Privacy Policy

1. Information We Collect

The following personal information is collected in connection with the Website

Information You Provide Directly
You may access and use our Website without telling us who you are or reviewing any personal information about yourself. However, for you to receive newsletters from us, you are required to provide us with personal information.

• The information we collected is your email address.

Information about Your Use of Our Services
In addition to the information you provide, we will collect information about your use of our Website through software on your devices and by other means. We will collect:

• Device information: Country, location information (city, state / province, country information from IP address), language, IP address, settings of devices and device identifiers, such as Customer GUID.

• Log information: Usage information, such as, browser, ISP, performance timing, referrer, time zone, most recent search engine, search query, total time spent on tracked pages in minutes, e-mail open tracking records and cookies.

• Service usage information: Other information about your use of our Website, such as visit history and how you interact with content offered through our Website.

2. How We Use the Information

We use your information we collect about you in order to:

• To send newsletters regarding LG Energy Solution’s new products and services.

• Operate, evaluate and improve our Website, including analyzing our Website, performing data analytics and other internal functions.

• Monitor use of our Website and use your information to help us monitor, improve and protect our products, content, services and websites

This means that the legal basis for us processing your information as described above will typically be one of the following:

• Legitimate Business Interests: We process personal information to the extent this is necessary to fulfil our legitimate interests (or those of third parties), which include our interests to

(1) protect against, identify and prevent fraud and other criminal activities, claims and other liabilities;

(2) provide you with tailored functions such as an autofill function, a quick search function based on your most visited pages on the Website, and additional contents tailored to your interests;

(3) monitor use of our Website and use your information to help us monitor, improve and protect our products, content, services and Website;

(4) effectively manage our relationship with our customers, including by communicating with you, responding to your queries, resolving technical issues, providing you with customer care support and sending you necessary information relating to contents on our Website;

(5) protect the security, availability and integrity of our Website and information systems, including by using authentication mechanisms and other security measures, monitoring our systems for security threats, keeping back-ups, and carrying out system maintenance services;

(6) protect our legal rights, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us or other companies in our group and our Website;

(7) operate, evaluate and improve our Website, including developing new products and services, managing our communications, analyzing our Website, performing data analytics, auditing and other internal functions;

(8) improve our Website, including by seeking your feedback and performing data analytics on the usage of our Website; and

(9) effectively manage our business, including by generating reports and analyzing the performance of our Website (through the use of aggregated information), auditing our business processes, using statistics to make informed business decisions.

• Your Consent: We seek your consent to process your personal information, where we consider it appropriate or where this is required by law. We use consent to:

(1) On an individual level analyze customer behaviors, build up customer usage patterns and profiles in order to identify user trends and optimize our offering to customers globally;

(2) Place cookies and use similar technologies in accordance with our Cookie Policy and the information provided to you when those technologies are used. For more information, see Cookie Policy section below; and

(3) Send you marketing communications (where this is required by law or where we otherwise elect to rely on consent).

On other occasions where we ask you for consent, we will use the data for the purpose explained to you at that time. When we rely on your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out before you withdrew your consent. To exercise this right, please see the “Your Rights” section.

3. When Do We Disclose Your Information to Third Parties?

We do not share your personal information with others except as indicated within this Policy or when we inform you. We do not sell personal information to anyone and only share your personal data with third parties for their use in authorized and necessary instances;

• Third Party Service Providers: We may disclose your information to companies that provide services on our behalf, such as, companies that help us develop and operate systems for our Website. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing the relevant services to us. In addition, we may share your personal information with third parties that operate apps and services that connect with certain features of our Website.

While we generally do not share the information with additional third parties, please note that in the following specific circumstances, we may further share the information with the following entities;

• Other Parties When Required by Law: As required by court order or other government or law enforcement authorities in order to comply with legal process or law;

• Other Parties When it is Necessary to Protect Our Services: In order to protect and defend our rights and property, including by way of legal proceedings;

• Other Parties When it is to Protect Any of Our Users’ Personal Safety or Property: In order to protect the personal safety or property of our users or the public.

We will take commercially reasonable steps in order to ensure any such third parties treat your personal information securely.

4. Transferring Information outside the Europe Economic

As a global, organization, we, our affiliates, subsidiaries, and suppliers may need to transfer your information (including your Personally Identifiable Information) outside the country where you are located, such as South Korea. This includes transferring your information outside the European Economic Area, if this is where you are located. We transfer your personal information in connection with providing this manner in order to provide you with our Website and any other purposes outlined in this Privacy Policy. You will need to provide your consent to this in order to use the Services. You should also bear in mind that the data protection laws in many of these countries may not offer the same level of protection as those in the country where you are located. However, before transferring your Personally Identifiable Information we will take steps to ensure that safeguards are put in place aimed at ensuring such information will be afforded the same level of protection. For further information on how we handle and protect your personally information, please contact us at privacy.es@lgensol.com

5. Retention of Personal Information

We will take reasonable steps to make sure that we keep your personal information for as long as is necessary for us to provide you with services under the Website or other purposes set out in this Privacy Policy. We apply criteria to determine the appropriate retention period for different categories of personal information you provide us with. For example, we will keep information necessary to protect us in a legal claim, such as information relating to a contract, for the lifetime of the contract and up to six months after. After this period it will be deleted or in some cases anonymized. Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.

6. Cookies and other tracking technologies

When you use the Website, we may use cookies (small text files containing a string of alphanumeric characters), beacons and other similar technologies (together referred to as “cookies” in this Policy). We notify you about our use of cookies when you first visit our Website, through a notification banner at the bottom of the page. By continuing to use the site, you consent to our use of cookies.

• What Are Cookies?
Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies do lots of different and useful jobs, such as remembering your preferences and generally improving your online experience.

• Session and Persistent Cookies
We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. It allows a website to remember your actions and preferences.

• What If I Don’t Want to Accept Cookies?
Although you have to consent to our use of cookies, as noted above, you can set your browser in such a way that you are informed about the placement of cookies and only allow cookies in individual cases, exclude cookies for specific events or automatically delete cookies. If you disable or limit the use cookies, the functionality of our website may be limited.

• Categories of Cookies We Use

Essential cookies — These cookies are necessary to help you access and move around our site and use all its features. Without these cookies, our Website would not work properly and you would not be able to use certain important features. These cookies don’t gather information about you for the purposes of marketing.

Functionality cookies — These cookies allow the website to remember choices you make, such as your username. They may also be used to provide services you have requested, such as watching a video. The information these cookies collect is anonymized (i.e., it does not contain your name, address, etc.) and they do not track your browsing activity across other websites.

Performance cookies — These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor, although they may collect the IP address of the device used to access the site. All information these cookies collect is anonymous and is only used to improve how a website works, improve the user experience.

• Third Party Cookies Used on Our Website

Whether a cookie is a first- or third-party cookie depends on which website the cookie comes from. First-party cookies are those set by or on behalf of the website you visited. All other cookies are third-party cookies. We use both first-party and third-party cookies, which you can read more about in our list that follows.

If you would like to learn more about any of these third-party cookies, we encourage you to visit their websites to learn more details about their policies.

Cookie Management
Visitors to our website are advised via a pop-up message about the cookies that we use and directed to this page if they would like more details. This cookie from Cookie Script remembers that the customer has accepted the cookie consent banner. It’s stored in the user’s browser and means you don’t see the banner again.

Multimedia Content
YouTube is used to deliver video content on our Website. Their cookies gauge the bandwidth of your internet connection so they can optimize the video display and also identify unique users so they can personalize your experience based on previous video usage.

Website Analytics
Google Analytics collects information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, from whence visitors have come to the site, and the pages they visited.

7. Your Choices

We provide many choices in relation to our marketing communications via an unsubscribe option on every marketing email, then we stop using your data for direct marketing purposes by contacting us using the information specified in the “Contact Us” section below. If you opt-out of marketing emails, we may still send you transactional and administrative emails about the Services you use.

8. Your Rights

Your personal information belongs to you. To the extent provided by applicable law, you may ask us to provide details about the personal information we have collected, and you can ask us to delete any personal information or correct any inaccuracies. To the extent provided by applicable laws, you can also ask us to restrict or limit the processing, sharing, or transferring of your personal information, as well as to provide you with personal information that we have collected from you so you can use it for your own purposes. We will not delete data that we are required by law to retain. To exercise your rights please contact us using the information specified in the “Contact Us” section below.

9. How we Protect Personal Information

We use commercially reasonable efforts to safeguard the confidentiality and security of your personal information. Nevertheless, due to the design of the Internet, ever-changing technology, and other factors outside of our control, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties or that we will not be subject to security breaches. We do not accept any responsibility for the disclosure of personal information due to errors in transmission or unauthorized or unlawful acts of third parties. If you believe your Personal Data has been compromised, please contact us. In the event that personal information is compromised, we will promptly notify our customers in compliance with applicable law.

10. Sensitive Data

We request that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send us this information, then you are consenting to its processing in accordance with this Privacy Policy. To avoid processing of sensitive data, do not submit it.

11. Children’s Privacy

Our Website is designed for a general audience and is not directed towards children. In connection with our Website, we do not knowingly collect or maintain personal information from anyone under the age of sixteen (16) or knowingly allow such persons to use our Website. If you are under the age of sixteen (16), please do not attempt to register for our Website or provide us with any personal information. If we learn that a person under the age of sixteen (16) has provided us with any personal information, we will promptly delete such personal information. If you believe that a child under the age of sixteen (16) may have provided us with personal information, please contact us using the information specified in the “Contact Us” section.

12. Updates to Our Privacy Policy

This Privacy Policy may be updated by us from time to time. If we make a material change to our Privacy Policy, we will update New Policy on our Website and notify our change of Privacy Policy. You may be required to acknowledge or agree to the revised Privacy Policy in order to continue using the Website.

13. Third Party Web Sites

This Policy applies solely to information collected on the Website. The Websites may contain links to other websites. We are not responsible for the privacy practices or the content of these other websites.

14. Contact Us

For more information about our privacy practices, or to exercise any rights you may have pursuant to applicable law, please contact us at privacy.es@lgensol.com (Tel. +82-2-3777-1114) or via post at Security Audit Team, LG Energy Solution, 108, Yeoui-daero, Yeongdeungpo-gu, Seoul, 07335 Republic of Korea.

Effective Date: 31 Mar, 2022
Last Updated: 28 Mar, 2022