ESL Power Systems, Inc. — Website Privacy Policy

1. Introduction and Scope

ESL Power Systems, Inc. (“ESL,” “we,” “us,” or “our”) designs and manufactures custom-engineered electrical power distribution equipment for the intermodal, shore power, emergency power, entertainment, eTRU, shipyard, wayside, and industrial markets.

We respect the privacy of everyone who visits or interacts with our Site. This Privacy Policy explains:

• What personal information we collect through the Site
• Why we collect it
• How we use and share it
• The rights available to you under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”), and other applicable U.S. state privacy laws

This Policy covers personal information collected through the Site, including information submitted through:

• Quote request (RFQ) forms
• Contact forms
• Newsletter sign-ups
• The careers page
• Information collected automatically through cookies and similar technologies

This Policy does not cover:

• Information we collect from job applicants, employees, or contractors within an employment relationship, which is addressed in a separate internal HR privacy notice

By using the Site, you acknowledge the practices described in this Policy. If you do not agree with this Policy, please do not use the Site.

2. Personal Information We Collect

Depending on how you interact with the Site, we may collect the following categories of personal information, as those categories are defined under Cal. Civ. Code § 1798.140(v)(1):

2.1 Sources of Personal Information

We collect personal information from the following sources:

• Directly from you — when you submit a form, request a quote, register for a newsletter, or apply for a job
• Automatically — through cookies, web beacons, and similar technologies as you navigate the Site (see Section 4)
• From third parties — including business partners, distributors, analytics providers, advertising networks, and publicly available sources

3. How We Use Personal Information

We use personal information for the following business and commercial purposes:

• Responding to quote requests (RFQs), product questions, and technical support inquiries
• Processing and fulfilling orders, and administering warranty and after-sales service
• Operating, securing, maintaining, and improving the Site and its functionality
• Sending product updates, trade show invitations, and marketing communications (with an opt-out available in every email)
• Evaluating employment and internship applications submitted through the careers page
• Measuring Site usage and advertising effectiveness through analytics and, where applicable, advertising cookies
• Detecting, investigating, and preventing fraudulent, unauthorized, or illegal activity
• Complying with legal obligations and enforcing our agreements

Automated decision-making: We do not use automated decision-making technology to make decisions that produce legal or similarly significant effects concerning consumers (for example, decisions about employment, credit, or access to services). If this changes, we will update this Policy and provide the notice and opt-out required under the CPPA’s automated decision-making technology (ADMT) regulations, which take effect January 1, 2027.

4. Cookies, Analytics, and Advertising Technologies

Like most commercial websites, the Site uses cookies and similar tracking technologies to operate core features, remember preferences, analyze traffic, and, where enabled, support advertising.

4.1 Categories of Cookies We Use

• Strictly necessary cookies — required for the Site to function (e.g., session management, form submission, security)
• Analytics cookies — for example, Google Analytics and Google Ads, used to understand how visitors use the Site so we can improve it

4.2 Sale and Sharing of Information for Advertising Purposes

ESL does not sell personal information for money. However, the CCPA defines “sell” and “share” broadly enough that the use of certain advertising and analytics cookies — which allow third-party advertising partners to receive information about your Site activity — may be considered a “sale” or “share” of personal information even though no money changes hands. Where that is the case, California residents have the right to opt out, as described in Section 6.

4.3 Your Choices

• Cookie banner — when you first visit the Site, a cookie preference banner lets you accept or reject non-essential cookies
• Browser controls — most browsers let you block or delete cookies through their settings; note that blocking necessary cookies may affect Site functionality
• Global Privacy Control (GPC) — ESL treats a validly enabled GPC signal received from your browser or extension as a valid request to opt out of the sale/sharing of your personal information for that browser and device, consistent with CPPA regulations

5. How We Disclose Personal Information

We disclose personal information to the following categories of recipients:

We have not sold or shared the personal information of minors under 16 years of age, and, in the preceding twelve (12) months, have disclosed the categories of personal information identified in Section 2 to the categories of recipients identified above for the business purposes described in Section 3.

6. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, the CCPA gives you the following rights with respect to your personal information. These rights are not absolute and are subject to certain exceptions.

6.1 Right to Know / Access

You have the right to request that we disclose:

• The categories and specific pieces of personal information we have collected about you
• The categories of sources
• The business or commercial purpose for collecting it
• The categories of third parties with whom we share it
• Whether we have sold or shared it (and to whom)

You may request information going back twelve (12) months, or, since removal of the CCPA’s original 12-month lookback cap for information collected on or after January 1, 2022, request access to a longer period where required.

6.2 Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions (for example, information we need to complete a transaction, detect security incidents, comply with a legal obligation, or exercise free speech).

6.3 Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

6.4 Right to Opt Out of Sale or Sharing

You have the right to opt out of the “sale” or “sharing” of your personal information. You may exercise this right by adjusting the Site’s cookie preference settings, or by enabling a Global Privacy Control signal in your browser.

6.5 Right to Limit Use of Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes beyond those necessary to provide the goods or services you request, so no additional action is required to limit our use of it. If this changes, we will provide a “Limit the Use of My Sensitive Personal Information” mechanism.

6.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights, including by denying goods or services, charging different prices, or providing a different level or quality of service.

6.7 Right to Appeal (Automated Decision-Making)

As described in Section 3, ESL does not currently use automated decision-making technology in a way that triggers a right to appeal. Should that change, we will provide a right to appeal consistent with CPPA regulations effective January 1, 2027.

6.8 How to Submit a Request

You, or an authorized agent acting on your behalf, may submit a request to know, delete, or correct by:

We will verify your identity before responding, generally by matching the information you provide against information we already have on file. We will confirm receipt of your request within ten (10) business days and will respond substantively within forty-five (45) days, with one 45-day extension available where reasonably necessary (with notice to you). There is no fee to submit or have us process a verifiable consumer request.

6.9 Authorized Agents

You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of authorization and may still require you to verify your own identity directly with us.

6.10 Shine the Light

Separately from the CCPA, California Civil Code § 1798.83 (“Shine the Light”) permits California residents to request, once per calendar year, information about any personal information we shared with third parties for their direct marketing purposes in the preceding calendar year. ESL does not share personal information with third parties for their own direct marketing purposes.

7. Privacy Rights for Residents of Other U.S. States

If you reside in a state with a comprehensive consumer privacy law — including Colorado, Connecticut, Utah, Virginia, and others as those laws take effect — you may have rights similar to those described in Section 6, such as the right to access, correct, delete, and obtain a portable copy of your personal information, and the right to opt out of targeted advertising, the sale of personal information, or certain profiling.

You may exercise these rights by contacting us at webmaster@eslpwr.com, and we will respond consistent with the requirements of the applicable law.

8. Children’s Privacy

The Site is directed at business and commercial audiences and is not intended for children. We do not knowingly collect personal information from children under 16 years of age. If we learn that we have inadvertently collected personal information from a child under 16, we will delete it promptly.

9. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including to satisfy contractual, tax, warranty, accounting, and legal recordkeeping requirements, after which it is securely deleted or de-identified.

10. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Third-Party Links

The Site may contain links to third-party websites, including distributor, supplier, and industry-association sites. We are not responsible for the privacy practices or content of those third-party sites, and we encourage you to review their privacy policies.

12. Where We Operate

ESL Power Systems, Inc. is headquartered in Corona, California, and the Site is hosted and operated in the United States. If you access the Site from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those of your jurisdiction.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or applicable law. We will post the revised Policy on this page with an updated “Last Updated” date, and, for material changes, will provide additional notice as required by law.

14. Contact Us

Questions about this Policy or requests regarding your personal information may be directed to: