Privacy Policy | XP Power

Overview – the key information you should be aware of:

(A) Who we are:

We are XP Power Ltd, and if you need it, our company number is 200702520N and our registered office is at

19 Tai Seng Avenue,
#07-01,
Singapore 534054.

XP Power Ltd is the controller of your personal information, and is responsible for your personal information. All references in this policy to "XP Power", "our", "us" or "we" refer to XP Power Ltd, or our group companies, as appropriate. All references in this policy to "our websites", refer to the websites owned by us at www.xppower.com and subdomains.
(B) Our values and what this policy is for:

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find in Section 6

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know using our contact details in section 13.
(C) Who this policy applies to:

This policy applies to:
- 1. Visitors to our websites
- 2. Customers, and employees of customers
- 3. Prospective customers and investors (to whom we send marketing communications)
- 4. Investors, being members of the investor alert service within our websites
- 5. XP Power Employees, and Prospective employees; and
- 6. People who contact us with enquiries
Depending on our relationship, we will collect and use your information in different ways. Please click on the links above to find out the information that we collect about you and how we use this information.
(D) What this policy contains:

This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):
(E) Your rights to object:

You have various rights in respect of our use of your personal information as set out in section 6. Two of the fundamental rights to be aware of are that:
- 1. you may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
- 2. you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.
You can find out more information in section 6.
(F) What you need to do and your confirmation to us:

Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of:
- 1. How we obtain your personal information
  - 1.1 You may provide us with your personal information voluntarily. [We may also receive information about you from third parties such distributors, marketing agencies, market research companies, media, our suppliers, contractors and consultants, group companies, public websites and public agencies, which we refer to as "third party sources" or "suppliers" throughout this policy. Our suppliers include Investis Digital and Code23 who host and maintain our Websites, SalesForce which stores and processes customer data.]
  - 1.2 You may give us personal information about yourself by using the online forms provided on our websites, setting up an account with us, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or products from us.
- 2. Collection of your personal information and how we use it
  - 2.1 Personal data that we collect from you
    - (a) We, or third parties on our behalf, may collect and use any of the following information about you:
      - (i) your name
      - (ii) your company name;
      - (iii) your postal address;
      - (iv) your job title;
      - (v) your email address;
      - (vi) your telephone number;
      - (vii) information provided when you correspond with us;
      - (viii) any updates to information provided to us;
      - (ix) information you provide to help us provide you with improved service, for example if we ask you to fill in a survey or questionnaire;
      - (x) personal information we collect about you or that we obtain from our third party sources; the following information created and recorded automatically when you visit our website:
        
        (A) Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the websites addressed and location from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our websites, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages;
        
        (B) Information about your visit and your behaviour on our websites (for example, the pages that you click on). This may include the websites you visit before and after visiting our websites (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads;
    - (b) if you are a customer we may also collect the following information about you:
      - (i) information about the goods and other services we provide to you; including:
        
        (A) information needed to provide the goods to you (including order details, order history and payment details);
        
        (B) customer services information; and
        
        (C) customer relationship management and marketing information;
      - (ii) bank details; and
    - (c) if you are a prospective employee, we may also collect:
      - (i) education data (school, academic performance); and
      - (ii) employment history (current role, salary and employer details)
      - (iii) other details from your CV or covering letter.
  - 2.2 How we use your personal data that we collect
    
    We will collect, use and store the personal information listed above for the following reasons:
    - (a) to allow you to access and use our website;
    - (b) to provide you with access to, and use of, our investor alert service;
    - (c) to receive and deal with enquiries from you about our products;
    - (d) to send you certain communications (including by email or post) about our products such as administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
    - (e) to assess your suitability for employment with us or a role;
    - (f) for improvement and maintenance of our websites and to provide technical support for our website;
    - (g) to carry out statistical analysis and market research on people who may be interested in our business and products;
    - (h) if it is in our legitimate interests for business development and marketing purposes, to contact you (including by telephone or post) with information about our products or the products and services of our suppliers which either you request, or which we feel will be of interest to you;
    - (i) if you are a sole trader or a non-limited liability partnership and if you have consented, to contact you by email with information about our products or the products and services of our suppliers which either you request, or which we feel will be of interest to you.
    - (j) to ensure the security of our website;
    - (k) to recognise you when you return to our websites, to store information about your preferences, and to allow us to customise the websites according to your individual interests; and
    - (l) to evaluate your visit to the websites and prepare reports or compile statistics to understand the type of people who use our websites, how they use our websites and to make our websites more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
    Please see section 2.4 for more details about how we use your personal information.
  - 2.3 Our cookies
    - (a) Some pages on our websites use cookies, which are small files placed on your internet browser when you visit our websites. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
    - (b) Where we use cookies on our websites, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our websites or to use all the functionality provided through our websites.
  - 2.4 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
    - (a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
    - (b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
    - (c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
    - (d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
- 3. Legal basis for use of your personal information
  - 3.1 We consider that the legal basis for using your personal information as set out in this privacy policy are as follows:
    - (a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to fulfil an order which you place with us, to comply with the terms of use of our websites which you accept by browsing our websites and/or to comply with our contract to provide products to you or your employer); or
    - (b) our use of your personal information is necessary for complying with our legal obligations [(for example, for health and safety purposes)]; or
    - (c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website).
      
      Our legitimate interests are to:
      - (i) run, grow and develop our business (as well as the businesses of our group companies);
      - (ii) operate our websites and our investor alert service;
      - (iii) select appropriately skilled and qualified personnel;
      - (iv) carry out marketing, market research and business development; and
      - (v) for internal group administrative purposes.
    If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
  - 3.2 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
  - 3.3 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at dataprotection@xppower.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our products and associated services to you (for example, we may not be able to provide marketing information to you regarding our products and services).
- 4. How and why we share your personal information with others
  - 4.1 We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
  - 4.2 We will share your personal information with the following third parties or categories of third parties:
    - (a) Investis Digital, Code23, which host our investor alert service and develops and/or maintains our website may access personal data stored within that solution when providing their services to us;
    - (b) we may share anonymised and aggregated statistical information with our customers, our distributors, our suppliers to demonstrate what interest there has been in any marketing campaigns we have assisted our suppliers in carrying out;
    - (c) our other service providers and sub-contractors, including payment processors, suppliers of technical and support services, insurers, logistic providers and cloud service providers;
    - (d) companies that assist in our marketing, advertising and promotional activities, such as the marketing automation platform SalesForce; and
    - (e) analytics and search engine providers that assist us in the improvement and optimisation of our website;
  - 4.3 We will also disclose your personal information to third parties:
    - (a) where it is in our legitimate interests to do so to run, grow and develop our business:
      - (i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
      - (ii) if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
    - (b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
    - (c) in order to enforce or apply our terms of use, our terms and conditions for customers and subscription service members or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
    - (d) to protect the rights, property, or safety of XP Power, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.
  - 4.4 We may also disclose and use anonymised, aggregated reporting and statistics about users of our websites or our products for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
  - 4.5 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
- 5. How long we store your personal information
  
  We will not retain personal information for a period longer than is necessary for achieving the purposes for which they were collected, or as long as necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
- 6. Your rights
  - 6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at dataprotection@xppower.com at any time. You have the following rights:
    We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details in section 13.
    We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 13.
    This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
    - (g) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
  - 6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
  - 6.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
- 7. Children
  - 7.1 Our websites and products are not directed at children and we do not knowingly collect any personal information from children.
  - 7.2 If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
  - 7.3 Please contact us at dataprotection@xppower.com if you are aware that we may have inadvertently collected personal information from a child.
- 8. Marketing
  - 8.1 We may collect and use your personal information for undertaking marketing by email, telephone and post.
  - 8.2 We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.
  - 8.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
  - 8.4 If you wish to stop receiving marketing communications, you can contact us by email at dataprotection@xppower.com.
- 9. Where we may transfer your personal information
  - 9.1 We are a global business and your personal information may be used, stored and/or accessed by staff operating outside the UK or the EEA working for us, other members of our group or suppliers.
  - 9.2 If we provide any personal information about you to any such non-UK and non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following:
    - (a) ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data; or
    - (b) where we have in place standard model contractual arrangements with the recipient which have been approved by the European Commission (or the UK Government for transfers out of the UK in due course). These model contractual clauses include certain safeguards to protect the personal data;
  - 9.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at dataprotection@xppower.com at any time.
- 10. Risks and how we keep your personal information secure
  - 10.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
  - 10.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.
  - 10.3 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our websites and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
  - 10.4 Where we have given you (or where you have chosen) a password which enables you to access your online account or certain other parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- 11. Links to other websites
  
  Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. If you follow a link to any of these websites, please note that these websites have their own terms and conditions and privacy policies and that we do not accept any responsibility or liability for these policies. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies. Please check these policies before you submit any personal data to these websites. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties.
- 12. Changes to our privacy policy
  
  We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.
- 13. Further questions and how to make a complaint
  The practices described in this privacy policy statement are current as of 11th April 2022.

Privacy statement

Overview – the key information you should be aware of: