PRIVACY POLICY PURSUANT TO ARTICLE 13, REGULATION 679/2016 of Upower Electric Co., Ltd

We hereby provide you with all the information necessary to describe the various data processing carried out by Upower as part of its normal activities.

1. DATA CONTROLLER

Upower Electric Co., Ltd
4F-A Block, No.62 Yinhe Road, Longgang District, Shenzhen, China 
privacy@ucanpower.com

2. DATA COLLECTED, PURPOSE AND STORAGE PERIOD

Listed below are all types of data and processing purposes concerning the activities of Upower:

· Data provided by the user as part of the website browsing process: These data are provided, for instance, when the user requests information by completing specific forms on the website or by writing to the email addresses or calling the telephone numbers provided on the website. These data are provided by the user in an optional manner and are used for purposes strictly related to the provision of the service requested by the user. The user takes responsibility for third-party personal data published or shared via this website and guarantees having the right to disclose or disseminate them, releasing the Data Controller from any liability towards third parties.

· Data provided during events, fairs, or courses: Upower organizes, coordinates, and sponsors various gatherings and meetings with industry professionals who may not yet be our customers. In these situations, the data of participants are collected, which are used to fulfill any requests, to present the company and to send out our newsletter. If the user does not sign the proposal, his/her data collected in the contact form shall be kept for internal analysis purposes for one year, after which said data shall be deleted.

· Corporate marketing communications concerning the provided products and services, their events and their trainings: Upower undertakes to keeping all of its customers and potential customers constantly up to date regarding high value-added initiatives, such as professional courses or educational events, provided products and services. To this end, customer is asked to provide their consent to the use of their email, provided whilst completing the registration or when providing their details, to receive our marketing newsletters/corporate communications. Failure to provide consent to the use of their email to receive marketing newsletters or the withdrawal of said consent shall in no way affect the existing business relationship but shall only prevent the professional from being informed regarding the latest industry news and best practices. The data subject can also withdraw his/her consent at any time and fully independently via the specific function located at the foot of all notifications. In this way, your email would be immediately removed from this mailing list, remaining in use exclusively for the legal obligations fulfillment as mentioned in this privacy policy.

· Photos and Videos: Upower believes that the creation of video-photographic material is an important element in developing its business and in promoting its corporate image. Therefore, on all occasions in which Upower is involved (meetings, fairs, conferences, courses) videos may be recorded and photographic material may be collected, which will then be used to create educational, clinical, publicity and commercial material. Data subjects are informed in advance of this initiative and refuse or withdraw their consent to the use of their images at any time. It is guaranteed that the images are created in such as way so as not to jeopardies the personal dignity and decorum of the data subject, who can, in any case, view the images and request their modification or deletion by contacting: privacy@ucanpower.com The material produced shall be kept in Upower’s archives for 10 years after its creation.

· Data relating to customer management (orders, invoicing, …) and fulfillment of legal obligations regarding tax and accounting and medical devices: during the signing of an agreement or commercial order, only the data strictly necessary for correctly processing the request shall be collected, including the data subject’s email address. Any failure to provide, or partial provision of, the data required for these purposes would result in the inability to process the order or provide the service. It is possible that some data may not be updated, and we invite you to report the correction via the usual channels of communication with Upower. Said data shall be kept for the entire duration of the existing relationship and for the entire expected duration of the accounting and tax regulations and Medical Devices Regulation.

· Information for candidacy: CVs and information submitted, including via the appropriate website, shall be used exclusively to assess possible candidates. No response is to be expected if an individual is not selected. Unselected CVs shall be kept for a maximum of 3 years, and it should be remembered that, should a CV contain medical information (e.g., protected persons), they will only be able to be processed in the event of the data subject’s explicit consent provided at the foot of said CV.

3. RECIPIENTS AND SUBMISSION ABROAD

The data collected shall be handled by staff of Upower and shall be included in documents, records and evidence that may be submitted to parties whose legal provisions give them right to access or to parties for whom said submission is necessary in order to carry out the activity or provision of the requested services (such as administrative, sales, marketing or legal staff, companies and consultants who provide IT supply and support services, hosting providers, postal couriers, video-photographic material processors). All external parties are duly contracted. Not submission abroad is planned.

4. RIGHTS OF THE DATA SUBJECT

By contacting the data controller by sending an email to privacy@ucanpower.com, data subjects can, at any time, exercise their rights referred to in Chapter III of Regulation 679/2016, including:

· Requesting access to their personal data and requesting their correction, deletion, or limitation of processing.

· Finding out the purposes for the processing, the categories of data processed, the recipients to whom the data are disclosed or the storage period.

· Withdrawing their consent (where required) at any time, remembering the consequences of this choice.

· Requesting the deletion (when possible) of data that are no longer necessary for the purpose for which they were collected.

· Objecting to processing, profiling, or direct marketing.

· Filing a complaint to the Privacy Authority.

· Finding out the parties to whom their personal data may be disclosed and verifying the true copy of existing agreements with said parties.