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U.S. PRIVACY POLICY for the LG ESS Battery Division

  • Last updated: February 21, 2022

    We at LG Energy Solution, Ltd. care about your privacy.

    This Privacy Policy applies specifically to the collection practices of the LG ESS Battery Division, including through its website (https://www.lgessbattery.com). This Privacy Policy does not apply to any other LG Energy Solution branded products or services.

    The purpose of this Privacy Policy is to explain how we collect information, what we collect, how we use it, how we share it, and what controls and rights you may exercise with respect to your information.

    We may update this Privacy Policy from time to time.

  • • Data Collection About Partners

    A “Partner” is an individual who has registered as a member of the ESS Battery Website (www.lgessbattery.com). Partners are typically installers or distributors who handle our LG home battery products. This section describes our practices with respect to Partner information.

    1. Information We Collect

        CEO Name / Phone Number / Email / Company Location / Number of Employees / Preferred Distributor

    2. Purpose for Collection

        Member registration / Providing product and company information, including about LG Energy Solution’s Residential Energy Storage business / Distribution of marketing materials (including by mail, email and telephone) / Notifications regarding software updates, training sessions for installers, and new product releases / Permitting access to other LG products and services, including the RESU Monitor

    3. Methods of Collection

        Directly from you through the website

    4. Additional Uses of Information and Grounds for Processing

      In addition to the purposes for collection listed above, we also process information:

      1. - For purposes related to the negotiations and performance of a contract, i.e. for the purposes necessary to perform the contract – this concerns Partners who are natural persons and are parties to a contract with us.

      2. - To comply with obligations resulting from legal requirements, e.g. tax regulations and other provisions that apply to us.

      3. - For administrative purposes, such as conducting internal policies, financial planning, debt collection, processing inquiries and complaints, pursuing claims and defending against claims, verification of compliance with internal procedures, marketing of our products and services, and for other legitimate business purposes.

      4. - In accordance with any consent that you give.

        Certain information collection may be voluntary, and other collection may be required. If you don’t provide information to us when required for a particular processing purpose (e.g., to complete a contract with you), then we may not be able to provide the service you request.

  • • Data Collection about Users

    A “User” is a non-registered individual who interacts with us, including but not limited to through the ESS Battery Website, SNS channels, and advertisements.

    1. Information We Collect

        Name / Postal Code / Phone number / Mobile phone number / Email / Address / Electricity bill / Whether you own your house / Title, Content, Recipient of Inquiry or Quote Request

    2. Purpose for Collection

        Marketing (including by mail, email and telephone) / Introduction of LG Energy Solution’s products / Contact you if necessary in relation to the product and its use / Manage and coordinate product recalls / Troubleshooting and monitoring product operation / Permitting access to other LG products and services, including the RESU Monitor

    3. Methods of Collection

      1. Directly from you through the website and offline / From our distributors, retailers, and installers / From other third parties, including LinkedIn Lead Generation Campaign, Marketing Automation Tool (Oracle Eloqua), Facebook Lead Generation Campaign, AllTime Power Lead Generation Campaign

    4. Additional Uses of Information and Grounds for Processing

      In addition to the purposes for collection listed above, we also process information:

      1. - For purposes related to our contracts with you, including our warranties and terms that apply to your use of our products and services.

      2. - To comply with obligations resulting from legal requirements, e.g., conducting recalls and reporting to regulators.

      3. - For administrative purposes, such as conducting internal policies, financial planning, debt collection, processing inquiries and complaints, pursuing claims and defending against claims, verification of compliance with internal procedures, marketing of our products and services, and for other legitimate business purposes.

      4. - In accordance with any consent that you give.

        Certain information collection may be voluntary, and other collection may be required. If you don’t provide information to us when required for a particular processing purpose (e.g., to help you troubleshoot a product), then we may not be able to provide the service you request.

  • • Retention Period and Data Security

    We retain your information for the period as required by the law and in accordance with our data retention policies. You may request copies of our data retention policies by contacting us.

    We take steps to secure your information and to destroy it once it is no longer necessary for our business purposes or the retention period has lapsed. In case of paper records, we use the paper shredder to dispose of such data or incinerate the paper. In case of electronic files, we delete the data in a manner that is intended to prevent restoration or re-identification.

  • • Recipients

    We may share your information outside of our company in the following ways:

    - User information: Service providers that assist with storage, marketing, and advertising.

    - Partner information: Service providers that assist with system maintenance.

    Furthermore, depending on the circumstances, the personal data may be transferred to other entities, e.g. entities providing services to the Company, such as IT service providers, advisers, auditors, and to the extent that it is necessary to fulfill obligations resulting from legal regulations, e.g. to the government authorities.

  • • Your Rights and Choices

    You may have certain rights under the law in connection with the processing of your personal information.

    1. Correcting your Information

        If you believe that we may have false or inaccurate information about you, you may request that we correct it. Please contact us at privacy.es@lgensol.com to submit your request.

    2. Marketing Opt-Out

        If you wish to opt-out of receiving our marketing communications, use the unsubscribe mechanism included in the marketing communication or contact us at privacy.es@lgensol.com. Even if you opt out of marketing, you may still receive administrative or transactional communications from us.

    3. California Privacy Rights

      1. If you are a California resident, you may request certain information regarding our disclosure of certain categories of personal information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at privacy.es@lgensol.com. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below. Note that we do not currently share personal information with third parties for those third parties’ direct marketing purposes.

      2. In addition, California residents may have the following additional rights under the California Consumer Privacy Act:

        1. - The right to know: You have the right to request to know (ii) the categories of personal information we have collected about you in the last 12 months; (ii) the specific pieces of personal information we have about you; (iii) the categories of sources from which that personal information was collected; (iv) the categories of your personal information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your personal information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your personal information.

        2. - The right to deletion: You have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.

        3. - The right to opt out: You have the right to opt out of the sale of your personal information.

        4. - The right to equal service. If you choose to exercise any of these rights, Kastle will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our websites or services.

      4. This Privacy Policy describes our practices over the last 12 months with respect to categories of information we collect, the sources of that information, and how we have disclosed it. We do not disclose your personal information to third parties who are not our service providers, nor do we sell your personal information.

      5. You may exercise your right to know twice a year free of charge. You may use an authorized agent to submit a request. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

      6. To exercise your rights, contact us at privacy.es@lgensol.com.

      7. We will take steps to verify your identity before processing your request. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose.

    4. Nevada Privacy Rights

      Nevada law gives residents the right to opt out of the sale of their personal information. We are not considered a data broker under the Nevada law and do not sell your personal information.

  • • Do Not Track Signals
    1. Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes; however, we do not currently recognize or respond to browser-initiated DNT signals.
  • • Protection of Children’s Privacy
    1. We do not knowingly or intend to collect any information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction.
  • • Contact Us

    You may contact us at privacy.es@lgensol.com or 1-888-737-8104 if you have any questions about this Privacy Policy or our data handling practices.

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