Privacy Policy

Last updated: August 18, 2026

1. Introduction

Zhongshan CW Solar Energy Limited ("CWSE", "we", "us" or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, share and safeguard your personal data when you visit www.cwse.cc (the "Site") or use our consultation, compliance diagnostics, reporting and advisory services.

Please read this policy carefully before using the Site or submitting information to us. If you have any questions, please contact us using the details at the end of this policy.

2. Scope

This policy applies to:

• Your access and use of the Site (www.cwse.cc and its multilingual versions);
• Inquiries you submit through the Site's contact forms, compliance radar, CBAM calculator, report download pages, advisor portal, email, telephone or WeChat;
• Advisory services we provide based on the above channels, including product green compliance, supply-chain carbon management, green electricity and energy attributes, distributed solar and energy storage, and packaging green compliance.

3. Information We Collect

3.1 Information You Provide Voluntarily

When you submit an inquiry, request a diagnostic report or communicate with us for business purposes, we may collect:

• Your name and job title;
• Company name, industry and region;
• Phone number and email address;
• Service modules of interest (e.g., CBAM, carbon footprint, EPR, PPWR, green electricity, solar and storage);
• Your specific requirements, product information, export destinations and other business background;
• Other business information generated through WeChat, email, telephone or meetings.

3.2 Information Collected Automatically

To operate, secure and improve the Site, we automatically collect:

• IP address, device type, operating system, browser type and version (User-Agent);
• Visit time, pages viewed, referrer and on-site click/scroll behaviour;
• Necessary cookies and local storage data used for session state and admin authentication;
• De-identified error logs and performance data.

4. How We Use Your Information and Legal Basis

We process your personal information for the following purposes, based on the legal grounds indicated:

• Responding to inquiries and providing services: performance of a contract or pre-contractual steps;
• Establishing and maintaining business contact: legitimate interests or your consent;
• Service delivery and solution customisation: such as embedded-emissions calculation, compliance-gap analysis, and green-electricity programme design, based on performance of a contract;
• Site operation, security and fraud prevention: legitimate interests and legal obligations;
• Service improvement and anonymised statistical analysis: legitimate interests (after de-identification);
• Sending policy updates or service information clearly relevant to you: legitimate interests or your consent, which you may withdraw at any time.

5. Cookies and Similar Technologies

The Site primarily uses essential cookies for:

• Maintaining session state (e.g., advisor portal login);
• Remembering your language preference;
• Security purposes such as preventing cross-site request forgery (CSRF).

We do not use third-party advertising or tracking cookies. You may disable cookies through your browser settings, but some features (such as portal login) may not function properly.

6. Sharing and Disclosure

We do not sell, rent or trade your personal information. We may share your information with third parties only in the following circumstances:

• Service providers: such as cloud infrastructure/security providers (Cloudflare), email and communication service providers, and file-storage providers. These parties may only process data to the extent necessary to provide services to us and are contractually bound to confidentiality and security obligations;
• Business partners: where necessary to deliver specific services you request (e.g., testing and certification bodies, customs/logistics providers, law firms or local agents), and only with your consent or where required by contract;
• Legal requirements: where disclosure is required by applicable laws, regulations, regulators or judicial authorities;
• Protection of legitimate interests: where necessary to prevent fraud, protect personal safety or defend our legitimate rights.

7. Storage, International Transfer and Security

Your inquiry data is stored on Cloudflare's globally distributed infrastructure and may be transferred to servers outside mainland China depending on the access location. We protect your data by:

• Encrypting all Site traffic using HTTPS/TLS;
• Requiring authentication and access controls for sensitive features such as the advisor portal;
• Restricting personal-data access to authorised personnel bound by confidentiality obligations;
• Using data-processing agreements (DPAs) or Standard Contractual Clauses (SCCs) and other lawful transfer mechanisms for cross-border transfers;
• Maintaining a security-incident response process and notifying affected users promptly in case of a data-breach risk.

8. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes described in this policy, typically:

• Consultation and business-communication records: 3 years from the last meaningful contact, or longer if required by law or contract;
• Technical logs and de-identified analytics data: up to 12 months;
• Advisor portal login logs: 6 months;
• Where a longer retention period is required by law, we will comply with the applicable requirement.

9. Your Rights

Depending on applicable data-protection laws (including China's Personal Information Protection Law and the EU GDPR), you have the following rights:

• Right to know and access: understand how we process your data and request a copy of your personal data;
• Right to rectification: request correction of inaccurate or incomplete personal data;
• Right to erasure: request deletion of your personal data where permitted by law;
• Right to restrict processing: request restriction of processing in certain circumstances;
• Right to data portability: receive your data in a structured, commonly used format where feasible;
• Right to object and withdraw consent: object to processing based on legitimate interests and withdraw consent at any time;
• Right to complain: lodge a complaint with the data-protection authority in your jurisdiction if you believe your rights have been violated.

To exercise these rights, please contact us using the details below. We will respond within 15 business days, or within 30 days for complex requests, and will inform you if an extension is needed.

10. Children's Privacy

The Site and our services are not directed to children under 14 years of age. We do not knowingly collect personal information from children. If you believe a child has provided us with personal data, please contact us immediately and we will take steps to delete it.

11. Third-Party Links

The Site may contain links to third-party websites (such as regulators, certification bodies and news outlets). We are not responsible for the privacy practices of those sites. We encourage you to review their privacy policies when you leave the Site.

12. Changes to This Policy

We may update this policy from time to time to reflect changes in our business, legal requirements or services. Material changes will be prominently noted on the Site or communicated to you. The "Last updated" date at the top of this policy indicates the current version. Continued use of the Site constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions, comments, complaints or requests regarding this policy, please contact us at:

• Mainland · Mr. Peng: Email lp@cwse.cc / Phone +86 185 2012 1694
• Hong Kong · Mr. Yeung: Email joy@cwse.cc / Phone +852 6816 0133
• Entity: Zhongshan CW Solar Energy Limited
• Address: Zhongshan, Guangdong, China / Hong Kong