Rheem Manufacturing Company (Singapore) Pte Ltd Mobile Privacy Policy
Effective Date: 01 Nov 2020
Updated: 20 Oct 2020
Rheem Manufacturing Company (Singapore) Pte Ltd and its affiliate and subsidiaries (jointly referred to as
“we”, “us”, “our” or “Rheem”) are committed to protecting your privacy. This Privacy Policy (“Policy”)
describes our practices in connection with information privacy on Personal Data we process through your
individual use of the following services, products, and related mobile applications (collectively, the
“Products”) on your Smart Devices (defined below):
• Rheem Mobile Application
• Rheem EHG & EHG S WIFI enabled water-heater products
In this Privacy Policy,
“Personal Data” means information that can be used to identify an individual, either from that
information alone, or from that information and other information we have access to about that
individual.
“Smart Devices” refers to those non-standard computing devices produced or manufactured by
hardware manufacturers, with human-machine interface and the ability to transmit data that connect
wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning
devices, etc.
“App” refers to those mobile applications developed by Rheem that provide end users with the ability
to remotely control their Smart Devices and with the ability to connect to Rheem’s third party IoT
Platform supplier.
What Personal Data do we Collect?
In order to provide our services to you, we will ask you to provide necessary Personal Data that is required
to provide those services. If you do not provide your Personal Data, we may not be able to provide you with
our products or services.
1. Information You Voluntarily Provide Us
• Account or Profile Data: When you register an account with us, we may collect your name and
contact details, such as your email address, phone number, username, and login credentials.
During your interaction with our Products, we may collect further information, including but not
limited to, your nickname, profile picture, country code, language preference or time zone
information into your account.
• Feedback: When using feedback and suggestion features in our Products, we will collect your
email address, mobile phone number and your feedback content to address your problems and
solve device failures on a timely basis.
2. Information We Collect Automatically
• Device Information: When you interact with our Product using a Smart Device, we automatically
collect device information, such as the MAC address of your devices, IP address, wireless
connection information, operating system type and version, application version number, push
notification identifier, log files, and mobile network information. • Usage Data: During your interaction with our App, we automatically collect usage data relating to
visits, clicks, downloads, messages sent/received, and other usage of our App.
• Log Information: When you use our App, the system and exception log may be uploaded.
• Location Information: We may collect information about your real-time precise or non-precise
geo-location when you use our App.
3. Smart Devices Related Information:
• Basic Information of Smart Devices: When you connect your Smart Devices with our App, we may
collect basic information about your Smart Devices such as device name, device ID, online status,
activation time, firmware version, and upgrade information.
• Information Reported by Smart Devices: Depending on the different Smart Devices you choose to
connect with our App, we may collect different information reported by your Smart Devices.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you are as follows:
• Provide You Services: We process your account and profile data, device information, usage data,
location information, and Smart Device related information to provide you with our Products and
Services that you have requested or purchased. The legal basis for this processing is to perform
our contract with you according to our Terms of Use.
• Improve Our Services: We process your device information, usage data, location information and
Smart Device related information to ensure the functions and safety of our Products, to develop and
improve our Products and Services, to analyze the efficiency of our operations, and to prevent and
trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our
contract with you according to our Terms of Use.
• Non-marketing Communication: We process your Personal Data to send you important
information regarding the Services, changes to our terms, conditions, and policies and/or other
administrative information. Because this information may be important, you may not opt-out of
receiving such communications. The legal basis for this processing is to perform our contract with
you according to our Terms of Use.
• Marketing Communication: We may process your Personal Data to provide marketing and
promotional materials to you on our Products and Services. If we do so, each communication we
send you will contain instructions permitting you to opt-out of receiving future communications of
that nature. The legal basis for this processing is your consent. Additionally, if you consent to
participate in our lottery, contest or other promotions, we may use your Personal Data to manage
such activities.
• Personalization: We may process your account and profile data, usage data, device information to
personalize product design and to provide you with services tailored for you, such as
recommending and displaying information and advertisements regarding products suited to you,
and to invite you to participate in surveys relating to your use of our Products. The legal basis for
this processing is your consent.
• Legal Compliance: We may process your Personal Data as we believe to be necessary or
appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c)
to respond to requests from public and government authorities (d) to enforce our terms and
conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy,
safety or property, and/or that of other users, including you; and (g) to allow us to pursue available
remedies or limit the damages that we may sustain.
Who do we share Personal Data with?
At Rheem, we only share Personal Data on an “as-required” basis and in ways that we tell you about. We
may share your Personal Data with the following recipients:
• To our third-party service providers who perform certain business-related functions for us, such as
website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable
them to provide services to us.
• To our customers and other business partners who provide you, directly or indirectly, with your
Smart Devices, and/or networks and systems through which you access and use our Sites and
Services.
• To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture,
assignment, transfer or other disposition of all or any portion of our business, assets or stock
(including without limitation in connection with any bankruptcy or similar proceedings). In such an
event, you will be notified via email and/or a prominent notice on our website of any change in
ownership, incompatible new uses of your Personal Data, and choices you may have regarding
your Personal Data.
• As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b)
to comply with legal process; (c) to respond to requests from public and government authorities,
including public and government authorities outside your country of residence; (d) to enforce our
terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights,
privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue
available remedies or limit the damages that we may sustain.
• To subsidiaries or affiliates within our corporate family, to carry out regular business activities.
Other than the third parties described above, we will seek your consent to disclose your Personal Data
to any other parties.
International Transfer of Information Collected
To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than
where you live. Laws in these countries may differ from the laws applicable to your country of residence.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal Data. You may exercise any of the following rights
via the “Profile – Personal Center” in our Products:
• Request access to the Personal Data that we process about you;
• Request that we correct inaccurate or incomplete Personal Data about you;
• Request deletion of Personal Data about you;
• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data
about you;
• Request transfer of Personal Data to you or a third party where we process the data based on your
consent or a contract with you, and where our processing is automated; and
• Opt-out or object to our use of Personal Data about you where our use is based on your consent
or our legitimate interests.
You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us,
in your request, please make clear what information you would like to have changed, whether you
would like to have your Personal Data deleted from our database or otherwise let us know what
limitations you would like to put on our use of your Personal Data. Please note that for security and
administration purposes, we may ask you to verify your identity and fill in the necessary forms before
taking further action on your request.
Please also take note that where restrictions are placed on our use of your Personal Data, it may result
in an inability on our part to process the Personal Data for the purposes of providing you with certain
services. In such an instance, we will inform you of this before proceeding with your request.Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the
integrity and security of your Personal Data. Rheem works with third party service providers which provide
various security strategies to effectively ensure data security of user and device. As for device access,
algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for
data communication, communication using security algorithms and transmission encryption protocols and
commercial level information encryption transmission based on dynamic keys are supported. As for data
processing, strict data filtering and validation and complete data audit are applied. As for data storage, all
confidential information of users will be safely encrypted for storage. If you have reason to believe that
your interaction with us is no longer secure (for example, if you feel that the security of any account you
might have with us has been compromised), you could immediately notify us of the problem by emailing
compliancemanager@rheem.com
Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy
Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We
determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal
Data, and after the retention period ends, we will destroy your Personal Data. When we are unable to do
so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further
such use of your Personal Data.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any material
changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a
notice in the App prior to the change becoming effective. We strongly encourage you to periodically review
this page for the latest information on our privacy practices.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us as follows:
Rheem Manufacturing Company (Singapore) Pte Ltd
Postal Mailing Address: 8 Pandan Crescent #02-02 Singapore 128464
Email: compliancemanager@rheem.com