Xi'an Huazhao New Energy Technology Co., Ltd. ("Huazhao New Energy", "we", "us" or "the Company") understands the importance of your personal information. This Privacy Policy applies when you visit the official website of Huazhao New Energy (www.huazhaoenergy.com), or interact with us through our Facebook ads, lead forms (Lead Ads) and other online channels. It explains how we collect, use, share and protect your personal information, and the rights available to you.

Please read this Policy carefully before using our website or submitting any information. If you do not agree with the processing described in this Policy, please do not submit any personal information and stop using the relevant features.

1.Information We Collect

Information you provide to us. When you contact us through the inquiry form on our website, Facebook lead forms (Instant Forms), email or other business communication channels, we collect the business contact information you voluntarily submit, including: name, company name, job title, work email address, phone number, country/region, and project requirements or inquiry details. As a B2B energy storage and solar PV OEM service provider, we collect this information to respond to your business inquiries and technical requirements, not for consumer profiling.

Information collected through automated technologies. When you visit our website, we and our third-party advertising partners (including Meta) may use cookies, pixel code (Meta Pixel) and similar technologies to automatically collect limited technical information, including: IP address, browser type and language, device type, operating system, pages visited, time spent on pages, referrer, and approximate geographic location (generally at city level only). This information is used to measure advertising effectiveness, optimize the website experience, and show relevant ads to business users who may be interested in our products.

2.How We Use Your Information

We use your personal information for the following purposes:

• Responding to inquiries and providing quotations: communicating with you regarding energy storage systems, solar PV modules, OEM/ODM manufacturing needs or other business inquiries;
• Ad delivery and performance measurement: using Meta Pixel and the Conversions API to measure the conversion performance of our Facebook ads, optimize our advertising strategy, and show retargeting ads to audiences who share similar business characteristics or who have visited our website;
• Business communications: following up on your project requirements by email or phone after you have contacted us;
• Website improvement and security: analyzing traffic trends, troubleshooting technical issues and preventing misuse;
• Legal compliance: fulfilling applicable legal, tax or export compliance obligations.

Legal bases for processing (where the GDPR applies): For B2B business communications and responding to inquiries, we process your data on the basis of the performance of a contract or steps necessary prior to entering into a contract, and our legitimate interests (conducting effective B2B business communications). For advertising tracking, retargeting cookies and sending you marketing communications, we rely on your consent, which you may withdraw at any time.

3.How We Share Information with Meta

This is a key disclosure of this Policy. When you submit information through our Facebook ads (including lead forms), or visit pages of our website where Meta Pixel is deployed, the following data is shared with Meta Platforms, Inc. (Facebook):

• Information submitted via Lead Ads forms: the name, email address, phone number and answers to custom questions you provide in a Facebook lead form are transmitted to both us and Meta. Meta processes this information in accordance with its own data policy; for details, please refer to Meta's Privacy Policy (https://www.facebook.com/privacy/policy).
• Website activity data: Meta Pixel collects event data such as page views and button clicks on our website, which is used to build Custom Audiences and measure ad conversions. This data may include your IP address and cookie identifiers.

We do not sell your personal information to Meta or any other third party. We share the above data only to the extent directly related to ad delivery, lead collection and performance measurement with Meta.

Your choices: You may limit or object to our processing for advertising purposes at any time by: (a) refusing or deleting Meta Pixel and other tracking cookies through your browser settings; (b) managing the ads you see in your Facebook "Ad Preferences" settings; or (c) contacting us directly using the contact details in Section 8 of this Policy to request that we stop using your data for retargeting purposes. Please note that Meta has adjusted its platform-level "Off-Facebook Activity" controls; therefore, raising an objection through our direct contact channel is an effective way to ensure that processing stops on our side.

4.Cookies and Similar Technologies

Our website uses the following types of cookies:

• Strictly necessary cookies: ensure the basic functionality and secure operation of the website;
• Analytics cookies: help us understand how visitors use the website so that we can improve content and navigation;
• Advertising cookies (including Meta Pixel): used to measure the effectiveness of Facebook ads, build retargeting audiences and show you more relevant ads.

You can manage or disable cookies through your browser settings. Disabling advertising cookies will not prevent you from accessing the website, but may affect the relevance of the ads you see. Where required by applicable law (such as in the EU/UK), we will obtain your consent through a consent banner before deploying non-essential cookies.

5.International Data Transfers

Huazhao New Energy serves the global market. Information you submit through this website or Facebook ads may be transferred to and processed in mainland China and other countries/regions where we or our service providers operate. When personal information is transferred out of the EU/European Economic Area, the UK or other jurisdictions with cross-border transfer restrictions, we implement safeguards based on applicable legal mechanisms (such as the Standard Contractual Clauses (SCC)). Where personal information is provided from within China to recipients outside China, we will, in accordance with the requirements of the Personal Information Protection Law of the People's Republic of China, fulfill our notification obligations and, where necessary, obtain separate consent or adopt compliance mechanisms such as the standard contract.

6.Data Retention and Security

We retain your personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. For inquiry and lead information, the retention period is generally [24] months from the last business contact, so that we can follow up on project progress; upon expiry of this period, we will delete or anonymize the relevant data.

We take reasonable technical and organizational measures to protect personal information, including transport layer encryption (HTTPS/SSL), access controls and least-privilege authorization. Please note, however, that no method of transmission over the internet can guarantee absolute security.

7.Your Rights

Subject to the applicable laws of your region (including the GDPR, PIPL and other data protection regulations), you have the following rights regarding your personal information:

• Right of access: to know whether we process your personal information and to obtain a copy;
• Right to rectification: to request the correction of inaccurate or incomplete information;
• Right to erasure: to request the deletion of your personal information under statutory conditions;
• Right to restriction of processing / right to object: to object to our use of your data for direct marketing or retargeting ads;
• Right to withdraw consent: for processing based on consent (including ad tracking), to withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please contact us as described in Section 8. We will respond within the time limits required by applicable law and may need to verify your identity before processing your request.

8.Contact Us

If you have any questions about this Privacy Policy, or wish to exercise the rights described above (including requesting that we stop using your data for Facebook retargeting), please contact:

We will respond within [2] business days of receiving your request.

9.Updates to This Policy

We may revise this Privacy Policy from time to time due to business changes, technology updates or legal requirements. The revised version will be posted on this page, and the "Last Updated" date at the top will be updated accordingly. In the event of material changes, we will notify you through a prominent notice on our website or by other practicable means.