1. Introduction

Sieyuan Electric Co., Ltd., together with its subsidiaries and affiliates (collectively, “Sieyuan,” “we,” “us,” or “our”), respects your privacy and is committed to protecting the personal data of visitors to en.sieyuan.com and related regional and product sites (the “Site”), as well as individuals who otherwise interact with us — including prospective and existing customers, business partners, suppliers, and job applicants.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, how long we keep it, and the rights available to you, wherever in the world you are located. Because Sieyuan operates and sells in more than 100 countries, this Policy is designed to meet a global baseline of good data protection practice while also addressing specific requirements under:

· the EU General Data Protection Regulation (GDPR) and the UK GDPR / Data Protection Act 2018;

· the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA); and

· the Personal Information Protection Law of the People’s Republic of China (PIPL).

Where a specific jurisdiction’s law grants you rights beyond the general provisions of this Policy, the region-specific sections in Section 11 apply in addition to, and where relevant in place of, the general provisions.

This Privacy Policy should be read together with our Cookie Policy, which provides further detail on the cookies and similar tracking technologies used on the Site.

If you do not agree with this Policy, please do not use the Site or otherwise submit personal data to us.

2. Who Is Responsible for Your Data (Data Controller)

For most processing described in this Policy, the data controller (or, under PIPL, the “personal information handler”) is:

Sieyuan Electric Co., Ltd.
Registered address: 3399 Huaning Road, Minhang District, Shanghai, China
Email: [email protected]
Phone: +86-021-61610502

Where you interact with a local Sieyuan subsidiary, sales office, or authorized distributor in your region, that entity may act as an independent controller or as a joint controller together with Sieyuan Electric Co., Ltd. for the relevant processing. A list of our group companies is available at en.sieyuan.com/structure; details of the specific entity responsible for a given interaction can be requested using the contact details in Section 16.

EU/EEA and UK representatives. In accordance with Article 27 GDPR and Article 27 UK GDPR, we have appointed the following representatives for data subjects in the EU/EEA and UK respectively:

· EU representative: Zhenyu Mao, [email protected]

· UK representative: Tonny Lian, [email protected]

Data Protection Officer. You can contact our Data Protection Officer / privacy team at Jinjing Peng, [email protected].

3. Personal Data We Collect

We collect the following categories of personal data, depending on how you interact with us:

3.1 Information you provide directly

· Contact and inquiry data: name, job title, company name, email address, phone number, country/region, and the content of any message, when you submit a contact form, request a product or service quote, register interest in a product, or otherwise contact us (including via live chat, where offered).

· Job applicant data: name, contact details, CV/resume, cover letter, employment history, education, qualifications, references, and any other information you choose to submit when applying for a position through our “Join Us” / careers section.

· Marketing and communications data: your contact details and preferences when you subscribe to newsletters, technical updates, or event invitations. Newsletter sign-up requires you to actively check a consent box confirming you agree to receive these communications; we keep a record of that consent (and of any later opt-out) as evidence of your choice.

· Correspondence: records of communications between you and Sieyuan, including emails, call notes, and chat transcripts.

3.2 Information collected automatically

· Usage and log data: IP address, browser type and version, device identifiers, operating system, referring/exit pages, pages viewed, time and date of visit, and clickstream data.

· Cookie and tracking data: information collected through cookies, pixels, and similar technologies, such as session identifiers, analytics identifiers, and advertising identifiers. See our Cookie Policy for the categories of cookies used, their purposes, and how to manage your preferences.

· Approximate location data: general location inferred from your IP address or (where you use a mobile app or grant permission) device positioning; you can generally disable device-level location sharing through your device settings.

3.3 Information from third parties

We may receive personal data about you from:

· business partners, distributors, and resellers who introduce you as a prospective customer;

· publicly available sources (e.g., company registries, professional networking profiles) in a business-to-business sales context;

· background-check or reference providers, where applicable, in connection with job applications;

· analytics and advertising partners (e.g., Google Analytics, LinkedIn Insight Tag, or similar tools), as described in our Cookie Policy.

3.4 Sensitive personal data

We do not intentionally collect sensitive personal data (such as health information, racial or ethnic origin, religious beliefs, or biometric data) through the Site. If you choose to include such information in a message to us (for example, in an open-text field of a job application), you do so voluntarily and we will only use it for the specific purpose for which it was provided, or as required by law.

4. How We Use Your Personal Data

We use personal data for the following purposes:

Legal bases for processing (GDPR/UK GDPR)

Where the GDPR or UK GDPR applies, we rely on one or more of the following legal bases:

· Contract: processing necessary to take steps at your request prior to entering into a contract, or to perform a contract with you (e.g., responding to a quote request, fulfilling an order).

· Legitimate interests: processing necessary for our legitimate interests, such as operating and securing the Site, direct marketing to existing business contacts, and improving our products and services — provided these interests are not overridden by your rights and interests.

· Consent: processing based on your consent, such as non-essential cookies or opt-in marketing emails, which you may withdraw at any time.

· Legal obligation: processing necessary to comply with a legal obligation to which we are subject.

5. How We Share Your Personal Data

We do not sell your personal data. We may share personal data with:

· Group companies and affiliates, including local Sieyuan subsidiaries and sales offices, for the purposes described in this Policy;

· Service providers and processors who perform services on our behalf, such as website hosting, IT support, analytics providers, marketing platforms, customer relationship management (CRM) tools, and background-check providers, under contractual terms that require them to protect your data and use it only for the purposes we specify;

· Distributors, agents, and business partners involved in fulfilling a quote, order, or service request you have initiated;

· Professional advisers, such as lawyers, auditors, and insurers, where necessary;

· Public authorities and regulators, where required by law, regulation, legal process, or governmental request, or where necessary to protect the rights, property, or safety of Sieyuan, our users, or others;

· A successor entity, in connection with a merger, acquisition, reorganization, or sale of assets, subject to appropriate confidentiality and data protection safeguards.

Any third party we share personal data with is contractually required to implement appropriate technical and organizational measures to protect that data and to use it only for the agreed purposes.

6. International Data Transfers

As a global company headquartered in China with operations and customers worldwide, we may transfer personal data across national borders, including to China and other countries that may not have data protection laws equivalent to those in your home jurisdiction.

· From the EEA/UK: where we transfer personal data outside the EEA or UK, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (or the UK International Data Transfer Addendum), or another legally recognized transfer mechanism. You may request a copy of the relevant safeguard by contacting us using the details in Section 16.

· From China: cross-border transfer of personal data collected in China is carried out in accordance with PIPL, using one or more of the mechanisms it permits (e.g., a security assessment by the Cyberspace Administration of China, a standard contract for cross-border transfer of personal information, or certification), and only after obtaining any separate consent required by law.

· General: wherever personal data is transferred internationally, we take steps designed to ensure it continues to be protected in accordance with this Policy and applicable law.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. In general:

· Contact and quote inquiry data is retained for up to 2 years from your last contact with us, or longer where an active business relationship continues.

· Job applicant data is retained for up to 2 years after the recruitment process concludes, unless you consent to a longer retention period for future opportunities, or a longer period is required to comply with law or defend legal claims.

· Cookie and analytics data is retained in accordance with the retention periods set out in our Cookie Policy.

· Marketing data is retained until you unsubscribe or opt out, plus a reasonable period to give effect to that choice and evidence compliance.

Criteria used to determine retention periods include the duration of our relationship with you, applicable statutory limitation periods, and any specific legal or regulatory retention obligations. At the end of the applicable retention period, personal data is securely deleted or anonymized.

8. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, and destruction, including the use of encryption (such as TLS/SSL) for data in transit, access controls, and security monitoring. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals and relevant supervisory authorities as required by applicable law.

9. Job Applicants

If you apply for a role with Sieyuan, we process your application data to assess your suitability for the position, to communicate with you about the recruitment process, and, where you agree, to consider you for other suitable roles. We may share your application with the relevant hiring team and, where applicable, with background-check or reference providers engaged for that purpose. Retention of applicant data is described in Section 7. You have the same rights described in Section 11 with respect to your application data.

10. Children’s Privacy

The Site is intended for business and professional audiences and is not directed at children. As a single global standard, we do not knowingly collect personal data from individuals under the age of 16, regardless of the lower age thresholds permitted in some jurisdictions. If you believe a child has provided us with personal data, please contact us using the details in Section 16 so that we can delete it.

11. Your Privacy Rights

Depending on your location, you may have some or all of the rights described below. To exercise any of these rights, please contact us using the details in Section 16. We may need to verify your identity before responding, and we will respond within the timeframe required by applicable law.

11.1 If you are in the EEA, UK, or Switzerland (GDPR / UK GDPR)

Subject to certain exceptions and conditions under applicable law, you have the right to:

· Access a copy of the personal data we hold about you;

· Rectification of inaccurate or incomplete personal data;

· Erasure of your personal data in certain circumstances (“right to be forgotten”);

· Restriction of processing in certain circumstances;

· Data portability, i.e., to receive certain personal data in a structured, commonly used, machine-readable format;

· Object to processing based on legitimate interests or for direct marketing purposes;

· Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal; and

· Lodge a complaint with your local data protection supervisory authority, or with the supervisory authority in the country where the alleged infringement occurred.

11.2 If you are a California resident (CCPA/CPRA)

You have the right to:

· Know/access the categories and specific pieces of personal information we have collected about you, the sources, purposes, and categories of third parties with whom it is shared;

· Delete personal information we have collected from you, subject to certain exceptions;

· Correct inaccurate personal information;

· Opt out of the “sale” or “sharing” of personal information (as those terms are defined under the CCPA/CPRA). We do not sell personal data for monetary consideration. We do share certain identifiers (such as your IP address and online identifiers linked to Google Ads click IDs (gclid) and UTM campaign parameters, and to LinkedIn Ads’ li_fat_id) with Google and LinkedIn for advertising and analytics purposes, which qualifies as “sharing” under the CPRA. You may opt out of this sharing using the cookie preference/consent tool described in our Cookie Policy, or by enabling a recognized opt-out preference signal (such as Global Privacy Control) in your browser;

· Limit the use and disclosure of sensitive personal information, to the extent applicable; and

· Non-discrimination for exercising any of these rights.

You may exercise these rights by contacting us at [email protected], or, where applicable, by using the “Do Not Sell or Share My Personal Information” mechanism referenced in our Cookie Policy. You may also designate an authorized agent to make a request on your behalf, subject to identity verification and confirmation of the agent’s authorization.

11.3 If you are in mainland China (PIPL)

In accordance with PIPL, you have the right to:

· Know and decide about the processing of your personal information, and to restrict or refuse its processing, except where otherwise provided by law;

· Access and copy your personal information;

· Correct or supplement inaccurate or incomplete personal information;

· Delete your personal information in circumstances specified by PIPL, including where the purpose of processing has been achieved or is no longer necessary, or where we cease providing products or services;

· Withdraw consent, where processing is based on consent;

· Obtain an explanation of our personal information processing rules; and

· Request transfer of your personal information to a personal information handler designated by you, where the conditions specified by the Cyberspace Administration of China are met.

You may lodge a complaint with your local cyberspace administration or other competent authority.

11.4 If you are located elsewhere

Even where a specific data protection law does not grant you the rights above, we will generally seek to honor reasonable requests to access, correct, or delete your personal data, consistent with applicable law and our legitimate business needs, on a good-faith basis.

11.5 Marketing opt-out

You can opt out of marketing communications at any time by using the “unsubscribe” link in any marketing email, or by contacting us using the details in Section 16. This will not affect service-related or transactional communications.

12. Automated Decision-Making

We do not currently use your personal data to make decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects on you. If this changes, we will update this Policy and provide the information required by applicable law, including your right to obtain human intervention.

13. Third-Party Links

The Site may contain links to third-party websites, including social media platforms and partner or distributor websites. This Policy does not apply to those third-party sites, and we encourage you to review their privacy policies before providing any personal data to them.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will post the updated version on this page with a revised “Last updated” date and, where required by law, will provide additional notice or seek consent for material changes. We encourage you to review this Policy periodically.

15. Cookie Policy

For details on the cookies and similar technologies used on this Site, including how to manage your cookie preferences, please see our Cookie Policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, or wish to exercise any of the rights described above, please contact us at:

Sieyuan Electric Co., Ltd.
Attn: Jinjing Peng, Privacy Team
Address: 3399 Huaning Road, Minhang District, Shanghai, China
Email: [email protected]
Phone: +86-021-61610502

If you are not satisfied with our response, you have the right to lodge a complaint with the data protection supervisory authority in your country of residence, place of work, or the place of the alleged infringement.