Privacy Statement

NEP LLC. (hereinafter referred to as "we" or "NEP") through this privacy statement, NEP would like to inform you that you are accessing NEP's server system (*.NEP.com, *.NEP.com.cn) and related online services, the scope and purpose of personal data processing. By using or continuing to use NEP services, you agree to our collection, storage, use and sharing of your personal information in accordance with this statement.

This statement will help you understand the following:

1. Our Statement
2. Scope of application of this statement
3. How we collect and use your personal information
4. How we use cookies and similar technologies
5. Use of Google Analytics
6. Sign up for NEP's online services
7. Use of Google Maps
8. How we share, transfer and publicly disclose your personal information
9. How to manage personal information
10. Use of third-party data services
11. Data transfer
12. Data storage cycle
13. Terms of Use for Minors
14. Privacy Policy Amendments and Notices
15. Contact us

1.Our Statement

We are committed to respecting and protecting the privacy and personal information you provide, and hope you can understand our privacy protection policy, including how to collect, use and disclose your personal information. We designate a dedicated team to manage the protection of your personal information and report directly to the Board of Directors and the General Manager on matters related to privacy protection.

2.Scope of application of this statement

This statement applies to all functions and services of NEP edge gateways, apps and cloud services.

3.How we collect and use your personal information

Every time we visit our website or cloud service, whether registered or not, we collect the following information: IP address of edge gateway device or user terminal device, website or cloud service query through TCP/IP service and the time of the query, Status and content of the data transferred, this data is usually stored for three months and then automatically deleted.

We use this data to operate our website, in particular to identify and correct errors, in order to determine the correct use of our online services and to adjust or improve them.

When you register for an account, the information we may collect includes: username, organization name, phone number and email address. The above information is collected to assist you in creating your account.

When you use the site monitoring function, we will collect information about the sites you add, including: site name, site type, site status, site location, installed power, real-time power, source, network, load, and storage quadrant power data and fault data (eg alarm name, device name, time of occurrence, report data) so you can manage and monitor devices within your site.

When you use the functions and services we provide, we will collect your operations, location clicks and other information within the NEP cloud service platform as relevant web logs to ensure data security. This helps to improve our website and error analysis etc. This includes your device information such as operating system, device model, device manufacturer, system version, account information, date and time of access, and IP address.

Other functions:：

• Additional functionality based on GPS location permissions. You can create a site or a sitemap after enabling the location permission, requiring you to provide the site's location information before, or the location information of your mobile device when creating the site.
• Additional functions based on camera and album permissions. You can use this function after enabling the camera and album permissions to scan QR codes, upload avatars, upload site pictures, and other functions.
• Additional functionality based on Bluetooth permissions. You can perform near-end debugging of the device through Bluetooth after enabling the Bluetooth permission.

When you enable the above permissions, you authorize us to access your mobile phone or smart terminal device and the corresponding personal information to achieve the above functions. If the corresponding permission is turned off, the corresponding authorization will be cancelled. We will not continue to collect and use your corresponding personal information, nor will we be able to provide you with corresponding functions. Data collected prior to cancellation will remain in our systems unless deletion is specifically requested.

4.How we use cookies and similar technologies

Like many websites, we also use cookies. Cookies are small text files that are sent from our web server to your web browser when you visit our website and saved on your computer for later access. Cookies allow us to identify the end device you are using and immediately provide any default settings.

The content of the cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. The use of cookies can help you avoid duplicating personal information, entering searches, steps and processes (eg filling out forms, searching history). You can manage or delete cookies according to your preferences. Most browsers provide users with the function of clearing browser cache data, and users can perform corresponding data clearing operations in the browser settings. However, you may not be able to fully experience some of our convenience and security service functions. We use both session cookies and persistent cookies. Session cookies are automatically deleted at the end of a browser session. In contrast, persistent cookies have a longer storage period and are stored for a predetermined period of time.

In order for you to be able to use our website, it is necessary to allow the use of cookies. We use these cookies to record and save certain user settings and information, for example, to identify and/or authenticate users (eg using the login function).

We use analytics cookies to record and statistically evaluate user usage patterns (e.g. advertiser banner clicks, subpage visits, search queries, etc.). We use the Google Analytics tool for analysis for these purposes. You can find additional information on this in the "Use of Google Analytics" section.

5.Use of Google Analytics

On NEP's website, we use Google Analytics and/or Google Universal Analytics, a web analytics service ("Google") from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses cookies to analyze your use of our website. The information generated by these cookies about your use of our website is usually transmitted to a Google server in the United States and stored there. On behalf of the operators of these websites, Google uses this information to evaluate your use of the websites, to compile reports on website activity, and to provide the website operators with other services related to website and internet usage. Google may transfer this information to third parties as required by law or where third parties process the information on its behalf. IP addresses are anonymous and therefore cannot be tracked. The United States does not have data protection comparable to that of the European Union. However, Google is a member of the EU-US Privacy Shield https://www.privacyshield.gov/EU-US-Framework. In conjunction with the use of Google Analytics, we create pseudonymized usage profiles. Unless otherwise expressly agreed, these pseudonym usage profiles are neither combined with personal data about the pseudonym holder nor with the IP address sent by your web browser.

You can prevent the collection and processing of data generated by cookies and data relating to your use of the website by downloading and installing the available web browser add-on via the following link: tools.google.com/dlpage/gaoptout.

6.Sign up for NEP's online services

If you register for our online services on our website or cloud services, you can use the corresponding authorization services we provide for different registered user roles. If you register for an online service, this will register you for all online services covered by this privacy statement, and you can log in to each online service using the same login credentials.

After registration, you can specifically register smart energy devices, system objects and devices (hereinafter referred to as "devices") according to the terms of use of different NEP edge gateways or third-party hardware devices. Registering devices allows you to easily visualize or manage various types of devices remotely.

• User Account
In order to use NEP online services, you must create a user account. When setting up your user account, you will be prompted to provide some information about yourself. Required fields in this process are marked as such. You can review and change the information you provide in your user account at any time. Information about you includes first name, last name, company, business address, credit code or tax ID number, contact details (phone number, email address). In any case, you must also provide an email address and password when registering. You may be prompted for additional information if you wish to use a particular service. Your user account will be used by NEP to perform contractual services for you.
• Equipment operating data
After you set up a user account, you can register one or more third-party hardware devices. Once a device is registered, we will collect and store baseline data that you provide or transmit to the device (such as obtained or transmitted from NEP) ("Device Baseline Data"), such as device name, commissioning date, location, site installation or maintenance operations staff and other technical details.
If a device is registered, we will collect and store performance data for that device ("Performance Data"), such as performance values for PV generation, grid-provided power and grid feed, charging and discharging of any batteries, and the device of current, voltage, and other measurements. Performance data must be collected in order to provide the services we provide, in particular the graphical display and statistical evaluation of the energy production and consumption of your equipment and the reporting of failures.
Device baseline data and performance data must be processed in order to perform the contract of use with you in accordance with the applicable specific contractual provisions. In addition to providing the services provided as part of our online services, we also use performance data to compile statistics, assessments and forecasts.
• Collection and use of grid status data
We also collect and maintain general technical data on the state of the utility grid when registered devices are interconnected, known as grid state data. The interconnection point is usually at or near the location of the equipment. For private home users, the junction box is the point of interconnection. For example, we collect and save the following grid state data: voltage, phase angle, frequency and impedance. This data is not reliant on utility grid usage alone and does not allow for any inferences about equipment usage, power consumption, amount of current generated by equipment, or other personal circumstances.
We collect and maintain grid status data to support cost-effective grid operations in accordance with local regulations. For this purpose, we provide grid status data to some grid operators and other utility service providers. After transmission, grid status data will be forwarded according to the device address. This address must be referenced to find the interconnection point. No other information is sent. We only transfer these records to grid operators and utility service providers that operate the utility grid at the appropriate location. The use of grid status data by us and the grid operator or utility service provider for the above purposes will be in compliance with local regulations.

7.Use of Google Maps

We also embed some maps from the Google Maps service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94034, USA ("Google").

If you visit a page on our website that contains Google Maps, your web browser will establish a direct link to Google's servers. This way, Google can generally obtain all the information that Google's web servers request from your web browser. In particular, this includes the IP address, the web browser used and the computer's operating system, as well as other data typically stored in server log files. When you visit our website from an area not covered by the Google Maps service, we do not provide related services by default.

We have no right to influence Google's processing and use of data. If you do not want Google to collect, process or use data about you through our website, you can disable JavaScript in your browser settings. However, you will not be able to use the map display.

8.How we share, transfer and publicly disclose your personal information

• Information Sharing
We will not share your personal information with third parties except in the following cases:
(1) Explicit consent to share: We share your personal information with other parties with your explicit consent.
(2) Sharing under statutory circumstances: We may share your personal information externally according to laws and regulations or the mandatory requirements of government departments.
(3) Sharing with authorized partners: We may share your data with third-party service providers (as our data processors) in order to provide you with NEP services, information technology and maintenance support, or to improve our products and Service Personal Information. We do not share your personal information with third parties for any marketing purposes. These support services include push services and map services.
• Business transfer
In the future, new situations such as mergers, acquisitions and transfers of our business may occur. In this case, your personal information will be transferred with the business as part of the transaction. We will require new companies and organizations that hold your personal information to continue to be bound by this policy, or we will require such companies and organizations to seek your authorization and consent again. We will carry out the above processing activities as necessary to safeguard our legitimate business interests.
• How we store your personal information
Unless otherwise required by laws and regulations, we will store your personal information in accordance with laws and regulations until you delete your account/account data or you request deletion of your personal data.
• How we protect your personal information
The security of your personal information is of the utmost importance to us. We will strictly abide by relevant laws and regulations and take reasonable and feasible measures recognized by the industry to protect your personal information. We will protect information from unauthorized access, disclosure, use, modification, and damage or loss of information. NEP will use encryption technology, such as Transport Layer Security (TLS), to protect your personal data in transit. When we store your personal data, we use computer systems with limited access, which are deployed in facilities protected by physical security measures. In addition, we will conduct security and privacy protection training sessions from time to time to raise employees' awareness of the importance of protecting personal data.
If you have any questions about how we process your data, please contact us as follows. To process any request, please visit www.NEP.com and find the service contact email for your area and submit your inquiry.

9.How to manage personal information

We take the management of your personal information very seriously and do our best to protect your rights to access, correct, delete, withdraw consent, cancel your account and report complaints to protect your privacy and information. The following action settings may vary due to different operating systems; in addition, to optimize your experience, we may also adjust the action settings, so the following guidelines are for reference only.

• Access to personal information
You have access to your profile picture, username, mobile number, email address and other basic information.
• Corrected personal information
You have the right to correct your profile picture, username, mobile phone number, email address and other basic information.
• Delete personal information
You have the right to delete your account at any time. After deleting your account, we will stop providing products and services to you, and delete or anonymize your personal information, unless otherwise required by laws and regulations.
• Withdraw consent
In the process of providing services, we need you to grant us some device permissions, such as notification, photo album, camera, bluetooth and other access permissions. You can turn off some or all of the permissions in your device settings at any time to refuse us to collect your corresponding personal information. Permissions are displayed and turned off differently on different devices and systems. For more information, see the device and system developer's instructions and guides.

10.Use of third-party data services

We will only provide you with third-party data services based on subscribable and cancelable forms if you expressly consent to it in accordance with your own needs and local regulations. We will require a contractual relationship with you through a written contract or express authorization on the website or APP. We would like to make it clear that we reserve the right to use other service providers than those mentioned in this Privacy Statement.

When providing third-party data services to you, we will provide you with back-to-back service and regulatory commitments in accordance with the relevant privacy and service statements of the third-party data service providers.

11.Data transfer

As a registered user, you can approve the transfer of device data to designated third parties. To do this, you must specify in the login area which devices are approved and to whom the data will be transferred. Once approved, we will allow third parties to access device data. Accordingly, third parties will obtain the device baseline data and performance data that they have access to on the approved devices (see the "Sign Up for Our Online Services" section for device baseline data and performance data).

To clarify, the login credentials of the user account are not forwarded under any circumstances. You can prohibit data transfer at any time by disabling approvals.

12.Data storage cycle

In general, we always delete or organize the use of your personal data when the purpose of storage no longer exists. However, storage may also occur if the storage needs are specified by legal provisions to which we are subject (for example, regarding statutory retention and documentation obligations). In this case, we will delete or block your personal data after the relevant provisions have been terminated.

As a registered user, the NEP edge gateway you have registered and used and the third-party hardware devices connected to it, all the data generated by the hardware devices in the process of operation and business occurrence. Your business data will follow the data storage cycle defined by the purchased or registered NEP service. In this case, we will delete your business data upon termination of the relevant contract or service agreement.

13.Terms of Use for Minors

Our services are not directed to individuals under the age of 18. We do not knowingly collect or solicit any information about the Service from anyone under the age of 18. If we learn that personal information from a child under the age of 18 has been inadvertently collected, we will delete that information as soon as possible.

14.Privacy Statement Amendments and Notices

We may revise the terms of this Privacy Statement from time to time, such revisions form part of the Privacy Statement, have the same effect as this Privacy Statement, and we will not reduce your rights under this Statement without your express consent. After this Privacy Statement is updated, we will remind you through announcement messages or emails on the platform or other appropriate means so that you can understand the latest version of this Privacy Statement.

15.Contact us

If you have any questions or suggestions about the content of the Privacy Statement, you can contact us by email:service@NEP.com or visit www.NEP.com and find your local service email.

Mailing address:

Shanghai Shanjin Information Technology Co., Ltd.

Room 604, Building 6, Lane 88, Shengrong Road, Pudong New Area, Shanghai; Zip Code 201210

Privacy Statement Version: August 2022