Informativa sulla Privacy

WHES Product and Service Privacy Policy

Latest Version Update Date: [September 1, 2025]
Effective Date: [September 1, 2025]

This Privacy Policy (“Policy”) applies to websites, products, or services of Jiangsu Weiheng Intelligent Technology Co., Ltd. and other affiliated parties (hereinafter referred to as “We” or “WHES”) displayed this Policy or linked to this Policy.

This Policy explains how WHES collects, uses, stores, or processes your personal information in other agreed-upon ways (collectively referred to as “Processing”), but this Policy may not cover all possible data processing scenarios. Information about the collection of product or service-specific data may be elaborated by WHES in specific privacy notices or supplementary statements for those products or services, or in notifications provided at the time of data collection.

Before providing us with any personal information, please read and thoroughly understand this Policy, and confirm that you fully understand and agree to it. [By ticking “I have read the Privacy Policy and agree to its contents” during the product or service registration process and continuing to click the “Register” button], you are deemed to agree to all the contents of this Policy.

If you reject to agree to this Policy, you should immediately stop using our products or services and should not continue to provide or assist in collecting your personal information to us or to third parties we entrust or cooperate with. Except as otherwise provided by laws and administrative regulations, regarding how we process your personal information, you have the right to know and decide, and you have the right to restrict or reject our or other parties’ processing of your personal information; simultaneously, you have the right to request us to explain the rules of personal information processing we provide to you. Based on this, we strongly recommend that you first carefully read this Privacy Policy and make corresponding authorizations based on a thorough understanding of its content.

1. The Personal Information We Collect

1.1 Collection of Your Personal Information

Personal information refers to various types of information recorded electronically or in other ways related to an identified or identifiable natural person, excluding information that has been anonymized. When you use WHES’s products and services or interact with us, we may collect your personal information. Depending on the products and services you use and your interactions with us, the specific types of data collected will vary. You are not required to provide us with personal information, but in some cases, if you choose not to provide it, we may not be able to provide you with relevant products or services, nor respond to or resolve issues you encounter. We will only collect and use your personal information for the purposes stated in this Statement. The personal information we may collect includes:

1.1.1 For the purposes of registering/logging in to products or services (Registration Purposes"):

Personal Information: Your username, email address, and password. Additionally, during registration/login, we may ask you to provide additional information to complete your profile, including your last name, address, etc. If you do not provide this additional information, it will not affect your registration for our services or products.

1.1.2 For providing the remote monitoring service for the WHES product linked to your account (“Monitoring Purposes”):

User identity information, including your username and email address;
Information about WHES products, including product status, serial number, device model, type, capacity, geographical location information, power, and power generation;
Inverter device information, including serial number, model, registration code, device type, power, WHES product, signal strength, software version of the inverter you are using;
Terminal device information, including device parameters and system information, geographic location information, device identifier information (IMEI, IDFA, Android ID, Cell ID, MAC, OAID, IMSI and other device-related information);
Network information, including your IP address, WiFi information;

1.1.3 For providing after-sales services, protecting your legal rights, and jointly resolving related disputes (“After-sales Purposes”):

Fault-related information, including the type of inverter device you use, serial number, device model, installation date, device installation location, fault description, and system log;

1.1.4 For the purpose of improving our products or services and of introducing and promoting our company, products, services, and brand activities to you (the aforementioned services are hereinafter collectively referred to as the “Promotion Services” and the aforementioned purpose as the “Promotion Purposes”), we may collect the following information from you:

Feedback information, including your feedback on products or services;

1.1.5 For providing AI interactive and predictive services (“Service Purposes”)

Interaction information: including the inquiries and problem descriptions you submit via the AI feature, and the responses generated by our AI system;
Device operating data (e.g., energy consumption/generation and usage patterns); Electricity tariffs or rates that you enter manually or obtain through third-party platforms; Location information (latitude and longitude) to determine relevant weather conditions; and Local weather forecast data obtained from third-party APIs.

The above registration purposes, monitoring purposes, after-sales purposes, and promotional marketing purposes are collectively referred to as “Processing Purposes.”

1.2 Processing of Sensitive Personal Information

Please note particularly that, for monitoring purposes, we are required to process your terminal device location information and WHES product location information in order to locate the position of your terminal device and WHES product, and to display or push monitoring information of WHES products to you. For after-sales purposes, we are required to collect your terminal device location information and WHES product location information to locate the position of your terminal device and WHES product and provide services such as repair and replacement. Please understand that if you reject to provide the aforementioned sensitive personal information, we will be unable to achieve the monitoring and after-sales purposes, and cannot provide you with related functions and services.
We are fully aware that once your sensitive personal information is disclosed or used illegally, it can easily lead to infringement of your personal dignity or harm to your physical safety and property security. Therefore, while processing and protecting your sensitive personal information in accordance with the general standards set forth in this policy, we will adopt stricter standards to protect your sensitive personal information. This is to ensure the security of your sensitive personal information, prevent its leakage or illegal use, and avoid any harm to you as a result.
We do not collect any personal information of minors for processing purposes. You should not provide us with any personal information of children.

1.3 Collection of information related to AI interactive services

User consent and notice: Access to the chatbot is an optional feature and will only be activated when you proactively initiate an interaction. By proactively initiating an interaction, you are deemed to have consented to our processing of the content of your inquiries and the chatbot’s responses. We recommend avoiding inputting sensitive personal information when using AI services.

2. How We Process Personal Information

2.1 How We Collect Your Personal Information

For the abovementioned processing purposes, we will collect your personal information either independently or through third parties via web pages, mobile applications, Cookies, and similar device identification technologies, as well as other tools, facilities, or equipment. You can manage or delete Cookies through your browser or device settings; please note that if you disable Cookies, some features may not function properly.
If you provide us with personal information of others, you must ensure that you have obtained separate consent from those individuals for such provision. Otherwise, if our use of the provided information infringes upon their personal information rights, we reserve the right to pursue legal liability against you in accordance with relevant laws and regulations.

2.2 How we use your personal information

For registration purposes, we or a third party entrusted by us will use your personal information in the following ways:

We will identify your user identity based on your nickname, email address, password, and other such information.

For monitoring purposes, we or a third party entrusted by us will use your personal information in the following ways:

We will collect and match your username and email address with device serial number of WHES products.
We will network your inverter device based on device serial numbers and other inverter device information, monitor and calculate your device’s power generation situation, revenue situation, status, and other such situations, and display the information to you through your terminal device. Provided that we collect your geographical location information and match it with device serial numbers for networking or other monitoring purposes, we will obtain your separate consent in a manner in compliance with application laws and regulations.

For After-sales Purposes, we or a third party entrusted by us will use your personal information in the following ways:

We will analyze the cause of the fault and resolve disputes related to products or services together with you based on the fault-related information you provide. Provided that we collect your device installation location to provide feedback or after-sales services, we will obtain your separate consent in a manner in compliance with application laws and regulations.
We will provide feedback and after-sales service for you based on your contact/receiver information.

For Promotion Purposes, we or a third party entrusted by us (including advertisers, other service providers) will use your personal information in the following ways:

We will improve our products and services based on the feedback you provide.
We will send you non-personalized information pushes or commercial marketing, such as sending you electricity usage reminder emails, displaying general information to you, and pushing information, based on your email address and device identifier information.

For Service Purposes, we or a third party entrusted by us will use your personal information in the following ways:

Based on the content of your inquiries and the chatbot’s responses, we will provide and continuously improve our AI services, evaluate the accuracy of AI-generated answers, and extract anonymized frequently asked questions (FAQs). We will not use this data for user profiling or behavioral advertising. In addition, these conversation records may be reviewed by authorized personnel to improve service quality.
Based on the device operating data you provide, electricity rate information, geolocation data, and weather data, we will provide and continuously improve energy load forecasting and automated control functions. This functionality may be used to generate electricity rate forecasts and to execute local control adjustments; results may vary depending on data quality and user behavior.

2.3 How we store your personal information

2.3.1 Storage locations

For personal information collected and generated by us within the territory of the People’s Republic of China (abbreviated as ‘China’), we will store it within China either by ourselves or through a third party (such as server providers).
For personal information collected and generated by us within the European Union (EU), we will store it on servers within the EU either by ourselves or through a third party (such as server providers).
For personal information collected and generated by us in other regions, we will store it in areas compliant with relevant national laws and regulations either by ourselves or through a third party (such as server providers).

2.3.2 Storage duration

We will only retain your personal information for the shortest time necessary to achieve the purpose of processing, unless otherwise stipulated by laws and administrative regulations. After the expiration of the aforementioned storage period, we will delete your personal information according to applicable legal requirements, or anonymize it.

2.4 How We Provide Your Personal Information to Third Parties

We will not provide your personal information to any third party; however, under any of the following circumstances, we may provide your personal information to a third party in compliance with relevant legal provisions:

We have obtained your separate consent;
It is necessary for the conclusion or performance of a contract to which you are a party;
It is necessary for fulfilling legal obligations or defined duties to which we are subject (e.g., providing information to administrative organs, judicial organs, or other state organs as required by relevant laws);
It is necessary to respond to public health emergency events or emergencies to protect the life and health of natural persons;
For the public interest, implementing news reporting, public opinion supervision, and other acts, providing your personal information to a third party within a reasonable range;
In accordance with relevant laws and regulations, providing your personal information to a third party within a reasonable range if it has been legally disclosed by yourself or others, except where you have explicitly rejected;
If you seriously violate laws, regulations, or relevant agreements, rules, and policies, we may disclose your related misconduct behavior and the measures we take against you;
Other circumstances stipulated by laws and administrative regulations.
In the above situations, unless laws and administrative regulations require confidentiality or do not necessitate notification, we will inform you of the recipient’s name or name, contact information, processing purpose, processing method, and type of personal information and other necessary information stipulated by applicable laws and regulations before providing your personal information to a third party.
If we need to transfer your personal information due to mergers, splits, dissolutions, bankruptcy declarations, or other reasons, we will inform you of the recipient’s name or name, contact information and other necessary information stipulated by applicable laws and regulations. The recipient will continue to fulfill the obligations of a personal information processor.

2.5 We Will Not Publicly Disclose Your Personal Information

Unless we obtain your separate consent, we will not actively disclose your personal information.

2.6 Self-Processing and Entrusted Processing

We will process your personal information either by ourselves or by a third party entrusted by us according to the agreed processing purposes and methods. If we process it by ourselves, we will assign necessary employees to represent us in processing your personal information and supervise their personal information processing activities to fully protect your personal information. If we entrust a third party for processing, we will sign an entrusted processing agreement with this entrusted third party and supervise its personal information processing activities to fully protect your personal information. Neither self-processing by employees nor entrusted processing by a third party constitutes to providing personal information for a third party; thus, upon obtaining your consent to this policy, we do not need to obtain your separate consent for self-processing by employees or entrusted processing by a third party. Neither self-processing by employees nor entrusted processing by a third party will alleviate or exempt our obligations and responsibilities as personal information controller.
Specifically, to provide you with products and services, we may integrate software development kits (SDKs) provided by third parties to achieve processing purposes. This may involve entrusting a third party to collect or otherwise process your personal information through their products and services.
AI interactive services: When you use our AI interactive services, your input data (such as text queries) will be sent to the API of a third-party cloud service provider (Aliyun) for processing in order to generate a response. This may involve cross-border data transfer (for example, if Aliyun’s servers are located in other countries/regions). We only transmit the data necessary to provide the Service Purposes and will not use it for any other purposes. You may refer to Aliyun’s privacy policy on how it processes data.

Third Party	Information	Purpose	Privacy policy link
Aliyun	Email, Username, Country, Time Zone, and Operating Log	Data storage	https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-privacy-policy?spm=a2c63.p38356.0.i0
Tuya	Network and Device Information	Internet of Things (IoT) Services and Storage	https://auth.tuya.com/policies/privacy
AWS	Email, Nickname , Country, Time Zone, Equipment Information and Operating Log	Data storage	https://aws.amazon.com/privacy/

2.7 Device Permission Management

In order to process your personal information as mentioned above, we may obtain the following permissions on your terminal device during your use of our products or services:

Permissions to read and write to the built-in SD card and other storage media, so that our products or services can download, write, and display images related to our products and other devices for monitoring purposes;
Permissions to access Wi-Fi information and other network information, and set Wi-Fi connections to specified hotspots, so that our products or services can connect to the internet for monitoring purposes;
Permissions to access Cell ID or Wi-Fi hotspots to obtain location information, so that our products or services can automatically identify power plant locations;
Permissions to access the camera, so that our products or services can automatically obtain the device serial number through the camera;
Permissions to access [precise/coarse location], used for realizing the positioning and map display functions of terminal devices and WHES products;
Permissions to read device identification information, used for network positioning, as well as tracking, troubleshooting, diagnosing, and statistical analysis of various issues in services, ensuring the safe and normal operation of products and services.

2.8 Anonymization Processing

If we take technical measures or other necessary measures to anonymize your personal information, making the processed information unable to identify a specific individual and irretrievable, then the use, storage, provision to third parties, public disclosure, and other handling of such processed information shall not require notification to you or obtaining your consent.

3 How We Protect Your Personal Information

3.1 Personal Information Protection Measures

We attach great importance to the security of your personal information. Based on the processing purpose, method, type of personal information, impact on your individual rights and interests, and potential security risks, we will take the following measures to ensure that personal information processing activities comply with laws and administrative regulations, and prohibit unauthorized access as well as prevent personal information leakage, tampering, and loss:

Establish internal management systems and operating procedures;
Carry out classified management of personal information;
Implement corresponding encryption, de-identification, and other security technical measures;
Reasonably determine the operation authority for personal information processing and conduct regular security education and training for personnel;
Formulate and implement emergency response plans for personal information security incidents;
Other measures stipulated by laws and administrative regulations.

3.2 Personal Information Protection Officer

If the quantity of personal information we process reaches the amount specified by relevant national laws and regulations, or our core activities consist of personal information processing operations which, by virtue of their nature, their scope and/or their purpose, require regular and systematic monitoring of personal information on a large scale, or as required by relevant national laws and regulations, we will designate a personal information protection officer in accordance with applicable laws to supervise the personal information processing activities and protective measures taken. At that time, we will publicly disclose the contact information of the personal information protection officer.

3.3 Compliance Audit for Personal Information Protection

We will regularly conduct compliance audits on our adherence to laws and administrative regulations in processing personal information.

3.4 Personal Information Protection Impact Assessment

We will conduct personal information protection impact assessments and record the processing situation in advance as required by applicable laws. These personal information protection impact assessment reports and processing records will be retained for at least three years.

3.5 Handling of Personal Information Security Incidents

In the event of or potential personal information security incidents such as leakage, alteration, or loss of personal information, we will immediately take remedial measures and, without any delay, notify the department responsible for personal information protection according to applicable laws. If we are unable to take effective measures to prevent harm caused by information leakage, alteration, or loss, or if requested by the department responsible for personal information protection, or if we deem it necessary, we will notify you of relevant circumstances regarding the personal information security incident according to applicable laws, including:

Our contact details, our personal information protection officer contact details (if applicable), the categories and number of data subjects concerned (if applicable), causes, and potential consequence of personal information leakage, alteration, or loss that have occurred or may occur;
The remedial measures we have taken and the measures you can take to mitigate the harm;
We will notify you via email, letters, phone calls, SMS, or other reasonable and effective methods as much as possible. However, if individual notifications cannot be achieved or will cause significant costs for us, we will adopt other reasonable and effective methods for notification.

3.6 The Limitations of Protection

We will strive to protect your personal information, but please understand that due to technological or managerial limitations and potential malicious attacks and external factors, even though we make every effort to implement the aforementioned measures, it is impossible to guarantee the absolute security of personal information at all times. You need to understand that your personal information may be disclosed, altered, or lost due to computer viruses, malicious intrusions, or other factors beyond our control; if such circumstances occur, you should directly pursue legal liability from the infringing party, and we will provide necessary assistance within a reasonable scope.

4. How to Exercise Your Rights over the Processing of Personal Information

You have the following rights regarding the processing of your personal information:

Right to be informed;
Right of access;
Right to rectification;
Right to erasure;
Right to data portability;
Right to restriction of processing;
Right to withdraw consent;
Right to object;
Right not to be subject to automated decision-making;
Right to share data with third parties.

4.1 Right to Be Informed

You have the right to be informed about the processing of your personal information, except as otherwise stipulated by laws and administrative regulations. To ensure your right to be informed, we openly provide you with this policy to fully explain our specific rules for handling your personal information. You should read and fully understand the contents of this policy. To exercise your right to be informed, you can review and save this policy when you first download or register for our products or services, or you can review and save it under the ‘About’ section in the ‘My’ options after logging into the product or service. However, please note that when copying or using this policy, you should avoid infringing upon the copyright of this policy. If you have any questions regarding the rules for processing personal information in this policy, you can send an email to service@whes.com, and we will promptly provide you with explanations and clarifications.

4.2 Right to Restriction of Processing and Right to Object

You have the right to restriction of processing and right to reject the processing of your personal information, with the authority to restrict or reject our processing of your personal information, except as otherwise stipulated by laws and administrative regulations. Please note that when you agree to this policy, it means you have agreed to our processing of your personal information in accordance with this policy.
If you reject our processing of your personal information, you should not agree to this policy and should not continue to provide us with or assist us in collecting your personal information. However, please note that unless otherwise specified in this policy, since the processing of your personal information is necessary for us to provide the services corresponding to various processing purposes, if you reject our processing of your personal information for the processing purposes, we will be unable to achieve such purposes and cannot provide you with the corresponding functions or services.

4.3 Right to Withdraw Consent

You have the right to withdraw your consent for us to process your personal information as granted through this policy.

Registration Purpose

If you no longer agree to our processing of your personal information for registration purposes, you can send us a user identity deactivation notice via thelog-out function within the software. We will process it within 7 days of receipt and deactivate your user identity for you.

After deactivating your user identity, we will delete your personal information related to the registration purpose (excluding anonymized information), except in the following circumstances:

If the retention period prescribed by laws and administrative regulations has not yet expired, or if the personal information is processed for other legitimated interests, we will be unable to delete it and will cease processing except for storage and necessary security protection measures; or
If the personal information is also necessary for other processing purposes and you still consent to our processing of your personal information for other purposes without withdrawing your consent, we may retain and process the personal information for those other purposes.

Please note that processing your personal information is essential for registering/logging into our products or services. Therefore, if you withdraw your consent for us to process your personal information for registration purposes, you will lose your user identity and will be unable to use related products and services. Additionally, your withdrawal of consent does not affect the validity of personal information processing activities we conducted based on your consent prior to the withdrawal.

Monitoring Purpose

If you no longer agree to our processing of your personal information for monitoring purposes, you can reject our provision of remote monitoring services for WHES products through the following method: [You can send a notification to us by email at service@whes.com, and we will respond within 48 hours after receiving such notification].

After you reject our provision of remote monitoring services for WHES products, we will delete your personal information related to the monitoring purpose (excluding anonymized information), except in the following circumstances:

If the retention period prescribed by laws and administrative regulations has not expired, or if the personal information is processed for other legitimated interests, we will be unable to delete it and will cease processing except for storage and taking necessary security protection measures; or,
if the personal information is also necessary for other processing purposes and you still agree to our processing of personal information for other purposes without withdrawing your consent, we may retain and process personal information for other processing purposes.

Please note that processing your personal information is essential for us to provide remote monitoring services for WHES products. Therefore, if you withdraw your consent for us to process your personal information for promotional service purposes, we will be unable to provide you with remote monitoring services for WHES products, and you will not be able to view or monitor information related to WHES products and devices. Additionally, your withdrawal of consent does not affect the validity of personal information processing activities we have conducted based on your consent prior to the withdrawal.

After-Sales Purpose

If you no longer agree to our processing of your personal information for after-sales purposes, you can reject our provision of after-sales services through the following means: [You can send us a notice by email to service@whes.com, and we will respond within 48 hours after receiving such notice].

We will delete your personal information related to after-sales purposes (excluding anonymized information) after you reject our provision of after-sales services, except for the following circumstances:

If the retention period prescribed by laws and administrative regulations has not expired, or if the personal information is processed for other legitimated interests, we will be unable to delete it and will cease processing except for storage and taking necessary security protection measures;
If the personal information is also necessary for other processing purposes and you still agree to our processing of personal information for other purposes without withdrawing your consent, we may retain and process the personal information for other purposes.

Please note that since processing your personal information is essential for us to provide after-sales services, if you withdraw your consent for us to process your personal information for after-sales purposes, we will be unable to provide you with after-sales services through our products or services. Additionally, your withdrawal of consent does not affect the validity of the personal information processing activities we conducted based on your consent prior to the withdrawal.

Promotional Marketing Purpose

If you no longer agree to our processing of your personal information for promotion purposes, you can reject our promotion services through the following means: [You can send an email to service@whes.com, and we will respond within 48 hours after receiving such notification.]

After you reject our promotion services, we will delete your personal information related to the promotion service purpose (excluding anonymized information), except in the following circumstances:

If the retention period stipulated by laws and administrative regulations has not expired, or if the personal information is processed for other legitimated interests, we will be unable to delete it and will cease processing except for storage and taking necessary security protection measures; or
If the personal information is also necessary for our other processing purposes and you still agree to our processing of personal information for other purposes without withdrawing your consent, we may retain and process the personal information for other purposes.

Please note that processing your personal information is essential for us to provide promotion services. Therefore, if you withdraw your consent for us to process your personal information for promotion service purposes, we will be unable to provide you with promotion services, and you will not receive our information push. Additionally, your withdrawal of consent does not affect the effectiveness of personal information processing activities we conducted based on your consent prior to the withdrawal.

Please pay special attention that before exercising your right to withdraw consent, please thoroughly consider the consequences of withdrawal. Once you withdraw your consent for us to process your personal information for individual or all processing purposes, we will be unable to continue providing you with corresponding functions or services. The consequences and responsibilities arising from this will need to be borne by you, including any losses incurred to you or any third party due to your inability to use the corresponding functions or services.

Service Purposes

If you no longer agree to our processing of your personal information for service purposes, you may request deletion through the following means:

For AI interactive services, you may send an email to service@whes.com specifying the time period of the interaction records to be deleted. We will complete the deletion within 72 hours after receiving your notice. Once deleted, these records will no longer be used to optimize the AI interactive service; however, this does not affect anonymized FAQs that have already been generated based on those records.

For predictive services, as this service is optional, you may disable it at any time in your device settings or within the application. You may also send an email to service@whes.com specifying the relevant data to be deleted, and we will complete the deletion within 72 hours after receiving your notice.

5. Others

5.1 How We Process Personal Information of Children

Our website, products, and services are intended for legal adults. We do not provide services or collect any personal information from children. If WHES discovers that it has collected personal information of a child without prior verifiable parental consent, it will endeavor to delete such data as soon as possible.

5.2 How Your Personal Information is Transferred Globally

WHES is a multinational company, which means that the personal information we collect about you may be processed in countries or regions where you use our products or services, or where WHES, its affiliates, subsidiaries, service providers, business partners, or establishments are located. These countries or regions may have different data protection laws. In such cases, WHES will take measures to ensure that the data we collect is processed in accordance with this policy and applicable laws. This includes, when personal information of data subjects located in the European Union is transferred to countries or regions with data protection levels not recognized as equivalent by the EU, WHES will take various legal mechanisms for appropriate safeguards, including without limits to the execution of Standard Contractual Clauses (e.g. Standard Contractual Clauses adopted by the European Commission) or requesting your explicit consent for cross-border transfer of personal information or implement security measures such as anonymizing personal information before cross-border data transfers. You may click here to obtain a copy of the executed EU Standard Contractual Clauses https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

5.3 Updates to this Policy

We reserve the right to update or modify this policy from time to time. If any modifications result in a material reduction of your rights under this policy, we will notify you of the changes through methods such as email, mail, telephone notification, announcements, or in-app push notifications.
If you receive a notice of change but do not agree with the provisions of this policy after modification, you should promptly notify us in writing. Otherwise, it will be deemed that you accept the modifications we have made to the relevant terms of this policy. If you continue to provide or cooperate in collecting your personal information for us or our authorized third parties, or continue to use our products or services after receiving the notice of change, it will be deemed that you accept the modifications we have made to the relevant terms of this policy.

5.4 How to Contact Us

If you have any questions, opinions, or suggestions regarding this policy or any matters related to your information, you can contact us by sending an email to service@whes.com.