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Global Data Protection Policy

Since the emergence of the first Covid-19 cases in the USA, we are committed to taking a serious of measures aimed at the well-being and health of our employees, and less impact of our custumers and partners. Currently, a good part of our team is working on a Home Office basis, but some activities considered essential remain happening in person. Well continue to fulfill our contractual and civic duty obligations, always guaranteeing the efficiency of our services. Our commitment is to provide actions and measures that protect everyone involved in these activities. We believe in the turning points, and that if everyone does their part, the USA can overcome this adversity.

SCOPE

The Global Data Protection Policy applies to Sunlight Solar, for all dimensions and activities, in all regions where we operate. This policy applies to the processing of personal data collected by Sunlight Solar, directly or indirectly, of all individuals, including, but not limited to, current, future or potential employees, customers, consumers, suppliers, contractors/subcontractors or any third parties, with “Personal Data” defined as any data relating to an identified, identifiable individual or a person who may be identified by reasonably likely means to be used. In this Policy, “you” and “your” indicate any individual covered. “We”, “our” and “Sunlight Solar” are terms that indicate SUNLIGHT ENTERPRISES INC.

COLLECTION AND PROCESSING OF USE OF YOUR PERSONAL DATA

IN ACCORDANCE WITH DATA PROTECTION LAWS AND ANY OTHER APPLICABLE LOCAL DATA PROTECTION LEGISLATION, we undertake to comply with all applicable laws in relation to personal data and we will ensure that personal data is collected and processed in accordance with the provisions of European Data Protection Law and other applicable local laws, if any.

LOYALTY, JUSTICE AND TRANSPARENCY

We may have to collect and process your personal data when necessary for the performance of a contract to which you are a party, or for the fulfilment of a legal obligation to which we may be subject, with your prior consent. We may also collect and process your personal data for the legitimate interests of Sunlight Solar, except where those interests are voided by your interests or fundamental rights and freedoms. We may also collect and store your personal data with consent to send content and information. By collecting and processing your personal data, we will provide you with a fair and complete information notice or a privacy statement about who is responsible for processing your personal data, for what purposes your personal data is processed, who the recipients are, what your rights are, and how to exercise it, among others, unless it is impossible, or requires disproportionate efforts to do so. Where required by applicable law, we will seek your prior consent (for example, before collecting any sensitive personal data).

LEGITIMATE PURPOSE, LIMITATION AND MINIMIZATION OF DATA

Your personal data is collected for specific, explicit and legitimate purposes and is not processed in a manner incompatible with those purposes. When Sunlight Solar acts for its own purposes, your personal data is processed primarily for, but not limited to, the following purposes: recruitment management, human resources management, accounting and financial management, finance, treasury and tax management, risk management, personnel security management, provision of IT tools or internal websites, and any other digital solutions or collaborative platforms, IT support management, security and health management, information security management, customer relationship management, bidding, sales and marketing management, supply management, internal and external communication ,data analysis operations, corporate legal management and implementation of compliance processes. When providing our services for the benefit of our customers or between us, we may also process personal data on behalf of a Controller (whether a customer or any other Sunlight Solar entity acting as such) primarily for the effective operation, management, performance and delivery of our services worldwide. We ensure that the personal data processed is adequate, relevant and limited to what is necessary for the purposes for which it is processed.

DATA ACCURACY AND STORAGE LIMITATION

Sunlight Solar will keep personal data processed accurately and, when necessary, up-to-date. In addition, we only retain personal data for as long as necessary for the purposes for which it is processed (in accordance with our Global Data Retention Policy). Sunlight Solar will act in accordance with the instructions of its clients in order to assist them in fulfilling this obligation.

SECURITY OF YOUR PERSONAL DATA

We have implemented appropriate technical and organizational measures to protect personal data from alteration, accidental or illegal loss, or unauthorized use, disclosure or access, in accordance with our Sunlight Solar Information Security Policy. We take, when appropriate, all reasonable measures based on privacy by design and privacy by standard principles to implement the necessary safeguards and protect the processing of personal data.

DISCLOSURE OF YOUR PERSONAL DATA

We may, in the normal course of our business and for processing purposes, share your personal data with relevant personnel within Sunlight Solar, or with our duly authorized employees and/or contractors/subcontractors, to ensure consistency in our hiring activities, maximize the quality and efficiency of our services and our business operations. We may also be required to disclose personal data to regulatory authorities, courts and government agencies when required by law, regulation or legal process, or defend the interests, rights or property of Sunlight Solar or related third parties. Otherwise, we will not share your personal data with other parties unless you request it or have given us prior approval for such sharing.

YOUR RIGHTS

Sunlight Solar is committed to ensuring the protection of your rights under applicable laws. You will find below a table summarizing your different rights:

Right of access

    • You can request access to your personal data. You may also request the correction of inaccurate personal data or have incomplete personal data completed.
    • You can request any available information about the source of the personal data, and you can also request a copy of your personal data being processed by Sunlight Solar.

Right to be forgotten

  • Your right to be forgotten gives you the right to request the deletion of your personal data in cases where:
    • data is no longer needed;
    • you choose to withdraw your consent;
    • you object to the processing of your personal data by automated means using technical specifications;
    • your personal data has been processed illegally;
    • there is a legal obligation to erase your personal data;
    • necessary to ensure compliance with applicable laws.

Processing restriction right

    • You may request that the processing of your personal data be restricted in cases where:
      • you dispute the accuracy of personal data;
      • Sunlight Solar no longer needs personal data for the purposes of processing;
      • objected to processing for legitimate reasons.

Right to opposition to processing for direct marketing purposes

    • You may owe (i.e. exercising your right to “opt-out”) of the processing of your personal data, particularly in relation to profiling or marketing communications. When we process your personal data based on your consent, you may withdraw your consent at any time.

Right to lodge a complaint with the competent supervisory authority

    • If you have a privacy complaint against us, you should contact us.

To exercise these rights, you may submit your Request or Complaint by following the procedure set out in the privacy statements brought to your attention at the time of the collection of your personal data or by sending an email to: marketing@sunlightsolar.us

UPDATE

We may update this Global Data Protection Policy in due course as our business or legal requirements change. If we make significant changes to this policy, we will post a notice on our site when the changes take effect and, where appropriate, we will send you a direct communication about the change.

CONTACT US

If you have questions about the collection and processing of your personal data by Sunlight Solar, you can submit your questions or complaints following the procedure set out in the privacy statements communicated to you at the time of collection of your personal data.

Contact us: marketing@sunlightsolar.us