SRE Website Privacy Notice

Last Updated: January 2024

Contents
What Information We Collect
How We Use Information We May Collect
Protection of Information
Do Not Track
International Transfers of Personal Data
Rights Under GDPR
Information and Deletion Requests
Governing Law
Contact

Synera Renewable Energy Co., Ltd. (“SRE”, “we”, “our” or “us”) thanks you (“you” or “user”) for visiting our website.  Your visit to this website (this “Site”) and/or other ways that you may interact with us such as visiting our premises, applying for employment, and other communications with us such as email are subject to this privacy policy (“Privacy Policy”).  By visiting this Site, our premises, or submitting an application for employment with us, you agree to this Privacy Policy, which may be updated by us at any time.  If we update our Privacy Policy, we will post such updates here.  Any such changes will be effective once we post them.  We encourage you to review the Privacy Policy each time you visit this Site or our premises.  If you do not agree with any provision of the Privacy Policy, you should not visit or use this Site or our premises or submit an application for employment.

This Privacy Policy also does not address our privacy practices with respect to any nonpublic personal information we may collect from you as an investor in investment vehicles or other entities managed or advised by SRE or as an employee of SRE.  We address these practices in separate notices.

This Privacy Policy also does not apply to any other third-party website, including those that may be linked to in our website.  We do not control the privacy policies or practices of others.  We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

Your privacy is important to us.  This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit this Site, and how we use such information.

If you have any questions or comments about our Privacy Policy, you can email us at SRE_LE@sreglobal.com or send messages to us at Contact Us.

What Information We Collect

When you enter and browse this Site, we may collect two different types of information about you:  information you provide to us and information we collect through technology.

You may choose to contact us using links or contact information available on our Site. In such instances, you may provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, company name, job title, and e-mail address.  Such information is referred to as “personal information” throughout this Privacy Policy.

We may collect personal information from third party sources, which may include publicly available sources of information.  Additionally, we may collect and retain a record of all communications with you, and we may monitor and record other activity on our Site for any reason.

We may collect information about you through technology.  For example, we may collect your IP address each time you request a page during a visit to this Site.  At times, we may also use IP addresses to collect information regarding the frequency with which you or other users browse various parts of this Site.  This Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the time at, frequency with and the website from which our users visit various parts of this Site.  These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf.  We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits to our Site, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page.  We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

The types of personal information we collect may include:

• Identifiers, including your name, postal address, email address, phone number;
• Internet or other network activity and technical information: for example, browsing or search history, information regarding your interaction with sites and related applications, IP addresses and online identifiers such as cookies;
• Mailing list data such as marketing and communications preferences and interests;
• Audio, electronic, visual or similar information, including photographs and CCTV footage;
• Physical access data relating to details of your visits to our offices;
• Commercial information and financial information;
• Legal and regulatory compliance data, including information as required for purposes such as know your client, anti-money laundering and other similar requirements, which may include passport or other identification and due diligence data;
• Professional information (e.g., employment details, education information, occupational history or business relationships); and
• Other information you provide, or which may be incidentally processed, when you contact us.

How We Use Information We May Collect

SRE does not disclose any nonpublic personal information about our Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose certain personal information we collect about you or that you provide when you visit and browse this Site, our premises, or apply for employment as part of our normal business operations, including to respond to requests from you.  We may also use service providers in connection with this Site.  These companies and individuals may have access to and use your personal information, as needed to perform their functions.

We may use your personal information:

• to contact you and respond to your requests and inquiries;
• for our legitimate business interests such as to operate, manage, develop and promote our business, sites and premises, to monitor access to the website and to protect our business from fraud, money laundering and other financial or business crimes, and to screen, identify and evaluate candidates for job positions, including conducting background checks;
• to comply with our legal and regulatory obligations and bring and defend legal claims.

We will disclose personal information we collect from you when we believe that such disclosures are required by law, regulation, legal process, subpoena, document or governmental request.  We may also do so to help enforce our Terms of Use, protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you or to third parties.  We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve this Site and your experience.  We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

Also, in the event that SRE, or any portion of our assets or businesses, are acquired by or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets.  We may transfer all user information (which may include personal information) to our acquirers or successors.  Other than as part of such transaction, we will not sell any of your personal information without your consent.

Protection of Information

We endeavor to protect your personal information.  We use technical, administrative and physical methods to maintain the integrity and security of our databases, including Encryption-at-Rest for any personally identifiable data, computer safeguards and secured files and buildings.  Please be aware though that there is no such thing as “perfect security” on the internet, and third parties may unlawfully intercept or access transmissions or private communications.  We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal information.  You use our Site and send us information at your own risk.

SRE retains your personal information in compliance with our obligations under applicable law and any applicable internal policies. We may destroy personal information without notice or liability. Once we notice that there’s no necessity to retain such information, we will carefully proceed the due process to delete it thoroughly.

Do Not Track

We do not track visitors of this Site over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals.  However, some third‑party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.  If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked.  You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

International Transfers of Personal Information

Our servers are located in Taiwan (Republic of China).  If you are accessing this Site from outside Taiwan, please be aware that your information may be transferred to, stored and processed by us in our facilities and by those third parties with whom we may share your personal information as outlined in this Privacy Policy, in Taiwan, and in other countries.

Depending on what country you are a resident of, these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in Taiwan.  We will, however, take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law and we transfer your data in compliance with all applicable law, including via implementation of appropriate safeguards (such as, where appropriate, agreements with standard data transfer contractual clauses).

Rights Under GDPR

In places where the EU General Data Protection Regulation (“EU GDPR”) and/or the UK General Data Protection Regulation (“UK GDPR”) (EU GDPR and UK GDPR, collectively, “GDPR”) apply, you may have certain rights in relation to personal information that constitutes “personal data” as defined in GDPR.

These rights may include:

1. the right to ask us to correct your personal information where it is inaccurate or incomplete;
2. the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your personal information and who we share it with.

We process personal data in order to perform any of our contracts with you, for compliance with legal obligations or requirements and/or to pursue our legitimate business interests. In certain circumstances, you have the right to ask us to delete the personal information we hold about you, including:

1. where you believe that it is no longer necessary for us to hold your personal information;
2. where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or
3. where you believe the personal information we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:

1. where you believe the personal information we hold about you is inaccurate and while we verify accuracy;
2. where we want to erase your personal information as the processing is unlawful but you want us to continue to store it;
3. where we no longer need your personal information for the purposes of our processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
4. where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal information unless we can demonstrate an overriding legitimate ground.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.  Please note, however, that this will not affect the lawfulness of the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To exercise any of these rights above, please email us at SRE_LE@sreglobal.com or send messages to us at Contact Us.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or the interests of SRE and its related parties (including their proprietary information, trade secrets or intellectual property), or where there are overriding public interest reasons or where we are required by law or bona fide internal policies and procedures to retain your personal information.

In the event that you wish to make a complaint about how we process personal information about you, please contact us at SRE_LE@sreglobal.com or send messages to us at Contact Us and we will work to deal with your request as soon as possible.  This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the applicable country in which you live or work or where you think we have infringed data protection laws.

Information and Deletion Requests

You have the right to request access to the personal information we collect from you and update or correct that information. Based on the applicable laws, you may have the right to request to delete it in some circumstances.  Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies.  The period we estimated to respond to your request is 30 days from the date of receipt or a shorter period in accordance with applicable laws. 

We will not discriminate against you if you exercise your privacy rights. However, the exercise of privacy rights may hinder your rights to use this Site. We may cease to respond to your messages or resume and suspend other services without getting necessary personal information.

Exercising your Rights

To exercise the rights described above, please submit a request to us by emailing us at SRE_LE@sreglobal.com or send messages to us at Contact Us.

Your request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person.
• Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with nonpublic personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you.  We will use the information provided in a request solely to verify your identity or authority to make the request.

Governing Law

The laws of Taiwan govern this Privacy Policy.  Any dispute relating to this Privacy Policy shall be resolved solely in the courts located in Taipei, Taiwan.  You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute, controversy or claim and agree to waive trial by jury in any such dispute.