DATA PROTECTION POLICY

(Effective Date: Feb. 22, 2023)

Please read this Data Protection Policy (the “Data Protection Policy”) carefully. By using the Application, installing and/or using and/or accessing the smart services through the Application, you agree to be legally bound and abide by this Data Protection Policy. The click on the "agree" locating at the bottom of this policy indicates that you have read and accepted this Data Protection Policy. By using the Application and/or the smart services, you acknowledge and accept this Data Protection Policy and consent to the collection and use of your data and information in accordance with this Data Protection Policy.

This Data Protection Policy applies to information about you that is collected by us, Qingdao Hisense Hitachi Air-conditioning Systems Co.,Ltd., as set forth herein，with detailed information as below:

Qingdao Hisense Hitachi Air-conditioning Systems Co.,Ltd.

No. 218, Qianwangang Road

Economic and Technological Development Zone

Qingdao, China

Our representative in European Union is VERDATA DATENSCHUTZ GmbH & Co KG, with detailed information as below:

VERDATA DATENSCHUTZ GmbH & Co KG

Römerstraße 12, 40476 Düsseldorf, Germany.

Email:hisensehitachi.representative@verdata.eu

We may update this Data Protection Policy from time to time in response to changing legal, technological and business developments. When we update our Data protection policy due to the above reasons, we may post the updated version on the applicable website or by providing such notice about or obtaining consent to changes as may be required by applicable law. By publishing data protection policy online and by publishing a link to the policy on the login page of the portal for managing connected Devices, we provide you with constant access to the Data Protection Policy.The Data Policy is available at https://en.connectlife.io/connectlife/privacy_policy_himit.html .

This Data Protection Policy does not apply to information that you provide directly to, or is collected by, third parties whose Smart Services you access via Internet or other application(s), system(s). You should review the applicable privacy policy and/or terms of use of any third party service providers whose Smart Services you access via Internet or other application(s), system(s).

1.IMPORTANT DEFINITIONS

“Application” means this Hi-Mit application, which can be downloaded from Android platform or iOS platform, capable of controlling Hisense VRF products and releasing relevant service.

“Device” means the air conditioning product(s) manufactured/provided by us, which is connected with the Application by you.

“Personal Data/Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sites” means Hi-Dom Cloud, Smart Touch Cloud and Hi-Mit Cloud operated, or maintained, by us or on our behalf.

“Smart Services” means all the types of services or functions typically available from the Application and Sites, offered by us, through Application and Sites to connect, administrate your Device, including turn on/off, diagnose Device failure, setting your favorite Device mode or running schedule, etc.

2.WHAT DATA WE COLLECT AND FROM WHAT SOURCES

We only collect and process your personal data that are relevant for the operation of connected Devices, Sites or which are legally requested to be collected (and processed):

· Account Registration Data. All of these data will be directly provided by you. For the registration of an account and providing support in case of any malfunctions (obligatory in case the Application/Sites will be used), you may provide:

Ø email address;

Ø password needed for using the Application/Sites (unless a supported third-party application providing this service is used);

Ø first name, last name, language, contact phone, address (street, house number, zip code, city, country);

Ø profile picture you offered to show with others.

· Device Usage Related and Diagnostic Data. These data will be collected directly or indirectly from the devices you use. This includes the data in relation to usage cycles of the Devices, about the data recorded and obtained by internal diagnostic sensors and are related to the operation and/or usage of the Devices, data regarding technical performance, data related to possible error messages.

Ø Position information of your mobile devices;

Ø Type of your air conditioner, air conditioning current;

Ø Temperature and humidity of indoor unit and temperature of outdoor unit;

Ø Power consumption of your air conditioner;

Ø Working modes of your air conditioner;

Ø Abnormal informationreporting of equipment.

· Non-Personal Data. When you use the Device, we may also collect certain information that, by itself or in combination with other such information, cannot be used to identify you individually, or contact you personally (“Non-Personal Data”).

Ø Online warranty information;

Ø Your local electricity price;

…….

· Personal Data of minors. We are committed to protecting the Personal Data of children, and recognize that parents, guardians, or other adults may purchase the Device for family use, including by minors. As such, Smart Services accessed through the Sites, Application are not intended for use by individuals under the applicable legal adult age and we will not knowingly collect Personal Data from individuals under such age for any purpose, nor will we accept registration from such individuals. In some cases, particularly where information is collected electronically, we may not be able to determine whether information was collected from children under local legal age, and we treat such information as though it were provided by an adult. If we learn that a child under local legal age has provided any Personal Data, we will use commercially reasonable efforts to delete such information. WE EXPRESSLY DISCLAIM ANY RESPONSIBILITY OR LIABILITY FOR THE USE, OR MISUSE, OF SUCH FEATURES BY CHILDREN IN VIOLATION OF THIS DATA PROTECTION POLICY.

3. HOW WE USE YOUR DATA

We may Process your Personal data for the following purposes:

· Verifying your identity and help you set up / administering user accounts;

· Connecting the Application with your chosen Devices so that you can manage your devices;

· Creating groups and inviting members, and realizing joint operation and management of devices through your groups;

· Providing you with your local weather service;

· Providing you with online warranty service and contacting you;

· Providing the Electricity Statistic and the Energy Management services to you;

· Sharing your device and your own information with the group members;

· Building the linkage between air conditioners and the room temperature;

· Controlling your device with a time scene;

· Communicating with you via any means (including via email, telephone, text message or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required;

· Engaging with you for the purposes of obtaining your views on our products and services;

· Detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law;

· Establishing, exercising and defending legal rights;

· Compliance with our legal and regulatory obligations under applicable law;

· Identifying issues with Sites, Application and Smart Services; planning improvements to Sites, Application and Smart Services; and creating new applications and Smart Services;

· We may use Non-Personal Data for our internal purposes, such as to understand aggregate usage patterns, to administer the Device, or to provide you with improved features;

· We may combine Personal Data and Non-Personal Data collected with other data in order to provide and improve services provided in connection with the Sites, Application and the Smart Services. We may also combine Personal Data we collect online with information available from other sources, including information received from our affiliates, marketing companies, or advertisers. If we combine any Non-Personal Data with Personal Data, the combined information will be treated as Personal Data under this Data Protection Policy for as long as it remains combined.

4. HOW WE SHARE AND DISCLOSE INFORMATION

We will only disclose your Personal Data to the extent that such disclosure is necessary:

· In order to maximize your rights and interests, and provide you with better service, we may share your personal data:

With our representatives in the EU and associated data processors.
With our and our affiliates staff, employees, contractors, agents, to help us provide or improve the services in connection with the Sites, Application and/or the Smart Services.
With our professional advisors in order to improve and provide targeted services.
With carefully selected third-parties, including suppliers, commercial partners, and maintenance partners as necessary to provide a service to us or to perform a function on our behalf in connection with the Sites, Application and/or the Smart Services. For any disclosure of your Personal Data by us to a carefully selected third party or to any third party referred to in this Data Protection Policy, we will comply with data protection law by ensuring that there are arrangements in place to ensure that the third party keeps your data secure, does not use your Personal Data for any purposes other than the purposes we specify and in accordance with the purposes outlined in this Data Protection Policy.
With other third-parties solely at your direction and with your express consent, and only for purposes that you request.

· For legal, security or safety purpose to share your personal data:

When required to or are permitted to do so by applicable law or regulation.
With any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security.
With any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights.
With legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.

· For the transaction in connection with other companies to share your personal data:

With third parties and their advisors in connection with a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets, financing, sale of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).

5. HOW LONG WILL WE KEEP YOUR DATA

During your use of this Application, we will continue to save your Personal Data.

If you no longer use this Application, you can click the “Delete Account” button through the Application. After you confirm the deletion of your account, we will clear your Personal Data left in this Application.

In case any other regulatory or legal requirement would oblige us to keep the data, the data will be kept for as long as legally required. In case we do no longer need the personal data, we may destroy, delete, anonymize it.

If we have the ongoing legitimate business need, we may continue to process the data related to the usage of the appliance for statistical purposes with intention to improve and upgrade our service and appliance features in the future. When you have any requirement on the data retention, please contact us.（hisense.vrf.iot@hisense.com）

6. YOUR RIGHTS AND CHOICES

According to local laws and regulations, where applicable, you may have the following rights:

· to access Personal Data we store and process ;

· in some cases, to withdraw your consent to our processing of your personal data. You have the right to withdraw your consent. In case we have legitimate reason to continue processing of your personal data we will continue to do so (in either case, we will inform you about the withdrawal procedure);

· to rectify your data in case the stored and processed personal data is not accurate or is incomplete;

· to erase your personal data, where we might continue to retain personal data if we are entitled or required to do so;

· to object to and the request that we restrict our processing of your personal data in some circumstances;

· right to contact the corresponding supervisory authority and file a complaint if you find that your personal data of our application may be leaked;

· right to obtain a copy of your personal information.

In case you would like to enforce your rights according to local laws and regulations, you can contact our support email: hisense.vrf.iot@hisense.com

6.1 YOUR CALIFORNIA PRIVACY RIGHTS

Data Subject Rights – California Residents

This portion of our Data Protection Policy advises California residents of the applicable rights as provided in the California Consumer Privacy Act (“CCPA”) and how to effectuate these rights by communicating with us. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information.

If a California resident wishes to make any of the requests described below, such as access and deletion, he or she may contact us as provided in the “Contact Us” section below. You may be able to exercise some of the below rights, such as access and deletion, by using the management features available in your account. You may authorize an agent to make such a request on your behalf. We will seek to verify your identity and your agent’s authority when we receive an individual rights request from you or on your behalf to ensure the security of your Personal Information, and may need to collect additional Personal Information to do so.

Right to Deletion of Personal Information

California residents have the right to request the deletion of Personal Information as prescribed in Section 1798.105(a) of the CCPA. We may not delete some or all Personal Information if such Personal Information is necessary for us, or our service providers or affiliates, to:

· Complete the transaction for which the Personal Information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform a contract between us and the consumer;

· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

· Debug to identify and repair errors that impair existing intended functionality;

· Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

· Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;

· Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us;

· Comply with a legal obligation, or

· Otherwise use the consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the Personal Information.

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices

You may request to receive details about how we collect, use, and share your Personal Information. Specifically, you may request to receive the specific pieces of information that we have collected about you by contacting us as provided in the “Contact Us” Section below. If you do so, we may need to collect additional Personal Information and other information, including name, email address, zip code, product purchase location, phone number (which you may choose not to provide), product model number and serial number to verify your identity. The same process applies to requests for the deletion of Personal Information described above.

You may also request to receive:

· categories of Personal Information that we have collected about you;

· categories of Personal Information that we have disclosed for a business purpose;

· categories of sources from which we collected the Personal Information;

· purposes for collecting that Personal Information, and

· categories of parties with whom we share your Personal Information.

Right to Opt-Out of Sale

You have a right to direct us not to sell your Personal Information. If you would like to exercise that right, please direct us to not to sell your Personal Information as provided in the Contact Us section below.

Right to not be Discriminated Against for Exercising CCPA Rights

We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above. If we choose to offer a product enhancement or financial incentive, that is contingent on you sharing personal information, we will ensure that the value provided to us by that collection is reasonably related to the value of the product enhancement or financial incentive.

7. LEGAL BASIS FOR PROCESSING PERSONAL DATA

This privacy agreement is prepared in accordance with GDPR (general data protection regulations). In Processing your Personal Data in connection with the purposes set out in this Data Protection Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

· Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);

· Contractual necessity: We may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us;

· Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law;

· Legitimate interests: We may Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

8. SECURITY OF THE INFORMATION WE COLLECT

We maintain physical, administrative, technical and organizational safeguards designed to maintain the confidentiality and security of your Personal Data:

· We adopt appropriate encryption measures for your personal data in the process of collection and temporary storage, in order to try our best to avoid the risk of data leakage during the use of your device;

· We encrypt your data when uploading it to the server to try to avoid data leakage and theft caused by accidents during transmission;

· We adopt appropriate encryption measures during the storage of your data, and restrict the persons who can access it in order to try to ensure the security of the data in the database;

· Meanwhile, we back up your data, even in the event of an accident, we will be able to restore your data;

· We will continue to update the existing encryption methods and measures, and regularly evaluate our data protection capabilities to try to ensure the security of your data.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through use of the Sites, Application and the Smart Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures for the Sites, Application or the Smart Services.

9. INTERNATIONAL TRANSFER OF INFORMATION

In connection with the service we provided, we may transfer your personal information to countries outside of the EEA (European Economic Area), including to countries that may not provide the same measure of data protection as your home country such as the United States and China. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Data Protection Policy, such as standard contractual clauses.

If you resident in European Economic Area, when we transfer your Personal Data from the European Economic Area to recipients located outside the European Economic Area who are not in adequate jurisdictions admitted by the European Commission, we do so on the basis of standard contractual clauses adopted by the European Commission.

Particularly, the provision of the weather service is from an America company, AccuWeather. In order to let you enjoy this service, we will provide your location information to AccuWeather. Your consent of this Data Protection Policy will be deemed as your agreement to this part.

CONTACT US

Please direct any questions you may have regarding your data protection or requests to exercise applicable rights described in this Data Protection Policy to our email at hisense.vrf.iot@hisense.com

If you are based in EEA or EEA residents, you may also contact our EU representative:

VERDATA DATENSCHUTZ GmbH & Co KG

Römerstraße 12, 40476 Düsseldorf, Germany.

Email:hisensehitachi.representative@verdata.eu