service providers and are used to analyze access patterns. You can manage or refuse the use of cookies through your browser settings.

3. Information Storage

3.1 Storage Location

To better comply with data protection laws and safeguard personal data, we have established a data center in Germany for data storage. If personal data from the European Economic Area, Switzerland, or the United Kingdom is transferred to a country or region not recognized by the European Commission as providing an adequate level of data protection, we will ensure such transfers are adequately safeguarded through the European Commission’s approved Standard Contractual Clauses and, if necessary, take other appropriate technical measures.

3.2 Storage Period

In general, we will retain your personal information for the necessary period to fulfill specific purposes, for example:

Phone number or email address: During your use of the SOLARMAN Business service, we will retain your phone number or email address (including those used for account registration and associated with the account) to ensure your normal use of the service. Such information will be deleted along with the deletion of your SOLARMAN Business account.

Plant information: When you create a plant, we need to retain the plant information to ensure you can normally use the monitoring functions. When you delete your plant information, we will also delete the corresponding data.

If we cease to provide our products or services, we will notify you via messages, announcements, or other means, and delete or anonymize your personal data within a reasonable period, generally within 30 days and no later than 60 days.

4. Information Security

We are committed to protecting users’ information from theft, misuse, unauthorized access, or disclosure.

We will use various security protection measures within a reasonable security level to safeguard information security. For example, we apply encryption technologies (such as SSL/TLS), de-identification, and anonymization measures to protect your personal information.

We will continuously enhance technical measures to strengthen the security of the software installed on devices to prevent data leaks. For example, we will encrypt part of your device information to ensure secure data transmission; collect data on installed applications or running processes, or data stored in the device memory to prevent viruses, trojans, or other malicious programs or websites; analyze and use unique device identifiers, login IP addresses, operation logs, and location data to take measures or issue alerts to prevent illegal activities such as online fraud, account theft, and impersonation, and to conduct security checks.

We have established relevant management policies, procedures, and teams to ensure information security. For example, we strictly restrict personnel who can access the information, require them to comply with confidentiality obligations, and conduct personnel audits.

If a data breach or any other security-related incident occurs, we will respond immediately to prevent further escalation and wider impact and will notify you of such an incident via messages or public announcements.

In terms of information security, SOLARMAN Business has achieved ISO27001 and ISO27701 Information Security Management System certifications.

We will take all possible technical and organizational measures to protect your information, but we cannot guarantee that our measures will eliminate all security risks.

5. Statement on Cross-Border Data Use

To better serve global users, we connect to the corresponding data center according to the user’s region. Overseas users’ data will be stored in the Germany data center to ensure secure and compliant data access.
1. Purpose of connection: To ensure the security of storage and transmission of overseas user data, overseas user data will be processed through connection to servers in Germany.
2. Method of connection: This application will intelligently select the data center based on the user’s location and connect to the corresponding server through encrypted channels to ensure data security.
3. Scope of connection: Overseas IP connections are only used to meet the data needs of overseas users.

6. Information Sharing

To ensure the realization of certain independent functions and to enable you to use and enjoy more services and features, we will embed third-party SDKs within the application and carefully evaluate the purposes of using these SDKs. For more details on the purposes, methods, and scope of SDKs’ personal data processing, please refer to the Third Party Sharing Checklist.

As our business continues to develop, IGEN may engage in mergers, divisions, or other transactions. If such transactions involve the transfer of personal information, we will notify you accordingly and continue to protect or require the new processor to continue to protect your personal information.

7. Your Rights

7.1 Right of Access

You have the right to request access to your personal data held by us at any time and to understand how we collect, use, and process your information. We will respond to your request within the legally prescribed period and provide the relevant information free of charge.

7.2 Right to Data Portability

You have the right to obtain a copy of your personal data held by us and receive such data in a structured, commonly used, and machine-readable format.

7.3 Right to Erasure

You have the right to request that we delete your personal data. We will process your request as soon as possible within the scope permitted by law. If deletion cannot be performed due to legal obligations or other legitimate reasons, we will inform you of the specific reasons.

7.4 Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data to ensure the accuracy of your information. If you find our data inaccurate, please contact us at any time to submit a correction request. We will process your request within the legally prescribed time and update your information promptly.

7.5 Right to Withdraw Consent

You have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent prior to withdrawal. Certain data collection and processing activities (such as device cloud connection, precise location acquisition, etc.) rely on your consent; if you withdraw your consent, we will cease the corresponding data processing, and some features may be restricted or unavailable.

7.6 Right to Lodge a Complaint

If you are dissatisfied with any of our actions, you may choose to lodge a complaint with IGEN. You also have the right to lodge a complaint with the relevant data protection supervisory authority. If you believe that our processing of your personal data violates applicable data protection laws in your country, you have the right to lodge a complaint with the supervisory authority of your EU member state or the supervisory authority at our main place of business.

7.7 Right to Restrict Processing

In accordance with applicable laws, under certain circumstances, you have the right to request that we restrict the manner in which we process your personal information. For example, if you dispute the accuracy of your personal data and we need a period to verify it, you may request that we restrict the processing of such data during that period.

7.8 Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to our processing of your personal data based on legitimate interests. Once you exercise this right, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing, or the processing is necessary for the establishment, exercise, or defense of legal claims.
If we process your personal data for direct marketing purposes, you have the right to object at any time, and once exercised, we will immediately stop processing your data for such purposes.

8. Revisions

This policy may be updated, revised, modified, or changed from time to time as necessary. If any terms of this policy are updated, revised, or changed, we will display the modified policy through push notifications, pop-ups, or other means when you log in to the SOLARMAN Business or update the application version.

9. Other Matters

In certain specific services or functions of the SOLARMAN Business , we may inform you of the purposes, methods, or scope of personal information processing through interactive texts, product interfaces, or pop-up windows. In case of inconsistency, the separately provided information shall prevail.

10. Contact Us

We have established a dedicated Personal Information Protection Team and Data Protection Officer. If you have any questions, complaints, or suggestions regarding this Privacy Policy or personal information protection, you may contact us by any of the following means:
(1) Telephone: 4001810512
(2) Email: customerservice@solarmanpv.com
(3) Data Protection Officer email: isc@igen-tech.com

We will review issues as soon as possible and respond within 30 days of receiving your request or complaint. The subsequent processing period usually does not exceed 90 days. If we encounter special circumstances, we will inform you of the processing time and reasons for the delay within 30 days of receiving your request.