Global Privacy Policy
Last updated: March 22nd, 2024

The companies as below, including STANLEY ELECTRIC CO., LTD. will provide (the “Company”, “we”,“us” or “our”) this global privacy policy (this “Privacy Policy”) for the methods of processing personal
information of the data subject (“you”,“your”,) that we collect in our business. The Company is located at as
described as below.
Name

Address

Stanley Electric Co., Ltd.

2-9-13 Nakameguro, Meguro-ku, Tokyo, Japan

Stanley Iwaki Works Co., Ltd.

3-1 chubukogyodanchi , Iwaki-shi,Fukushima 972-8338,
Japan

Stanley Tsuruoka Works Co., Ltd.

45 aza-Otsubo, Watamae, Tsuruoka-shi,Yamagata 9997695, Japan

Stanley Miyagi Works Co., Ltd.

20-2 Aza-kawadonuma, Kitakata, Hasama-cho, Tomeshi, Miyagi 987-0513, JapanSTANLEY WELL Corp.

434 Soya, Hadano-shi, Kanagawa 257-0031, Japan

Stanley Ina Works Co., Ltd.

7302-1 Matsuoteradoko, Iida-shi, Nagano 395-0822,
Japan

Stanley Niigata Works Co., Ltd.

497-28 aza-Miyashita, Kitatanaka, Minamiku, Niigatashi, Niigata 950-1237, Japan

Matsuo Electric Co., Ltd.

10392-2 Kamitokura,Daiwacho, Mihara-shi, Hiroshima729-1405, Japan

Stanley Pal Co., Ltd.

2-5-26 Nakameguro, Meguro-ku, Tokyo 153-8636,
Japan

Tianjin Stanley Electric Co., Ltd.

No.140 Nanhai Road, TEDA, Tianjin, China

Tianjin Stanley Electric Technology
Co., Ltd.

No.99, 6th Avenue TEDA, Tianjin, China

Wuhan Stanley Electric Co., Ltd.

No.818, Gexin road, Dongxihu District, Wuhan, Hubei,
China

Stanley Electric (China) Investment
Co., Ltd.

08B, 2nd floor, No.1600, Zhongshan West Road, Xuhui
District, Shanghai, China

In addition to this Privacy Policy, which applies to all of our processing personal information, the Company
has prepared addenda that may also apply to the data subject depending on the area in which the data subject
resides or is located. In such case, please refer to the applicable addenda. If this Privacy Policy conflicts
with the country-specific addenda, such addenda will prevail.

1.
Categories of personal information subject to processing
The Company collects and processes the following personal information. Some of it may be collected
automatically.

(1) Personal information relating to customers
The Company collects and processes the following personal information of customers of the Company(Collectively, “customers”), including, but not limited to, potential customers and customers who access thewebsite of the Company (the “Website”) , and who inquire of the Company through the Website.
- Name, e-mail address, address, postal code, territory or country of residence, phone number, type of yourbusiness, your company`s name, your department, and phone number of your company, position in thecompany, record of products or services you have considered (or are interested in), bank accountinformation, credit card information, ID, and password of customers.
- Cookies, ADID, IDFA and other terminal identifiers and attribute information of customers who accessthe Website (such as age, gender, interests categories, affinity categories, in-market segments, purchasing
tendency inferred from Website browsing history and level of interest inferred from information on
Website the customers stay. For more information about interests categories, affinity categories, in-market
segments, visit About Demographics and Interests - Analytics Help (google.com)- IP addresses, provider information, terminal information, web browser information and access area
information (location data) of customers who access the Website.
- Questionnaire information and inquiry details, products for which you wish to obtain IES information,categories of inquiry (specifications, price, inventory, request for brochure, sample, proposal, etc.) of
customers who inquiry of the Company.
- Other personal information required to pursue purpose of use in Article 2 below.
(2) Personal information relating to directors and employees etc. of business partners
The Company collects and processes the following personal information of directors and employees etc. ofbusiness partners which they provide.
- Name, e-mail address, address, postal code, phone number, type of the business partners’ business, thebusiness partners’ name, department the directors and employee belong to, and phone number of thebusiness partners, position of the directors and employee, record of products or services the business
partners have considered (or are interested in), bank account information- Questionnaire information and inquiry details (specific inquiries such as UV LEDs, infrared LEDs, visible
light LEDs, etc., inquiries regarding requests for information materials, etc.), categories of inquiry(specifications, price, inventory, request for brochure, sample, proposal, etc.) and- other personal information required to pursue purpose of use in Article 2 below.
(3) Personal information relating to shareholders
The Company collects and processes the following personal information of shareholders which they provide.
- Name, address, e-mail address, number of shares held, date of acquisition of shares, shareholder number,
dividend payment history, dividend payment account, and other information necessary to contact
shareholders or for administration in accordance with the Companies Act and other laws and regulations- other personal information required to pursue purpose of use in Article 2 below.
(4) Personal information relating to applicants for employment by the Company
The Company collects and processes the following personal information of applicants for employment by
the Company which they provide.
- Name, alias, age, gender, e-mail address, phone number, educational and in-house background,
qualification, academic transcript of their former school, bank account information, work history,
signature, social insurance information, transcripts of academic results, married/unmarried, healthcondition, military service record, origin of country, personnel evaluations, resumes, face photo, family
information- other personal information required to purse purpose of use in Article 2 below.

2.
Purpose of use of personal information
The Company may process your personal information for the following purposes:(1) Personal information relating to customers- to respond to inquiries from customers- to send quotations, product introductions, performance reports, catalogues, etc. and provide information
on B to C products, LED products, and IES data to customers, and otherwise communicate with you
through various means, which may include by email, telephone, post, or by other means as communicatedto you from time to time
- direct marketing- targeted advertising based on the preference and interest inferred from the browsing and purchasing history- to provide services, operate, and improve services- to analyze the use of the Website- to make de-identified or aggregated information from personal information- for compliance with law- for other purposes permitted under applicable laws and regulations.
(2) Personal information relating to directors and employees etc. of business partners- to respond to inquiries from business partners- to send quotations, product introductions, performance reports, catalogues, etc. to business partners , andotherwise communicate with you through various means, which may include by email, telephone, post, orby other means as communicated to you from time to time
- to receive services and goods (contracts, inquiries, orders, etc.)- to contact suppliers to deal with bankruptcy, etc. of suppliers- to confirm schedule adjustments and changes in delivery dates, etc.
- to confirm that business operations are being handled properly- QCDE operations and management with business partners- to make de-identified or aggregated information from personal information- to register internal account to start transaction- for compliance with law- for other purposes permitted under applicable laws and regulations.
(3) Personal information relating to shareholders- to exercise rights or perform obligations under the Companies Act and other laws and regulations- to manage the Company in accordance with laws and regulations- to make de-identified or aggregated information from personal information- otherwise communicate with you through various means, which may include by email, telephone, post, orby other means as communicated to you from time to time
- for other purposes permitted under applicable laws and regulations.
(4) Personal information relating to applicants for employment by the Company- to implement and manage operations related to recruitment- to provide or communicate employment information, etc. to applicants for employment- to make de-identified or aggregated information from personal information- for compliance with law- for other purposes permitted under applicable laws and regulations.

3.
Legal basis, etc. for processing
The Company processes your personal information in accordance with applicable personal information
protection regulations. Please refer to the country-specific addenda regarding the Company’s legal basis forprocessing.
You may be required to provide the Company with certain personal information because the provision of
personal information is a statutory or contractual requirement, or a requirement necessary to enter into acontract or for other reasons. In this case, if you do not provide your personal information, the Company may
not be able to provide to you our service.
For example, customer’s IP addresses, provider information, terminal information and web browser
information is a requirement necessary for the customer to access the Website.

4.
Retention period for personal information
We retain personal information for as long as necessary to fulfil the purposes for which we collected it,
including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend
legal claims, or for compliance and protection purposes. To determine the appropriate retention period for
personal information, we consider the amount, nature, and sensitivity of the personal information, the potential
risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we
process your personal information and whether we can achieve those purposes through other means, and theapplicable legal requirements.

5.
Sources of personal information
The Company collects your personal information directly when you provide your personal information and
the Company may also collect personal information from you automatically.
The Company may also collect your personal information indirectly from third parties. Specifically, theCompany collects attribute information of customers who accesses the Website which the Company obtains
from the Website Traffic Analysis Service Provider such as Google LLC. The Company may also infer yourpreference and interests from the information collected from you. In addition, as for the personal information
relating to applicants for employment by the Company, the Company may collect personal information fromschool you are graduating from or have graduated from. Furthermore, the Company may collect personal
information from Group companies of the Company (Stanley’s Locations | STANLEY ELECTRIC CO., LTD.).

6.
Sharing and disclosure of personal information
The Company shares with and discloses your personal information to the following third parties in order tofulfil the purpose of processing personal information as set out above.
I Sharing with Processors (service providers)(1) Personal information relating to customers- Server management company-

Homepage management companies
Website maintenance service provider
EC shopping service provider
The Website Traffic Analysis Service Provider (such as Google LLC); andOther contractors of the Company

(2)Personal information relating to directors and employees etc. of business partners-

Server management company-

Other contractors of the Company(3) Personal information relating to shareholders- Server management company-

Stock transfer service providers
Japan Securities Depository Center, Inc.
Lawyer, tax accountant, certified public accountant
Other contractors that provide services necessary for the Company's business activities(4) Personal information relating to applicants for employment by the Company- Server management company-

Affiliates necessary to archive the purpose, unemployment office, organizations related to schools towhich applicants belong to and agencies for recruitment
Website maintenance service provider
Recruitment agency company
Other contractors of the Company

II Sharing with Group companies(1) Personal information relating to customers- Group companies of the Company (Stanley’s Locations | STANLEY ELECTRIC CO., LTD.),(2) Personal information relating to directors and employees etc. of business partners- Group companies of the Company (Stanley’s Locations | STANLEY ELECTRIC CO., LTD.)(3) Personal information relating to applicants for employment by the Company- Stanley Electric Co., Ltd.
- StanleyPal Inc.,
III Legal compliance, etc.
In some instances, the Company may be required to disclose your personal information to public andgovernmental authorities within or outside your country of residence in accordance with law and/or requests
from such authorities. The Company will also disclose your personal information if the disclosure isnecessary or appropriate, due to the purposes of law enforcement or handling other issues of public importance.
The Company will also disclose your personal information if the disclosure is reasonably necessary to protect
the Company’s rights, to pursue available remedies, to enforce the Company’s terms of use, to investigate
fraud, or to protect the Company’s operations or you.
IV OtherIn addition, we may also share your personal information with other parties, including the following.
- As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including aspart of a bankruptcy proceeding;- Cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain aprincipal's consent;- With your consent- Other cases permitted under applicable laws and regulations.

7.
Overseas transfer of personal information
As a result of the above sharing and disclosure, your personal information may be transferred to the following
countries.
- United States of America-

Thailand
Korea
China
India
Germany
FranceEngland
Hungary
Singapore
TaiwanHong Kong
Indonesia
Philippine
Vietnam
Australia
BrazilMexicoIn such cases, the Company will take proper protection measures required by the personal information
protection regulation of each country. For the protection measures of each country, please refer to the countryspecific addenda.

8.
Joint use of personal information
We will use personal information jointly with specific parties as follows on the basis of joint use clause underthe Act on the Protection of Personal Information in Japan (APPI). However, if it is necessary to obtain yourconsent under applicable personal information protection regulations other than the APPI, we will obtain yourconsent.
(1) Categories of the jointly utilized personal information
Following personal information of directors and employees etc. of business partners- Name, e-mail address, address, postal code, phone number, type of the business partners’ business,the business partners’ name, department the directors and employee belong to, and phone number of thebusiness partners, position of the directors and employee, record of products or services the business
partners have considered (or are interested in),- Questionnaire information and inquiry details (specific inquiries such as UV LEDs, infrared LEDs,
visible light LEDs, etc., inquiries regarding requests for information materials, etc.), categories of inquiry(specifications, price, inventory, request for brochure, sample, proposal, etc.)(2) Scope of a jointly utilizing person
Affiliates of Stanley Electric Co. Ltd.
(Stanley's Locations | STANLEY ELECTRIC CO., LTD)
(3) Purpose of use for the jointly utilizing person
Purpose of Use as described in 2(2)(4) Appelation and address, and the name of its representative of a person responsible for controlling thesaid personal information
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku, Tokyo, Japan
President and Representative Director YASUAKI Kaizumi

9.
Safety management measures
For safety management of your personal information, the Company takes the following safety management
measures:- Formulation of basic policies: to secure proper processing of personal information, the Company will form
basic security policies e.g. “compliance with related laws, regulations, guidelines, and the like”, “questions
and complaints processing center”, etc.
- Preparation of procedures related to processing of personal information: in each of the steps of acquiring,using, storing, providing, deleting, disposing etc., the Company will form processing procedures for
personal information regarding processing methods, responsible persons, persons in charge and their duties
etc.;- Organizational safety management measures: the Company will, as well as identifying persons responsible
for the processing of personal information, clarify which employees will process personal information andthe scope of personal information that such employee will process, and prepare a reporting andcommunication system if a breach of such access rights is found or a breach of any personal information isfound (in accordance with applicable personal information protection regulations).
- Human safety management measures: The Company will conduct regular training for employees forimportant matters regarding processing of personal information.
- Physical safety management measures: In the areas that personal information will be processed, theCompany will, as well as managing employees’ access of rooms and limiting devices that would be brought
into the room, take measures to prevent access to personal information by persons without authority. The
Company will, take measures to prevent robbery, loss or unauthorised access etc. devices, electronic media,
documents and anything else containing personal information.
- Technical safety management measures: The Company will limit the number of persons in charge and thescope of personal information databases accessible by persons. The Company will install systems toprotect information systems that process personal information from unauthorized access and unauthorizedsoftware from outside.
- Grasping the external environment: The Company will take safety management measures after grasping
systems regarding protection of personal information in the foreign countries where personal informationis stored.

10.
Cookies and similar technologies
When a customer accesses the Website and such customer enables cookies, etc. (including tracking
technologies such as flash cookies and web beacons, and other technologies; “Cookies, etc.”), the Company
may automatically acquire information about the PC, mobile phone, tablet, or other information regarding thecommunication devices used by the customer etc.
Please see the following URL for more information on our cookie policy of the corporate website.
https://www.stanley.co.jp/e/cookiepolicy.html

11.
Regarding acquisition of information accompanied by service tools provided by third parties
I Analytics tool
We may work with third parties that collect data about your use of the Website over time for non-advertising
purposes. For example, the system may use Google Analytics for analytics and marketing purposes.
In Google Analytics, user information will be collected by using Cookies, etc. For more information about
how Google Analytics collects and uses data when you use our Site, visit
https://policies.google.com/technologies/partner-sites?hl=en, and to opt out of Google Analytics, visit
https://tools.google.com/dlpage/gaoptout?hl=en.
Google Analytics advertising function that the Company uses is as follows:- Reports on user attributes and interest categories of Google Analytics
II Links to third-party websites or apps
The Website may provide links to third-party websites or apps. We do not control the privacy practices of
those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy
policies of other websites or apps that you use to learn about their data practices.

12.
Rights of data subjects
The Company will respect the rights you hold regarding personal information protection regulations applicableto you. You may require disclosure of personal information (including records of the provision of personal
information to third parties), correction, addition, and elimination of content, suspension and erasure of usage,
and suspension of provision to third parties in accordance with Japanese laws regarding protection of personal
information. In addition, in personal information protection regulations of each country that will be applied,
rights may be granted to you. For rights granted in each country, please refer to the country-specific addenda.
If you wish to exercise your rights, please make an inquiry using the contact in Article 14 (Contact Details)of this Privacy Policy.

13.
Languages
This Privacy Policy is described in English and translated in Japanese. If any matter set forth herein isinconsistent or in conflict with the Japanese translation version, the provisions of the English prevail withrespect to such matter.

14.
Contact Details
For questions and inquiries regarding this Privacy Policy, please contact the consultation center stated below:

Stanley Electric Co., LTD.
Legal Affairs and Intellectual Property Department
Legal Affairs/IP Management Section
Email: privacy@stanley-electric.com
TEL: 03-6866-2779
If you assert your rights, we may ask a copy of your ID or equivalent details to identify you. In addition, if
the request is submitted by a person other than you, submission of power of attorney may be required.

15.
Changes to the Global Privacy Policy
The Company may, in making changes to the Global Privacy Policy (including country-specific addenda),change or add all or part of the Global Privacy Policy by publishing on the Website, sending e-mail to you, or
giving notice by any other method that the Company deems appropriate (subject to applicable laws andregulations, if any).
If there are any necessary procedures in personal information protection regulations
that will be applied, such procedures will be taken.

UK and EEA Privacy Addendum
Last Updated: March 22nd, 2024

1.

Applicability

This Addendum applies to you if you are in the EEA or UK (or if EEA or UK data protection law applies).

2.

Purposes of process and legal basis for processing

We have to have a legal basis to process your data. For the categories of data listed in Section 1 of the Global Privacy
Policy, we process the data on the following bases to meet the purposes listed in Section 2 of the Global Privacy Policy:(1) Personal information relating to customers
Purpose of the processing

Lawful basis of the processing

to respond to inquiries from customers-

Contract performance (Art. 6.1 (b) GDPR)

to send quotations, product introductions,-

Legitimate interest (Art. 6.1 (f) GDPR)

direct marketing-

Consent (Art. 6.1 (a) GDPR)

targeted advertising based on the preference-

Consent (Art. 6.1 (a) GDPR)-

Contract performance (Art. 6.1 (b) GDPR)

performance reports, catalogues, etc. andprovide information on B to C products, LEDproducts, and IES data to customers, andotherwise communicate with you throughvarious means, which may include by email,telephone, post, or by other means ascommunicated to you from time to timeand interest inferred from the browsing andpurchasing history
to provide services, operate, and improve
servicesto provide and operate services-

Legitimate interest (Art. 6.1 (f) GDPR) to
improve services

to analyze the use of the Website-

Consent (Art. 6.1 (a) GDPR)

to make de-identified or aggregated-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legal obligation (Art. 6.1 (c) GDPR) for

information from personal information
for compliance with law

compliance with EEA, EEA member state,
and UK law-

Legitimate interest (Art. 6.1 (f) GDPR) forcompliance with other laws including
Japanese laws

for other purposes permitted under applicablelaws and regulations-

applicable lawful basis under Art.6 GDPR

(2) Personal information relating to directors and employees etc. of business partners
Purpose of the processing

Lawful basis of the processing

to respond to inquiries from business partners-

Contract performance (Art. 6.1 (b) GDPR)

to send quotations, product introductions,-

Legitimate interest (Art. 6.1 (f) GDPR)-

Contract performance (Art. 6.1 (b) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)-

Contract performance (Art. 6.1 (b) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)

to register internal account to start transaction-

Contract performance (Art. 6.1(b) GDPR)

for compliance with law-

Legal obligation (Art. 6.1 (c) GDPR) for

performance reports, catalogues, etc. tobusiness partners, and otherwise communicate
with you through various means, which may
include by email, telephone, post, or by othermeans as communicated to you from time totimeto receive services and goods (contracts,
inquiries, orders, etc.)
to contact suppliers to deal with bankruptcy,
etc. of suppliers
to confirm schedule adjustments and changes indelivery dates, etc.
to confirm that business operations are being
handled properly
QCDE operations and management withbusiness partners
to make de-identified or aggregatedinformation from personal informatio

compliance with EEA, EEA member state,
and UK law-

Legitimate interest (Art. 6.1 (f) GDPR) forcompliance with other laws including
Japanese laws

for other purposes permitted under applicableapplicable lawful basis under Art.6 GDPR

laws and regulations(3) Personal information relating to shareholders
Purpose of the processing
to exercise rights or perform obligations under

Lawful basis of the processing-

Legal obligation (Art. 6.1 (c) GDPR) for

the Companies Act and other laws andcompliance with EEA, EEA member state,

regulations

and UK law-

Legitimate interest (Art. 6.1 (f) GDPR) forcompliance with other laws including
Japanese laws

to manage the Company in accordance with-laws and regulations

Legal obligation (Art. 6.1 (c) GDPR) forcompliance with EEA, EEA member state,
and UK law-

Legitimate interest (Art. 6.1 (f) GDPR) forcompliance with other laws including
Japanese laws

to make de-identified or aggregated-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)-

applicable lawful basis under Art.6 GDPR

information from personal information
otherwise communicate with you throughvarious means, which may include by email,telephone, post, or by other means ascommunicated to you from time to time
for other purposes permitted under applicablelaws and regulations(4) Personal information relating to applicants for employment by the Company
Purpose of the processing
to implement and manage operations related toLawful basis of the processing-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legitimate interest (Art. 6.1 (f) GDPR)-

Legal obligation (Art. 6.1 (c) GDPR) for

recruitment
to provide or communicate employment
information, etc. to applicants for employment
to make de-identified or aggregatedinformation from personal information
for compliance with law

compliance with EEA, EEA member state,
and UK law-

Legitimate interest (Art. 6.1 (f) GDPR) forcompliance with other laws including
Japanese laws

for other purposes permitted under applicable-applicable lawful basis under Art.6 GDPR

laws and regulations*List of legal basis-

Contractual performance – we have obligations under our service agreement with you, depending on thenature of the contract. To fulfil these obligations we have to use your data.

-

Consent – in certain limited cases, we ask for your consent to use your data. Whenever we ask for yourconsent as a legal basis to process data we will explain the situations where we use your data and for what
purposes.

-Legitimate interest – we process your data when this is necessary for us to achieve a legitimate businesspurpose, or where this is necessary for someone else to achieve their legitimate purpose.

-

Legal obligation – as an organisation we have obligations to comply with legal, regulatory and otherrequirements under EEA or UK laws. In certain cases we will have to use your data to meet these obligations.

**For details of the balancing test for legitimate interests, please contact us using the contact details specified in Section
14 (Contact Details) of the Global Privacy Policy.
3.

Overseas transfer of personal information

As a Japanese headquartered company, most of our IT systems are hosted in Japan and all the personal information held by
the Company listed at Section 1 of the Global Privacy Policy is hosted in Japan. The European Commission and UK
government have determined that Japan offers an adequate level of protection – you can find out more in the adequacy
decision(s) here and here. We rely on these decisions for EEA-Japan and UK-Japan transfers and explain below what
happens when there is not an adequacy decision covering a transfer.
We also transfer personal information to some third parties which host or access personal information outside of the
EEA/UK. In the event such an organisation is in a country which is not subject to an adequacy decision by the European
Commission or UK government or considered adequate as determined by applicable data protection laws, we take steps toensure your personal information is adequately protected by the use of approved Standard Contractual Clauses, or by
vendor's Processor Binding Corporate Rules, or by relying on such other data transfer mechanisms as available underapplicable data protection laws
A copy of the relevant mechanism can be obtained for your review on request by using the contact details at section 14 ofthis Policy.

4.

Rights of data subjects

You have the right to ask us for a copy of your personal information; to correct, delete or restrict processing of your personal
information; and to obtain the personal information you provide in a structured, machine-readable format. You also have theright to object where we are processing your data for direct marketing.
In addition, you can object to the processing of your personal information in some circumstances (in particular, where we
don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you
may withdraw consent at any time. If you ask to withdraw your consent to Stanley processing your data, this will not affectany processing which has already taken place at that time. When you exercise your rights, we will ask for information tocheck your identity; this will only involve official ID documents if this is necessary given the risk posed by the data processed.
These rights may be limited, for example if fulfilling your request would reveal personal information about another person,
or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you
have unresolved concerns, you have the right to complain to a data protection authority. In the UK, this will be the Information
Commissioner. In the EEA, this will be your Data Protection Authority which you can find here.

California Privacy Addendum
Last Updated: March

22nd, 2024

To print this Policy, click [here] for a printable version of this Policy.

To view the Global Privacy Policy , click [here].
1.

Applicability

This Addendum (“California Privacy Policy”) applies to you if you are California residents (or if California Consumer
Privacy Act as amended by the California Privacy Rights Act applies).
California Privacy Policy explains your California privacy rights and describes our personal information collection practices
when the Company is acting as the business.
Especially, information on the categories of Personal information we collect and whether we sell or share personal
information is contained in Section “2. Categories of Personal information collected within the past 12 months and its and
its Source” and Section “5. Categories of Personal information Stanley Electric has sold and / or Shared within the past 12
months & Categories of Third Parties to whom Such Information was Sold and/or Shared” below.

Information on thelength of time the business intends to retain personal information is contained in Section “7. Retention Period” below, andinformation on your rights is contained in Section “8. Your Privacy Rights” below.
California Privacy Policy supplements the Stanley Electric Global Privacy Policy (“Global Privacy Policy”). The
definitions in the Global Privacy Policy apply to this California Privacy Policy.
If this California Privacy Policy and any provision in the Global Privacy Policy conflict, then this California Privacy Policy
controls for the processing of personal information of California residents pursuant to California law.

2.

Categories of Personal information collected within the past 12 months and its and its Source
We have collected the following categories of Personal Information within the past 12 months:•

Identifiers (e.g., name, mailing address, email address, phone number).

•

Personal information described in subdivision (e) of Section 1798.80. (e.g. name, mailing address, phone number,bank account information)•

Characteristics of protected classifications under California or federal law with regards to applicants for
employment by the Company (e.g. married/unmarried, national origin, signature, educational background, work
history, information related to health condition)•

Commercial information (e.g., questionnaire information and inquiry details, products for which you wish to obtain
IES information, categories of inquiry (specifications, price, inventory, request for brochure, sample, proposal, etc.)
of customers who inquire of the company).

•Internet or other electronic network activity information (e.g., cookies, ADID, IDFA and other terminal identifiers
and attribute information of customers who access the Website, IP addresses, provider information, terminal
information, web browser information, and access area information of customers who access the Website).

•

Professional or employment-related information•

Education information, defined as information that is not publicly available personally identifiable information as
defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec.1232g; 34 C.F.R. Part 99) with regards toapplicants for employment by the Company•

Inferences drawn from any of the information above (e.g. purchasing tendency inferred from Website browsing
history and level of interest inferred from information on Website the customers stay)•Sensitive personal information with regards to applicants for employment by the Company✓

personal information collected and analyzed concerning a consumer’s health✓a consumer’s social security number

For a complete list of personal information we collect from you as a consumer, please visit the Global Privacy Policy .
We gather this information directly from you when you engage with us or our services. For device and technicalinformation, we gather this directly from you when you interact with us, and from third party analytics and service
providers who assist us with providing our services, as well as from our affiliated companies.

3.

Business or Commercial Purposes

We collect the information for the business and commercial purposes set forth in Section 2 “Purpose of Use of Personal
Information” of the Global Privacy Policy, such as to fulfil or meet the purpose for which the personal information wasprovided, to audit Site usage; for internal research; detecting security incidents; and undertaking activities to verify or
maintain the quality or safety of our services, including any service or device that is owned, manufactured, manufactured
for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured,
manufactured for, or controlled by us.

4.

Categories of Personal Information we have disclosed to third parties in the past 12 months & Categories ofThird Parties to whom Such Personal Information was disclosed

Within the past 12 months, we have disclosed all categories of personal information described above withparties set forth in Section 6 “ Sharing and Disclosure of Personal Information” of the Global Privacy Policy andfor the purposes set forth in this California Privacy Annex.

5.

Categories of Personal information Stanley Electric has sold and / or Shared within the past 12 months &Categories of Third Parties to whom Such Information was Sold and/or Shared•Internet or other electronic network activity has been sold and/or shared with advertising networks, internet service
providers, data analytics providers, operating systems and platforms, and network partners. The purpose is toanalyze traffic and content within our sites and services, which helps the Company to better tailor its services to its
customers.

The Company does not knowingly collect or sell the personal information of minors under the age of 16.

6.

Whether Stanley Electric uses or discloses sensitive personal information for purposes other than those specified
in section 7027, subsection (m) of CCPA regulations.

Stanley Electric does not uses or discloses sensitive personal information for purposes other than thosespecified in section 7027, subsection (m) of CCPA regulations.

7.

Retention Period

We retain personal information for only so long as necessary for our commercial and business purposes further
described in California Privacy Policy as explained in Section 4 “Retention period for personal information” of
the Global Privacy Policy.
8.

Your Privacy Rights

If you are a California resident, you may exercise the following rights regarding your personal information, subject
to certain exceptions and limitations:•

The right to know the categories and specific pieces of personal information we collect, use, disclose, andsell about you; the categories of sources from which we collected your personal information; our purposes
for collecting or selling your personal information; the categories of your personal information that wehave either sold or disclosed for a business purpose; and the categories of third parties with which we haveshared personal information;•

The right to request that we delete the personal information we have collected from you or maintain
about you;•

The right to correct inaccurate personal information we maintain about you;•

The right to opt out of our sale(s) or sharing of your personal information; and•The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the
CCPA.

•

Shine the Light. California’s “Shine the Light” law permits California residents to request a noticedisclosing the categories of personal information about you that we have shared with third parties for theirdirect marketing purposes during the preceding calendar year, or providing a mechanism by which you can
opt out of such sharing. At this time, the Company does not share personal information with third parties
for their direct marketing purposes.

If you have a request regarding your information and would like to exercise your rights under applicable law, please contact
us through the methods provided in Section 14 “Contact Details” of the Global Privacy Policy.

(Verification Process and Required Information) Please note that we may need to request additional
information from you to verify your identity or understand the scope of your request, although you will not
be required to create an account with us to submit a request or have it fulfilled. We will require you toprovide certain personal information to countercheck with our records.
(Authorized Agent) To submit a request through an authorized agent, we may require the agent to provide proof of
authorization to submit a request on your behalf.

China Privacy Addendum
Last updated: March 22nd, 2024

1.

Applicability
This Addendum applies to customers located in Mainland China (excluding Hong Kong and Macau, Taiwan hereinafterreferred to as “China”).
In addition, when our processing of personal information of customers outside of China is subject to extraterritorial
application of the Personal Information Protection Law of China, the provisions of this Addendum shall also apply.

2.

Legal basis for processing
When we process personal information, we shall obtain the customer’s consent and process the information in accordancewith the principles of lawfulness, legitimacy, necessity and good faith, and such consent shall include consent to the Privacy
Policy and this Addendum. However, in the following circumstances, personal information may be processed without thecustomer’s consent based on the Personal Information Protection Law of China:Where it is necessary for the conclusion or performance of a contract to which the customer is a contracting party;

Where it is necessary for performing a statutory responsibility or obligation;

Where it is necessary for responding to a public health emergency, or for protecting the life, health or property of anatural person in the case of an emergency;Where the customer’s personal information is processed within a reasonable scope to carry out any news reporting,supervision by public opinion or any other activities for public interest purposes;

Where the personal information, which has already been disclosed by the customer or otherwise legally disclosed, isprocessed within a reasonable scope and in accordance with the Personal Information Protection Law of China; or

Any other circumstances as provided by law or administrative regulation.

3.

Personal information transfer outside of China
We may transfer customers’ personal information to our group companies located in countries/regions other than China to

the extent described in the Privacy Policy, and customer consent to the policy and this Addendum shall also include consent
to such transfer of personal information outside of China.
In addition, we may take necessary measures to ensure that the activities of processing the personal information provided
by customers carried out by overseas recipients meet the standards of personal information protection provided in the
Personal Information Protection Law of China.

4.

Customers’ rights
We ensure that customers can exercise the following rights with respect to their personal information, unless otherwise

provided by law or administrative regulation:

Right to be informed and make decisions

Customers have the right to be informed of and to decide on the processing of their personal information, as well as theright to restrict or deny other persons from processing it.
Right to request access and copies
Customers have the right to request access to or copies of their personal information. If such requests are made, we shallprovide access or copies in a timely manner.
Right to transfer
If any customers request to transfer their personal information to their designated personal information processors whomeet the conditions prescribed by the national cybersecurity authority, then we shall provide the transfer method.


Right to correct and complete
If any customers discover that their personal information is incorrect or incomplete, they have the right to request

personal information processors to correct or complete that information.
If any customers request any personal information processors to correct or complete their personal information, we shallconfirm the information and correct or complete it in a timely manner.
Right to delete
Customers have the right to request the Company to delete their personal information if (i) the purpose of processing has

been achieved or is unable to be achieved, or the personal information is no longer necessary for achieving such purpose;(ii) the personal information processor ceases the provision of the product or service involved, or the retention period has
expired; (iii) consent is withdrawn by the customer; (iv) the processing of personal information by the personal information
processor is in violation of any law, administrative regulation or agreement; or (v) there are any other circumstances asprovided by law or administrative regulation.


Right to request explanation of the rules of processing personal information
Customers have the right to request the Company to explain its rules of processing personal information.



Right to withdraw consent
Customers have the right to withdraw their consent to the processing of their personal information carried out based onthat consent.

(End)