sonnen, Inc. External Privacy Notice
What does this Privacy Notice cover?
This Privacy Notice provides information regarding the processing of your personal data when using services and/or purchasing products from or on behalf of a company or companies within the sonnen, Inc. whether as:
- a customer (a potential/existing battery owner, and/or virtual power plant participant);
- a visitor to a sonnen, Inc. website and/or social media pages;
- a user of sonnen online learning or test page; or
- as a participant in a sweepstake, contest, promotion or competition offered by sonnen, Inc., either alone or with a third party/ies (“Promotion”).
- a user of the sonnen user Portal and/or sonnen App(s)
If you choose to create a sonnen, Inc. user account in the sonnen portal or the sonnen website, for whatever purpose, a personal profile will be created for you to use and navigate across these sonnen services and/or offers.
Bespoke notices and supplementary privacy statements may contain further information about how sonnen is processing your personal data. This would be the case, for example, if you are a battery customer or you participate in the sonnen Virtual Power Plant as a customer. In those instances, such privacy notices may be communicated to you separately.
If you would like to receive this Privacy Notice in an alternative format (for example in larger print) please contact email@example.com.
This Privacy Notice explains what personal data are processed about you; why we are processing your personal data and for which purposes; how long we hold your personal data for; how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.
sonnen does not sell your personal information unless you provide us with your explicit consent to pass on your information to a local installation partner to contact you for an offer regarding our products and services.
For the avoidance of doubt these provisions apply to all consumers whose personal information is processed by sonnen, Inc. in the United States of America regardless of the State you reside in. These rights are without prejudice to any additional rights you may have in line with local law.
Special Notice - if you are under 13 years old. Processing children’s personal data
Except in those cases where sonnen, Inc. organizes educational events specifically designed for children, we do not intentionally collect personal data of individuals under 13 years old. If you are under 13 years please do not send us your personal data for example, your name, address and email address. If you wish to contact sonnen, Inc. in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.
What personal data do we process about you? Collection of information
We collect information, including personal data about you, as a sonnen customer, user of sonnen, Inc. personal battery storage Online Portal and/or App (“sonnen App(s)”) and/or visitor to a sonnen, Inc. website or sonnen, Inc. administered social media page (‘sonnen, Inc. Social Media Page’). This information may be either:
- Information that you provide to us - when creating a sonnen account profile, we will ask for your name, e-mail address and gender (so that we can address you properly but you do not have to provide us with this information), your contact preferences and information necessary for answering any security questions. If you decide to become a user of sonnen, Inc. App(s), or register on our online learning center, you may be asked to provide further personal data necessary for the performance of such services and/or authentication such as:
- First and Last Name with title (Mr., Mrs, Ms., etc…)
- Installer Company
- sonnen ID
- Installer ID
- Installer email
- Installer name with title (Mr., Mrs., Ms., etc…)
- WAN IP
- Current unit state (e.g. software/firmware version)
- sonnen Unit mode (backup/consumption/discharge)
- sonnen Unit performance over time of consumption/production/charge/discharge over time
- sonnen Unit battery cell temperature and battery cell performance
- Information that we obtain through your use of sonnen, Inc. services - we will also collect information about how and where you use or purchase sonnen, Inc. services and products. Such information may include electronic device information, IP addresses, log information, browser type and preferences, location information, online identifiers to enable ‘cookies’ and similar technologies
- Information gathered through social media pages - When you communicate with us through a sonnen, Inc. Social Media Page (for example, when you comment on, share or react to a post, upload media, send a personal message or subscribe to a sonnen, Inc. Social Media Page), we may receive personal data about you such as your user name, profile picture, home town, email address and gender. We will use any personal data received from social media in accordance with this Privacy Notice.
In addition, in order to comply with legal and regulatory obligations, to protect sonnen, Inc.’s assets and employees/contractors and specifically to ensure that sonnen, Inc can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business Customers, Suppliers and Business Partners. This screening takes place against publicly available or government issued sanctions lists and media sources.
The screening does not involve profiling or automated decision making in relation to the counter-parties or potential counter-parties.
Why do we process your personal data?
The personal data covered by this Privacy Notice are only processed:
- with your explicit consent;
- where it is necessary to conclude a transaction with you (such as setup, testing, or troubleshooting information of your battery system);
- where it is necessary for the purposes of the legitimate interests pursued by sonnen, Inc., except where such interests are overridden by your interests or fundamental rights and freedoms;
- where it is necessary for sonnen, Inc. to comply with a legal obligation; or
- for legitimate interests of sonnen, Inc. installers and distributors, such as for marketing and promotional purposes, for providing you with offers tailored to your preferences, for the purposes of detecting and investigating fraud, and/or responding to security threats.
Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
What are the consequences of not providing your personal data?
Where you choose not to provide us with information set out above for the purposes of using a sonnen, Inc. App or participating in our online Learning Center, it will affect your ability to fully interact with the sonnen, Inc. App and/or to fully participate in our Online Learning Center. Additionally, if you own a sonnen, Inc. battery storage system, if you choose not to provide us with the information set out above, we may be unable to access your battery and/or perform hardware or software updates, as necessary, which may further result in the voidance of your warranty.
Who is responsible for any personal data collected?
sonnen, Inc., a Delaware corporation having offices at 2084 Weems Road, Tucker, Georgia 30084 on behalf of itself.
For what purposes do we process your personal data?
We process your personal data to:
- provide our products and deliver our services to you through certified network of sonnen contractors in your area, our sonnen user App(s) and/or our online Learning Center;
- process warranty questions or claims;
- update the software and/or firmware within the unit;
- access your battery system for the purposes of ensuring its proper installation, function or for troubleshooting;
- enable you to participate in our online battery storage user Portal, sonnen App(s) and our online Learning Center;
- manage relationships and for marketing such as maintaining and promoting contact with you;
- account management including account verification (that is, ensuring that only you or someone you have authorized can access your account and information);
- customer service and development of our products and services;
- performance of and analysis of market surveys and marketing strategies;
- promotions offered to sonnen, Inc. customers; or
- detecting or preventing security issues/concerns regarding your battery system.
or for a secondary purpose where it is closely related, such as:
- storing, deleting or anonymizing your personal data;
- audits, investigations, dispute resolution or warranty purposes, litigation or defense of claims;
- statistical, historical or scientific research; or
- legal and/or regulatory compliance.
Communication and marketing - your choices
We may send you service updates and notifications without your advance consent only where such updates and/or notifications are necessary for the proper functioning of the sonnen App(s) or other services that you use with us, as they may be updated from time to time.
You may receive pertinent offers and communications through interaction with our sonnen, Inc. website and social media channels. You may update your subscription preferences anytime by clicking on the unsubscribe link included in sonnen, Inc. emails, by updating your personal profile settings in your social media accounts or by contacting firstname.lastname@example.org.
Who will we share your personal data with?
Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis and for a relevant business purpose with:
- Any company that is a member of our group of companies, which includes our ultimate parent company Royal Dutch Shell Plc, where necessary for internal administrative purposes, corporate strategy, auditing and monitoring, sanctions screening and research and development.
- Other global sonnen companies including to those which may be located outside of your location;
- With your consent, authorized third party companies in co-operation with sonnen that may supply products and/or services to users of sonnen battery storage systems, sonnen User Portal, sonnen App(s) and/or our Online Learning Center;
- Authorized installers and distributors of sonnen, Inc.;
- Authorized agents, licensees, service providers, external auditors and/or subcontractors of sonnen, Inc.;
- A competent public authority, government, regulatory, supervisory, investigative or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which sonnen, Inc. is subject to or as permitted by applicable law;
- Any person to whom sonnen, Inc. proposes to transfer any of its rights and/or duties; or
- As necessary or appropriate to enforce our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Transfers of your personal data to other countries
Where your personal data have been transferred to companies within the global sonnen companies and/or to authorized third parties located outside of your country, we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the EU, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of the Shell Binding Corporate Rules at www.shell.com/privacy.html or by contacting privacy-office-SI@shell.com
Interacting with sonnen, Inc. through social media
If you choose to publicly interact with sonnen, Inc. through social media on a sonnen, Inc. administered social media page (‘sonnen, Inc. Media Page’) such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in sonnen, Inc.) will be visible to all visitors of your personal page depending on your privacy settings on the relevant social media platform, and will also be visible to sonnen, Inc. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. sonnen, Inc. does not track your activity across the different social media sites that you use. If you send a message to sonnen, Inc. via any private or direct messenger service on a social media platform, these messages are subject to governance set forth by the privacy policies of each individual company, sonnen does not specifically store a copy of these messages. Please contact sonnen, Inc. if you wish to make a request that you are unable to action yourself and which relates to a sonnen, Inc. Social Media Page - see the section below [link to ‘Your rights in relation to your personal data’].
Additionally and to the extent sonnen, Inc. is jointly responsible with a social media platform of a sonnen, Inc. Social Media Page, sonnen, Inc. will have access through the social media platform to third-party aggregated data providing statistics and insights that help to understand the types of actions you and other users take on sonnen Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
How long do we hold your personal data for?
Personal data processed by sonnen, Inc. in line with this Privacy Notice will be deleted or rendered anonymous (such that it will no longer be possible to identify you):
- without undue delay upon you requesting that your sonnen, Inc. account profile is deleted or you discontinue your participation in the sonnen User Portal or sonnen App(s).
In relation to any financial transactions directly entered into with sonnen, Inc., your personal data will be held for the life of the warranty of the unit, so long as your warranty is not voided.
In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.
Your rights in relation to your personal data
We aim to keep our information as accurate as possible. Regardless of which US State you are resident in, you can request:
- access to your personal data;
- correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction);
- that you no longer receive marketing communications;
- that the processing of your personal data is restricted; and/or
- that you receive personal data that you have provided to sonnen, Inc., in a structured, digital form to be transmitted to another party, if this is technically feasible.
How to exercise your rights
To exercise any of your rights listed above, please submit a verifiable request to us by either:
- calling sonnen, Inc. at +1 (818) 824-6363
- Or emailing sonnen, Inc. at email@example.com
The request must:
- provide sufficient information for us to be able to verify you are the person whose personal information we hold or are an authorised representative of that person;
- describe your request in enough detail so that we can properly locate the personal information related to the request.
We cannot respond to your request unless we can verify your identity or authority to make the request. We will aim to verify your identity based on personal information we already hold about you. If we need to request further information from you in order to verify your identity, we will only use that personal information for the purposes of identifying you or that you have authorized the request.
Who can you contact if you have a question, concern or complaint about your personal data?
If you have any issues, questions, or complaints regarding the processing of your personal data, please contact us at firstname.lastname@example.org. You may also contact us via mail to: sonnen, Inc., Attn: Customers Privacy Operations, 2048 Weems Road, Tucker, Georgia 30084.
You may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, at privacy-office-SI@shell.com.
If you are unsatisfied with the handling of your personal data by sonnen, Inc. then you have the right to lodge a complaint to your local data protection authority or the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information
Cookies and similar technologies
Security of your personal data
sonnen is committed to safeguarding your personal data. We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use. In particular we may use encryption for some of our services, we apply authentication and verification process for access to sonnen, Inc. services and we regularly test, assess and evaluate the effectiveness of our security measures.
Effective Date: January 1, 2019. Last Reviewed: December 2019.
We do not sell your personal information unless you provide us with your explicit consent to pass on your information to a local installation partner to contact you for an offer regarding our products and services.
We do not and will not discriminate against you for exercising any of your rights explained in this Privacy Notice regardless of whether or not the California Consumer Privacy Act applies to you including:
- denying you access to goods and/or services;
- charging you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
- providing you a different level of goods and/or services;
- suggesting you may receive a different price or rate for goods and/or services or a different level of quality of goods and/or services.
Changes to this Privacy Notice
This Privacy Notice may be changed from time to time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in April 2020.