Privacy Policy

As of: November 21, 2023

We, Safety Tax Free GmbH (hereinafter referred to as "Developer," "we," "us"), are committed to protecting your personal data. In this privacy policy, we explain how your personal data is collected, used, and disclosed in accordance with the European General Data Protection Regulation (EU GDPR) when you use our SunLit Solar App (hereinafter "App") or the SunLit Solar website (hereinafter "Website"). The data controller and data processor for the processing of your personal data is Safety Tax Free GmbH, Zeppelinstr. 33, 85748 Garching bei München, Germany (hereinafter "Controller").

For more information and details about the handling of your processed data through our App and on the Website, please refer to the Controller's privacy policy on their website.

Data Collected by Us, Retention Period, and Legal Basis

When you use our SunLit App, we collect the following categories of personal data, and we will retain this data for the duration of your contract with us unless otherwise legally required to fulfill our contractual obligations. Further information regarding the use of the App can be found in the Terms and Conditions (hereinafter "T&C").

• Personal data provided by you, such as your username/pseudonym, password, email address, personal profile pictures, custom device or location names, and other voluntary information for the use of the App in your account.

  1. The legal basis and purpose for processing this data are Art. 6(1)(b) GDPR (performance of a contract) and, otherwise, Art. 6(1)(a) GDPR (consent).
  2. Your username/pseudonym and email address may be used to occasionally send information about the App in the form of software and feature updates and so-called direct advertising via email. This is intended to inform you regularly about innovations related to the App and relevant offers related to devices controlled by the App. You can revoke your consent at any time. The legal basis for processing this data for informational and marketing purposes is Art. 6(1)(a) GDPR (consent) and, otherwise, Art. 6(1)(f) GDPR (legitimate interest).

• Device information, including device identifiers (e.g., inverter and other device serial numbers) and information about the electrical energy generated by your solar devices, transmitted to us by your device. We use this information for the proper operation of the App and associated devices. The legal basis for this processing is Art. 6(1)(b) GDPR (performance of a contract).

• Readings generated during the use of our App, including information about your overall savings, energy yield, and analyses such as trends and forecasts. The legal basis for this processing, if necessary, is Art. 6(1)(b) GDPR (performance of a contract).

• Network information, including your IP address, approximate location, WiFi network name/SSID, and other network-related data, is partially needed for the proper operation of the App. Your IP address may also be used to ensure the security of our services by detecting unusual data traffic or access patterns. The legal basis for this processing is Art. 6(1)(b) GDPR (performance of a contract) and, otherwise, Art. 6(1)(f) GDPR (legitimate interest).

• Information about your use of the SunLit App or the Website, such as the features you use and the duration of your sessions. The legal basis and purpose for this processing are our legitimate interest in analyzing user behavior to improve our services, according to Art. 6(1)(f) GDPR (legitimate interest). Further information on data protection for the use of the Website can be found on the Controller's website.

Upon termination of your contract with us or when storage is no longer legally required, we will promptly and securely delete or anonymize your personal data in accordance with the requirements of the GDPR. If legal obligations prevent us from completely deleting your data, we restrict the processing and access to this data to the legally required minimum requirements.

Data Processing by Third Parties

To carry out and provide our services, we utilize third-party data processing to perform certain services on our behalf (so-called "data processing"). We only disclose personal data to third parties if it is necessary to fulfill their tasks. For third-party data processing, a contract for data processing is concluded with the respective provider. We collaborate with the following service providers, among others:

Within the European Economic Area (EEA):

• Amazon Web Services (AWS), Germany: We use AWS as our primary hosting provider for our App. The data processed by AWS includes personal data of our users.
• AWS Simple Email Service, Germany: We use this service for the automatic sending of emails with the domain sunlitsolar.de. The transmitted data includes your email address, username/pseudonym, and possibly other personal data voluntarily provided by you, such as your name and address.
• Amazon WorkMail, Ireland: We use this service for the automatic sending and receiving of emails with and to the domain sunlitsolar.de. The transmitted data includes your email address, IP address, possibly your username/pseudonym, and other personal data voluntarily provided by you, such as your name and address.
• Solarman Smart Platform, Germany: We use this service for device management and data monitoring of devices connected to our App. The transmitted data includes your IP address, device serial number, country, time zone, and the name of the WiFi network/SSID.
• Quectel IoT Platform, Germany: We use this service for device management and data monitoring of devices connected to our App. The transmitted data includes your IP address, device serial number, country, time zone, and the name of the WiFi network/SSID.
• APsystems Energy Monitoring & Analysis System, Germany: We use this service for device management and data monitoring of devices connected to our App. The transmitted data includes your IP address, device serial number, country, time zone, and the name of the WiFi network/SSID.
• Brevo, a service of SENDINBLUE, France: We use Brevo to send notifications of changes to the terms of use, applied privacy, and occasionally for marketing emails to App users if you have not objected to receiving such messages. The data used for this purpose includes your email address and possibly your username/pseudonym.

Outside the EEA:

• AWS Hong Kong, China: We use this provider for input logging. The processed data includes your settings within the App and your IP address.

Your Rights

According to the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

• The right to access and obtain a copy of your personal data.
• The right to correct or update inaccurate personal data.
• The right to request the deletion of your personal data.
• The right to restrict the processing of your personal data.
• The right to object to the processing of your personal data.
• The right to data portability, allowing you to receive your personal data in a structured, commonly used, and machine-readable format.
• The right to withdraw your consent to the processing of your personal data at any time without affecting the legality of the processing based on your consent before its withdrawal.
• The right to file a complaint with a supervisory authority.

If you wish to exercise any of your rights under the GDPR, please contact us at privacy@sunlitsolar.de. We will process your request promptly and respond within the deadlines set by the GDPR.

Changes to This Privacy Policy

We may update this privacy policy from time to time and publish the updated version in the respective app stores and on the website.

We will inform you of any significant changes to this privacy policy (e.g., changes in providers or changes in the purpose of data processing) by sending an email to the address you provided during registration or by notifying you within the App. It is your responsibility to keep your email address up to date, regularly check your email inbox for messages from us, and update the App.

If you do not delete your account before or at the time the new terms come into effect, we consider this as your consent. If you disagree with the new terms in whole or in part, you must cease using the App, delete your account, or terminate your existing agreements with us (such as the "Terms and Conditions of SunLit") in writing. You can also request the restriction of the processing of your data if necessary and technically feasible. Please contact us immediately if you have any questions or objections to the options and conditions mentioned here.

Contact Us

If you have further questions or comments about this privacy policy or if you would like to exercise your rights under the GDPR, please contact us at:

privacy@sunlitsolar.de

You can also reach us by mail at the address provided in the imprint.

Imprint

Safety Tax Free GmbH Zeppelinstr. 33 85748 Garching bei München GERMANY

Managing Director: Chengyuan Zhai Registry Court: Amtsgericht München Registry Number: HRB 225103 VAT ID No.: DE306117575