1. Purpose

We are committed to safeguarding the privacy of the personal information that we gather from you concerning you as our customers (“you”or“customers”). In this Privacy Policy for Customers (this “Policy”) we explain:

• what information we collect from you;
• how we use that information; and
• how you can get access, update or ask for removal of your information.

2. The Application of this Policy 

This Policy applies to your personal information and to the use of that personal information in any form – whether oral, electronic or written.
 
This Policy gives effect to Delta Electronics’ commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, own and/or provide services to various Delta Electronics’ legal entities. Those entities include Delta Electronics (Netherlands) B.V. and its direct and indirect subsidiaries, including  but not limited to, Delta Electronics (Switzerland) A.G., Delta Solutions (Finland) Oy, Delta Electronics (France) S.A., Delta Electronics (Poland) Sp.z.o.o., Delta Electronics (Czech Republic) spol.s.r.o., Delta Electronics Solutions (Spain), S.L., Delta Electronics (Italy)S.r.l., Delta Electronics Europe Limited, and all of the separate and distinct legal entities that own the individual Delta Electronics properties worldwide. References to “Delta Electronics”, “we” and “our” throughout this Policy, depending on the context, collectively refer to those separate and distinct legal entities, including the entity with which you have or may have a customer relationship. 

3. Information we collect

We collect information, mostly the information on your business card, and information you provide to us, in order to provide newsletters, technical supports, application (app) services, promotion activities, events, and product information to you.

We collect information in the following ways, including the device information:

• Information you give to us. The personal information like your name, e-mail address, home address, telephone number, company name, company address and job position we ask you to fill in when you sign up for newsletters, request for technical support on our webpage, or request for unique applications such as app or webpage back office.
• Unique applications. Certain services (for example the EV charger, UPS,  PV inverter’s on-site monitoring, maintenance and control systems or other products sold by Delta Electronics) require your personal information to set up a user account. 
• Location information. When you subscribe to our unique application, we may collect and process information about our products’ actual location for the purpose of providing EV charger, UPS or PV inverter’s on-site monitoring services. We use various technologies to determine location, including, but not limited to, IP address, GPS and other sensors that are currently sold or shall be sold by Delta Electronics that may provide us with information so that we can target the right machine and produce correct electricity consumption data and machine working conditions for you.
• Log information. When you use our services in some unique applications, we automatically collect and store certain information in server logs. This includes (but is not limited to):
  • the details of how you used our applications;
  • telephony log information such as phone number, time and date of calls, duration of calls, routing information and types of calls;
  • internet protocol address;
  • time and date of your log in; and
  • device information, including hardware and software settings.

4. How we use information we collect

The information we collect from you is only used for providing you services upon your request.  Such services includes, without limitation, providing newsletters, promotion activities, events, product information (when you sign up for newsletter), technical support on using our products, repair and replacement services, and/or to provide product app or back office management services, including without limitation, on-site monitoring, maintenance and control services to our products (when you sign up for unique applications).  

We will ask for your consent to process your personal data before you subscribe to our services.

5. Data Transfer

Like most international businesses, we have centralized certain aspects of our data processing and administration in accordance with applicable laws in order to allow us to better manage our business. That centralization may result in the transfer of personal information from one country to another. For example, some personal information concerning you will be transferred to and processed by servers located outside the European Economic Area (EEA), in particular the United States of America. 

All personal information transferred to the United States of America is processed by processors that have been certified by the Department of Commerce of the United States of America as providing adequate privacy protection on the same level as the EU standards on the basis of the EU-US privacy shield agreement, effective as of 1 August 2016.
 

6. Accessing your personal information (for unique application only)

All requests for access to your personal information must be submitted in writing by emails. We may respond to your request by email or any other suitable method.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort or risk the privacy of others.

We respond free of charge to your request for access or correction of your personal information, unless such access or correction requires a disproportionate effort. If so required for warranty, support and maintenance or statutory requirements, we may keep your information in our backup systems after you have deleted information from our services in a manner that protects information from accidental or malicious destruction or use.  

Whenever you apply for our unique applications, for example, an account to do on-site monitoring, maintenance and control to our products, we will provide you with separate contact person/information to maintain your account. We have to keep that account information for legitimate business and legal purposes. When updating your personal information, we may ask you to verify your identity before we act on your request.

7. Rights of a Data Subject

In regard to your personal information, and according to Chapter III GDPR (Rights of the Data Subject), you may request Delta to execute the following rights:

• Inquiry or request to read;
• Request to make copies;
• Request for supplement or correction;
• Request to stop collection, processing and utilization;
• Request deletion;
• Refuse Delta the use of your personal information for marketing;
• Request for data transfer to a third-party service provider with necessary needs and to meet the technical constraints; and
• Submit a complaint or request report of any existing or potential privacy incident.

Delta should provide you with sufficient information, so that you can understand how to execute your rights as a data subject. Delta should also implement notification obligations at the appropriate time and manner in accordance with the requirements of personal information relevant regulations, including clearly informing you of the rights of a data subject, and should ensure that any other information has been clearly expressed to you. 
You may submit a data subject request regarding the personal information we maintain about you by:

• e-mail. You may e-mail to us at EMEA-PRIVACY@deltaww.com. When you send out request by e-mail, please be sure to include your personal information on your business card including your full name, company name, job position so we can ascertain your identity and the personal information we maintain about you. We may not disclose data that you are not entitled to receive under applicable laws (e.g., data revealing information about another individual).

• clicking on the “unsubscribe” link. If you subscribe to newsletters with us, then you may find the “unsubscribe’ icon at the last paragraph of the newsletter. Click on “unsubscribe” icon and it will take you to the unsubscribe link. Once you unsubscribe, we will remove your personal data from our database. Should you wish to change your personal information, we kindly request you to send us an e-mail in the manner detailed in the previous paragraph “e-mail”.

Before we accept your request, we will do necessary identity check to ensure that you are the same person as you claim. When we have reasonable doubt that you are not the person you claim, we will reject your request directly. When we accept your request, the action we do for meeting your request is usually free of charge. However, we reserve the right to charge you a fee when we discover your request behavior is a harassment (an unreasonable unwanted and annoying action). This fee will be 22.50 EUR each time for your request from the moment your harassment behavior begins. We will notify you in a separate notification about the detailed payment method, in order to cease this unreasonable and annoying request, we will not take any action before we actually receive the correct payment from you. This amount is subject to changes according to the extent permitted under applicable law. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.
You may request that we correct, delete or stop processing, personal information that we hold about you on legitimate grounds by sending an email to the address set out above. If we agree that the information is incorrect, or that the processing should be stopped, we will delete or correct the information. If we do not agree that the information is incorrect, we will tell you that we do not agree and record the fact that you consider that information to be incorrect in the relevant file(s).

8. How we share information

We do not share your personal information with any third parties that is outside Delta Electronics unless one of the following circumstances applies:

• With our service partners
  
  Our service partners may provide services for us. We need to share your registered personal information with them in order to provide you services stated in section 4.
  
  In the case of unique applications, we need to share your personal information to the software developers/ account manager in order to set up your account.    
• With our associated enterprises and affiliates 
  
  We may provide your personal information to our associated enterprises and affiliates, or other trusted businesses or persons to process or store your information for us.
• For legal reasons
  
  We will share your personal information with companies, organizations or individuals outside Delta Electronics if we have a belief in good faith that access, use, preservation or disclosure of your information is reasonably necessary to:
  • meet any applicable laws, regulations, legal processes or enforceable governmental requirements;
  • enforce our services, including investigation of potential violations;
  • detect, prevent possible fraud, infringement of security or technical issues; and
  • protect against harm to our rights, property or data security, or other user’s/public safety.

9. Information security

We work hard to protect your personal information from unauthorized access, alteration, disclosure or destruction of information that we hold. We restrict access to your personal information to our employees, contractors and service partners who need to know in order to process / provide services to you. We protect your personal information the same way as we protect ours from hacking, unlawful leaking, and any malice theft done by any third party. We will keep your personal information, until you unsubscribe our newsletter or when we accept your removal request in writing by e-mail.   

10. When and to​ what this policy applies

This policy applies to services stated in section 4 offered by Delta Electronics and its affiliates, associated enterprises.
This policy does not cover the commercial practices of other companies and organizations that advertise our service.

11. Changes

Our policy may change from time to time. We will not reduce your rights under this policy without your explicit consent. We will post any changes in the newsletter, and if the changes are significant, we will provide a notice or an announcement on product webpage, or by a separate e-mail notification.

Effective Date: May 25, 2018