Hitachi Smart Life Privacy Policy

Effective Date: Effective immediately

Updated: June 18, 2024

Hitachi Building Technology(Guangzhou) Co.,Ltd and subsidiaries(“we”, “us”, “our”, “Hitachi Building Technology(Guangzhou) Co.,Ltd”) are committedto protecting your privacy. This Privacy Policy (“Policy”) describes our practicesin connection with information privacy on Personal Data we process through yourindividual use of the following services, products, and related mobile applications(collectively, the “Products”):

Hitachi Smart Life Mobile Application

Before you use our Products, please carefully read throughthis Policy and understand our purposes and practices of collection, processingof your Personal Data, including how we use, store, share and transfer PersonalData. In the Policy you will also find ways to execute your rights of access, update,delete or protect your Personal Data.

When you accept this Policy when you register with yourPersonal Data, or if you start to use our Products and does not expressly objectto the contents of this Policy, we will consider that you fully understand and agreewith this Policy. If you have any question r regarding this Policy, please do nothesitate to contact us via:

Contact number: 020-36115010

For other branded mobile applications powered by HitachiBuilding Technology(Guangzhou) Co.,Ltd, our Clients control all the Personal Datacollected through our Products. We collect the information under the direction ofour Clients and the processing of such information shall be limited to the purposeof providing the service for which our Clients has engaged us. If you are a customerof one of our Clients and would no longer like to be contacted by one of our Clientsthat use our service, please contact the Client that you interact with directly.

Definition

In this Policy, Personal Data means information generated,collected, recorded and/or stored, electronically or otherwise, that can be usedto identify an individual or reflect the activity of an individual, either fromthat information alone, or from that information and other information we have accessto about that individual.

Personal Sensitive Data includes personal biometric information,communication records and contents, health information, transaction information,and precise location information. When we collect Personal Sensitive Data from you,we will generate an explicit notification for your consent before we collectionpersonal sensitive data about you.

Smart Devices refers to those computing devices producedor manufactured by hardware manufacturers, with human-machine interface and theability to transmit data that connect wirelessly to a network, including: smarthome appliances, smart wearable devices, smart air cleaning devices, etc.

Apps refers to those mobile applications developed byHitachi Building Technology(Guangzhou) Co.,Ltd that provide end users remote controlto Smart Devices and with the ability to connect to the supplier IoT Platform.

What Personal Data do we collect

In order to provide our services to you, we will ask youto provide necessary Personal Data that is required to provide those services. Ifyou do not provide your Personal Data, we may not be able to provide you with ourproducts or services.

1.Information You Voluntarily Provide Us

· Registered Account Data: When youregister an account with us, we may collect your name and contact details, suchas your email address, phone number, user name, and login credentials. During yourinteraction with our Products, we may further collect your nickname, profile picture,country code, language preference or time zone information into your account.

Ifyou authorize login to the Products with a third party account, we will obtain fromsuch third party your account information (such as portrait, nickname, region, gender,etc.) which may be bound with your Hitachi Building Technology(Guangzhou) Co.,Ltdaccount for quick login. We will ensure compliance with applicable data protectionlaws and regulations, as well as agreements, policies or documentations agreed withsuch third party regarding sharing personal information, in processing your PersonalData.

· Non-registered Account: If you donot want to provide your account data when you start to use any of the Services,you may use the App without logging in or creating an account, namely the “Try Now”mode, and you may still use certain Services, such as searching and browsing anyfeatures on the App by creating a guest ID. When you are using the "Try Now"mode, we will not collect Personal Data related to your account. Collection anduse of the Personal Data collected here will be limited to: the time of enteringthe App, operating system of your mobile phone, and the purposes you have authorizedin using the additional functions of the App and/or the Smart Devices. For instance,if you enable the location setting in the "Try Now" mode, the locationdata will be uploaded for supporting the function. Once you exit from the "TryNow" mode, we will remove your data instantly and permanently.

However,if the Services you request or purchase are based on your account, please go tothe registration/login page for guidance.

· Feedback: When using feedback andsuggestion features in our Products, we will collect your email address, mobilephone number and your feedback content to address your problems and solve devicefailures on a timely basis.

Information based on additional functions:

In order to offer you with more convenient and higher-qualityServices with optimized user experiences, we may collect and use certain informationif you consent to use additional functions in the App. Please note, if you do notprovide such information, you may continue to use basic Services of the App andconnected Smart Devices, but certain features based on these additional functionsmay not be available. These additional functions may include:

1)Additionalfunctions based on location information:

When you enable the location-based functions through permissionsettings on your mobile device, we will collect and process your location informationto enable these functions, such as pairing with your Smart Devices. Also, we maycollect information about your: a) real-time and precise location, for instancewhen you choose to use the automation scenarios for controlling your Smart Devices,or b) non-precise geo-location when you use certain Smart Devices or the Services,such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature,your location information will be generated and shared with Google Maps services.Please note that Google has corresponding data protection measures, which you mayrefer to Google’s Data Processing and Security Terms for more details.

You may disable the collection and use of your locationinformation by changing your mobile device settings ("My - Setting - PrivacyRight Setting - Switch on/off Location Information"), upon which we will ceaseto collect and use your location information.

2)Additionalservices based on camera:

You may use the camera to scan the code by turning onthe camera permission to pair with a Smart Device, take video, etc. Please be awarethat even if you have agreed to enable the camera permission, we will only obtaininformation when you actively use the camera for scanning codes, video recording,etc.

You may opt-out the using of camera permission: "My- Setting - Privacy Right Setting - Switch on/off Camera".

3)Additionalservices for accessing and uploading pictures/videos based on photo albums (picturelibrary/video library):

You can use this function to upload your photos/pictures/videosafter turning on the photo album permission, so as to realize functions such aschanging the avatar, reporting device usage problems by providing photo proofs,etc.. When you use the photos and other functions, we will not recognize this information;but when you report a device usage problem, we may use the photos/pictures you uploadto locate your problem.

You may opt-out the using of photo album permission: "My- Setting - Privacy Right Setting - Switch on/off Photo Album".

4)Additionalservices related to microphone-based service:

You can use the microphone to send voice information afterturning on the microphone permission, such as shooting videos, waking up the voiceassistant, etc. For these functions, we will collect your voice information to recognizeyour command. Please be aware that even if you have agreed to enable the microphonepermission, we will only obtain voice information through the microphone when youvoluntarily activate the microphone in the App.

You may opt-out the using of microphone permission: "My- Setting - Privacy Right Setting - Switch on/off Microphone".

5)Additionalservices based on storage permission(Android):

The purpose is to ensure the stable operation of the Appby utilizing the storage permission. After you give or indicate the permission toread/write your mobile device’s storage, we will access pictures, files, crash loginformation and other necessary information from your mobile device’s storage toprovide you with functions, such as information publications, or record the crashlog information locally.

You may opt-out the using of storage permission: "My- Setting - Privacy Right Setting - Switch on/off Storage".

6)Additionalservices based on Notification permission:

The reason why we ask you for the permission is to sendyou notifications about using the Smart Devices or Services, especially if you havepurchased security services and you require an alert or message so that you cancapture the real-time status.

You may opt-out the using of App notifications: "My- Message Center - Setting - Switch on/off Notifications".

7) Additionalservices based on Alert Window permission：

You may choose to bind a camera in the App and requirethe App to display the real-time image of the camera in a separate window.

You may opt-out the using of alert window information:"My - Setting - Privacy Right Setting - Switch on/off Alert Window".

8) Additionalservices based on Bluetooth permission:

You can enable Bluetooth functions after turning on thepermission, including controlling the Smart Devices, acquiring status of, discoveringand configuring Smart Devices. In these functions, we will communicate with SmartDevices via Bluetooth. Please be aware that even if you have agreed to enable theBluetooth permission, we will only use Bluetooth for communication in these scenarios:display device status on the home page and Smart Device panel; perform device controlon the home page and Smart Device panel; discovering Smart Devices on the home pageand the add device page, Smart Device distribution network.

You may opt-out the using of Bluetooth via "My -Settings - Privacy Setting - Disable/Enable Bluetooth permission".

9）Additional services based on HomeKitpermission (iOS):

You can enable related functions after enabling HomeKitpermissions, including discovering Smart Devices, enabling Smart Device networkconfiguration, controlling Smart Devices, and checking device status. Among thesefunctions, we will process data with the "Home“ App that comes with the iOSsystem through HomeKit. Please be aware that even if you have agreed to enable theHomeKit permission, we will only use it in these scenarios: on the home page, todiscover HomeKit devices, HomeKit device network configuration; in "Settings- HomeKit" for discovering HomeKit devices, HomeKit device network configuration.

You may opt-out the using of HomeKit permission via "My- Settings - Privacy Settings-Turn off/on HomeKit permission".

10）Additional services based on HealthKit(iOS):

You can proactively enable related functions after enablingHealthKit permission, including statistics on weight, height, running, and swimming.In these functions, we will exchange data with the health-related functionalitiesthat comes with the iOS system through HealthKit. Please be aware that even if youhave agreed to enable HealthKit permission, we will only use them in these scenarios:when you use the health-related Smart Device, such as body fat scales, bracelets,watch and consent to use the HealthKit, the data reported by the Smart Device willbe transferred to HealthKit.

You may opt-out the using of HealthKit permission via"My - Settings - Privacy Settings - Turn off/on HealthKit permission".

Please note that if you turn on any permission, you authorizeus to collect and use relevant personal information to provide you with correspondingServices. Once you turn off any permission, we will take it as canceling the authorization,and we will no longer continue to collect Personal Data based on the correspondingpermissions, and the related functions may be terminated. However, your decisionto turn off the permission will not affect the previous collection and use of informationbased on your authorization.

2.Information We Collect Automatically

· MobileDevice Information: When you interact with our Services,in order to provide and maintain the normal operation of our Services, to improveand optimize our Services, and to protect your account security as well, we automaticallycollect mobile device information, such as mobile device model number, IP address,wireless connection information, the type and version of the operating system, applicationversion number, push notification identifier, log files, and mobile network information.Meanwhile, we will collect your software version number. In order to ensure thesecurity of the operating environment or to provide services, we will collect informationabout the installed mobile applications and other software you use.

· UsageData: During your interaction with our websites and Services,we automatically collect usage data relating to visits, clicks, downloads, messagessent/received, and other usage of our websites and Services.

· LogInformation: When you use the App, in order to improve your userexperience, the system and exception log may be uploaded, including your IP address,language preference setting, operating system version, date or time of access, sothat we can facilitate and accurately identify problems and help you solve themin timely manner.

Please note that we cannot identify a specificindividual by using device information or log information alone. However, if thesetypes of non-personal information, combined with other information, may be usedto identify a specific individual, such information will be treated as PersonalData. Unless we have obtained your consent or unless otherwise provided by dataprotection laws and regulations, we will aggregate or desensitize such information..

3.Smart Devices Related Information:

· BasicInformation of Smart Devices: When you connect your Smart Deviceswith the Services, we may collect basic information about your Smart Devices suchas device name, device ID, online status, activation time, firmware version, andupgrade information.

· Informationcollected during the process of connecting to a Smart Device:Based on the type of Smart Device you need to connect, the basic information collectedincludes: Wi-Fi information, device MAC address, etc.

· InformationReported by Smart Devices: Depending on the different SmartDevices you elect to connect with our Products or Services, we may collect differentinformation reported by your Smart Devices. For example, Please enter information about the smart device report.

Purposes and legal basis for processing Personal Data

The purpose for which we may process information aboutyou are as follows:

· ProvideYou with Our Services: We process your account data, mobiledevice information, usage data, location information, and Smart Device related informationto provide you with the Services that you have requested. The legal basis for this processingis to perform our contract with you according to our user agreement of user.

· ImproveOur Services: We process your mobile device information, usage data,location information and Smart Device related information to ensure the functionsand safety of the Services, to develop and improve the Services, to analyze theefficiency of our operations and to prevent and trace fraudulent or inappropriateusage. The legal basis for this processing is to perform our contract with you accordingto our user agreement of user.

· Non-marketingCommunication: We process your Personal Data to send you important informationregarding the Services, changes to our terms, conditions, and policies and/or otheradministrative information. At the same time, we will also send you notificationsrelated to the services you have purchased, such as alert services. You can checkthe “App Notification” in the App ("Me &rt; Message Center &rt; Setting &rt;Notification Setting”) to manage these communications. When you decide not to enablethe Notifications function, we will no longer process your information for suchpurpose. The legal basis for this processing is to perform our contract with youaccording to our user agreement of user.

· DataAnalysis: In order to analyze the usage of the products we provideand improve your user experience, we will analyze the data you provide us, a) weneed to check your problems when you encounter any malfunctions during the usageof the product, under such circumstance, you may not able to opt-out because itis highly relate to your functionalities and quality of using our product and service,and b) analyze data about how you interface with the product or under particularscenarios so that you can better enjoy the convenience brought by our Services,under such circumstance, if you do not agree to data analysis of your data, youcan enter the privacy settings of App (“My &rt; Settings &rt; Privacy Settings &rt;Data Analysis”) to opt-out your selection. The legal basis for such processing isbased on your consent.

· MarketingCommunication and Personalization: We may processyour account data, usage data, device information to personalize product designand to provide you with services tailored for you, such as recommending and displayinginformation and advertisements regarding products suited to you, and to invite youto participate in surveys relating to your use of the Services. If you do not allowus to process your Personal Data for personalization, you may opt out when you enterthe App, or by changing your preferences in “Privacy Settings” (“Me&rt; Settings&rt; Privacy Settings &rt; Personalization”) in the App. The legal basis for thisprocessing is your consent.

· LegalCompliance. We disclose information if we are legally required todo so, or if we have a good faith belief that such use is reasonably necessary to:

· comply with a legal obligation, processor request;

· enforce our User Agreement and otheragreements, policies, and standards, including investigation of any potential violationthereof;

· protect the rights, property or safetyof us, our users, a third party or the public as required or permitted by law; or

· detect, prevent or otherwise addresssecurity, fraud or technical issues.

If there is any change in the purposes for processingyour personal data, we will inform such change to you via email and/or a prominentnotice on our website of such changes of purposes, and choices you may have regardingyour Personal Data.

Who do we Share Personal Data with?

At Hitachi Building Technology(Guangzhou) Co.,Ltd, weonly share Personal Data in ways that we tell you about. We may share your PersonalData with the following recipients:

· To our third-party service providerswho perform certain business-related functions for us, such as website hosting,data analysis, payment and credit card processing, infrastructure provision, ITservices, customer support service, e-mail delivery services, and other similarservices to enable them to provide services to us.

· To our customers and other businesspartners who provide you, directly or indirectly, with your Smart Devices, and/ornetworks and systems through which you access and use our websites and Services.

· To subsidiaries or affiliates withinour corporate family for purpose of regular business activities based on our instructionsand in compliance with applicable law, this Policy and other appropriate confidentialityand security measures.

· To an affiliate or other third partyin the event of any reorganization, merger, sale, joint venture, assignment, transferor other disposition of all or any portion of our business, assets or stock (includingwithout limitation in connection with any bankruptcy or similar proceedings). Insuch an event, you will be notified via email and/or a prominent notice on our websiteof any change in ownership, and choices you may have regarding your Personal Data.

· As we believe in good faith that accessto, or use, preservation, or disclosure of the information is reasonably necessaryor appropriate to:

(a)Complywith applicable law, regulation, legal process, or lawful governmental request;

(b)Enforceour User Agreement and other agreements, policies, and standards, including investigationof any potential violation thereof;

(c)Protect our operation and business systems;

(d)Protectthe rights, property or safety of us, our users, a third party or the public asrequired or permitted by law; or

(e)Performrisk management, screening and checks for unlawful, fraudulent, deceptive or maliciousactivities.

Except for the third parties mentioned above, we onlydisclose your Personal Data to other third parties with your consent.

International Transfer of Information Collected

Hitachi Building Technology(Guangzhou) Co.,Ltd will complywith applicable data localization requirements in corresponding jurisdictions withrespect to storage of data. To facilitate our operation, we may transfer, storeand process your Personal Data in jurisdictions other than where you live. Lawsin these countries may differ from the laws applicable to your country of residence.When we do so, we will ensure that an adequate level of protection is provided forthe information by using one or more of the following approaches:

· Agreement on the basis of approvedEU standard contractual clauses per GDPR Art. 46. For more information, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

If you would like further detail on the safeguards wehave in place, you can contact us directly as described in this Privacy Policy.

Your Rights Relating to Your Personal Data

We respect your rights and control over your PersonalData. You may exercise any of the following rights:

· • Through "My-Setting-Accountand Security" or "My-FAQ & Feedback" in our application;

· • And you can contact us throughthe following information:

Contact number: 020-36115010

You do nothave to pay a fee and we will aim to respond you within 30 days. If you decide toemail us, in your request, please make clear what information you would like tohave changed, whether you would like to have your Personal Data deleted from ourdatabase or otherwise let us know what limitations you would like to put on ouruse of your Personal Data. Please note that we may ask you to verify your identitybefore taking further action on your request, for security purposes.

You may:

· Request access to the Personal Datathat we process about you: "My-Setting-Privacy Settings-Personal Data Export";

· Request that we correct inaccurateor incomplete Personal Data about you: 1) Modify your account number (email addressor phone number): "My-Setting-Account and Security-Change your Account";2) Modify the nickname and/or time zone: "My-Personal Information";

· Request deletion of Personal Dataabout you: "My-Setting-Account and Security-Delete Account", when youconfirm the deletion of your account, your Personal Data will be deleted accordingly.

· Request restrictions, temporarilyor permanently, on our processing of some or all Personal Data about you: Pleasesend over your request through "My-FAQ & Feedback".

· Request transfer of Personal Datato you or a third party where we process the data based on your consent or a contractwith you, and where our processing is automated: Please send over your request through"My-FAQ & Feedback".

· Opt-out or object to our use of PersonalData about you where our use is based on your consent or our legitimate interests.

Withdrawal of consent Confirm the following details: Wewill exercise your privacy right to withdraw consent through the following approaches:

1)For privacy permissions acquired through device systemsettings, your consent can be withdrawn by changing device permissions, includinglocation, camera, photo album (picture library/video library), microphone, Bluetoothsettings, notification settings and other related functions;

2)You may opt-out the non-marketing communication through“Me &rt; Message Center &rt; Notification Settings” to manage your selection;

3)You may opt-out the data analysis features through “Me&rt; Settings &rt; Privacy Settings”;

4)You may opt-out the Personalization feature through“Me &rt; Settings &rt; Privacy Settings &rt; Personalization”;

5)Unbind the Smart Device through the App, and the informationrelated to the Smart Device will not be collected;

6)By using product with the "Try Now" mode,and not enable certain location setting for particular smart scene, we will notcollect any Personal Data about you;

7)If you previously agreed to associate App account witha third-party service, such as a health platform, please unbind it on the third-partyplatform.

When you withdraw your consent or authorization, we maynot be able to continue to provide you with certain products or services correspondingly.However, your withdrawal of your consent or authorization will not affect the processingof personal information based on your consent before the withdrawal.

About Deletionof the Account: You can find the Delete function through “Me &rt; Settings &rt;Account and Security &rt; Delete Account” (Deactivate Account）

Security Measures

We use commercially reasonable physical, administrative,and technical safeguards to preserve the integrity and security of your PersonalData. Hitachi Building Technology(Guangzhou) Co.,Ltd provides various security strategiesto effectively ensure data security of user and device. As for device access, HitachiBuilding Technology(Guangzhou) Co.,Ltd proprietary algorithms are employed to ensuredata isolation, access authentication, applying for authorization. As for data communication,communication using security algorithms and transmission encryption protocols andcommercial level information encryption transmission based on dynamic keys are supported.As for data processing, strict data filtering and validation and complete data auditare applied. As for data storage, all confidential information of users will besafely encrypted for storage. If you have reason to believe that your interactionwith us is no longer secure (for example, if you feel that the security of any accountyou might have with us has been compromised), you could immediately notify us ofthe problem by emailing.

Data Retention

We process your Personal Data for the minimum period necessaryfor the purposes set out in this Policy, unless there is a specific legal requirementfor us to keep the data for a longer retention period. We determine the appropriateretention period based on the amount, nature, and sensitivity of your Personal Data,and after the retention period ends, we will destruct your Personal Data.

· For as long as you require us to fulfillthe products and services you request from us as defined in the user agreement ofuse;

· Personal Data will no longer be retainedwhen you request to remove your Personal Data, we will accordingly complete thetask.

When we are unable to do so for technical reasons, wewill ensure that appropriate measures are put in place to prevent any further suchuse of your Personal Data.

Children’s Privacy

Protecting the privacy of young children is especiallyimportant to us. The Services are not directed to individuals under the age of thirteen(13) (or such other age provided by applicable law in your country/region of residence),and we request that these individuals do not provide any Personal Data to us. Wedo not knowingly collect Personal Data from any child unless we first obtain permissionfrom that child’s parent or legal guardian. If we become aware that we have collectedPersonal Data from any child without permission from that child’s parent or legalguardian, we will take steps to remove that information..

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes toour information practices. If we make any material changes we will notify you byemail (send to the e-mail address specified in your account) or by means of a noticein the mobile applications prior to the change becoming effective. We encourageyou to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our practices or thisPrivacy Policy, please contact us as follows:

Hitachi Building Technology(Guangzhou) Co.,Ltd

Service Email：jiangjiawei@hitachi-helc.com

Postal Mailing Address: No. 2, Nanxiang 3rd Road,Science City, Guangzhou Hi-Tech Industrial Development Zone, Guangdong Province