Rinnai Australia Pty Ltd (ABN 74 005 138 769) (the Company) offers a mobile application to

allow you to control, monitor and operate selected Company products (App) subject to the

products and the mobile or other device being connected to the same WiFi network and are

operating within working range. We are committed to protecting your privacy, and want you to

be familiar with how we collect, use and disclose information in connection with the App.

This Privacy Policy describes our practices in connection with information that we collect

through the App and the embedded software installed in the Company’s products, as well as

through the services and content provided by the Company in relation to the App and software

(collectively, including the App, the Services). By providing Personal Information to us or using

the Services, you agree to this Privacy Policy.

Personal Information

The Company may collect the following information:

For the purpose of this Privacy Policy, Personal Information is information that identifies you

as an individual or relates to an identifiable person, including your name, email address,

residential address and telephone number.

If you submit any Personal Information relating to other people to us or to our service providers

in connection with the Services, you represent that you have the authority to do so and permit

us to use the information in accordance with this Privacy Policy.

The Company may collect Personal Information the following way(s):

The Company and our service providers may collect Personal Information through the

Services, such as when you create an account, register your product(s) and or sign up for a

newsletter.

The Company may use the Personal Information collected for the following purpose(s):

(1) To enable you to use the Services and provide you with related customer service;

(2) To provide you with updates to the App;

(3) To respond to your inquiries and fulfill your requests, such as to create an account or

send you newsletters;

(4) To provide maintenance support for your product(s);

(5) To send notices and administrative information to you, such as information regarding

the Services and changes to our terms, conditions and policies; and

(6) For our business purposes, such as data analysis, sales analysis, audits, fraud

monitoring and prevention, addressing issues with our Services, developing new

products, enhancing, improving or modifying our Services, identifying usage trends,

determining the effectiveness of our promotional campaigns and operating and

expanding our business activities.

The Company may disclose Personal Information in the following instances:

(1) To our parent company, Rinnai Japan, for the purposes described in this Privacy

Policy. The Company will remain the party responsible for the management of the

jointly-used Personal Information;

(2) To our third-party service providers who provide services such as app design,

development, interoperability and maintenance; data hosting; data analysis;

information technology and related infrastructure provision; customer service; email

delivery; auditing and other services; and

(3) To a 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 in connection with any bankruptcy or similar proceedings).

Other Uses and Disclosures:

The Company may also use and disclose your Personal Information as we believe to be

necessary or appropriate: (a) under applicable law, which may include laws outside your

country of residence; (b) to respond to requests from courts, law enforcement agencies,

regulatory agencies, and other public and government authorities, which may include such

authorities outside your country of residence; (c) to enforce our terms and conditions; and (d)

to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

Other Information

The Company may also collect:

For the purpose of this Privacy Policy Other Information is any information that does not

reveal your specific identity or does not directly relate to an identifiable individual, such as

device information, App usage data, product usage data, IP address, physical location of your

product, demographic information and other information provided by you, aggregated

information.

If the Company is required to treat Other Information as Personal Information under applicable

law, then we may use it for the purposes for which we use and disclose Personal Information

as detailed in this Privacy Policy.

The Company may collect Other Information the following way(s):

We and our third party service providers may collect Other Information in a variety of ways,

including:

Through your device: Certain information is collected through your device or software, such

as your Media Access Control (MAC) address, screen resolution, operating system name and

version, device manufacturer and model, language, software type and version and the name

and version of the Services (such as the App) you are using. We use this information to ensure

that the Services function properly;

(1) Through your use of the App: When you download and use the App, we and our

service providers may track and collect usage data, such as the date and time the App

on your device accesses our servers and what information and files have been

downloaded to the App based on your device number;

(2) Through your use of your product(s): When you use the Services, we and our

service providers may collect information about your product(s), such as its model and

serial number. In addition, we may collect usage data, such as when and for how long

the product is on or off, operating mode, operating conditions and operating

parameters;

(3) IP Address: Your IP address is a number that is automatically assigned to the device

that you are using by your Internet Service Provider. An IP address may be identified

and logged automatically in our server log files whenever a user accesses the

Services, along with the time of the visit and the page(s) that were visited. Collecting

IP addresses is standard practice and is done automatically by many websites,

applications and other services. We use IP addresses for purposes such as calculating

usage levels, diagnosing server problems and administering the Services. We may

also derive your approximate location from your IP address;

(4) Physical Location: We may collect the physical location of your product(s) by, for

example, using WiFi signals. We may use the information to improve our products and

services and provide you with personalized location-based services and content;

(5) From you: Information such as your company name or country of residence is

collected when you voluntarily provide it; and

(6) By aggregating information: Aggregated Personal Information does not personally

identify you or any other user of the Services (for example, we may aggregate Personal

Information to calculate the percentage of our users who have a particular telephone

area code).

The Company may disclose Other Information in the following instances:

We may use and disclose Other Information for any purpose, except where we are required

to do otherwise under applicable law. In some instances, we may combine Other Information

with Personal Information (such as combining your name with your location). If we do, we will

treat the combined information as Personal Information as long as it is combined.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information

or other practices of any third parties, including any third party operating any site or service to

which the Services link. The inclusion of a link on the Services does not imply endorsement of

the linked site or service by the Company or by our related parties.

In addition, we are not responsible for the information collection, use, disclosure or security

policies or practices of other organisations, such as Apple, Google, Microsoft or any other app

developer, app provider, social media platform provider, operating system provider, wireless

service provider or device manufacturer, including with respect to any Personal Information

you disclose to other organisations through or in connection with the Services.

Security

The Company seeks to use reasonable organisational, technical and administrative measures

to protect Personal Information within our organisation. Unfortunately, no data transmission or

storage system can be guaranteed to be 100% secure. If you have reason to believe that your

interaction with us is no longer secure (for example, if you feel that the security of your account

has been compromised), please immediately notify us in accordance with the Contacting

Us section below.

Choices and Access

Your choices in relation to the disclosure of your Personal Information:

If you would prefer that the Company not share your Personal Information with our related

parties in future, you may opt-out of this sharing by contacting us at

privacy@rinnai.com.au. We will try to comply with your request as soon as reasonably

practicable.

How you can access, change or suppress your Personal Information:

If you would like to review, correct, update, suppress or delete Personal Information that you

have provided to the Company, you may do so by editing your user account or by contacting

us as set out in this Privacy Policy. In your request, please make clear what Personal

Information you would like to have changed, whether you would like to have your Personal

Information suppressed from our database or otherwise let us know what limitations you would

like to impose on the Company’s use of your Personal Information. For your protection, we

may only implement requests with respect to the Personal Information associated with the

particular email address that you use to send us your request, and we may need to verify your

identity before implementing your request. We will try to comply with your request as soon as

reasonably practicable.

Records Retention

The Company may need to retain certain information for record-keeping purposes. There may

also be residual information that will remain within our databases and other records, which will

not be removed.

The Company will retain your Personal Information for the period necessary to fulfill the

purposes outlined in this Privacy Policy unless a longer retention period is required or

permitted by law.

Use of the Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we request

that they not provide Personal Information through the Services.

Cross-Border Transfer

The Services are controlled and operated by us from Australia and are not intended to subject

us to the laws of any other jurisdiction. Your Personal Information may be stored and

processed in any country where we have facilities or in which we engage service providers,

including Japan, and, by using the Services, you consent to the transfer of information to

countries outside of your country of residence, which may have data protection rules that are

different from those of your country. In certain circumstances, courts, law enforcement

agencies, regulatory agencies or security authorities in those other countries may be entitled

to access your personal information.

Sensitive Information

We ask that you not send the Company, and you not disclose, any sensitive Personal

Information (e.g. information related to racial or ethnic origin, political opinions, religion or other

beliefs, health, biometrics or genetic characteristics, criminal background) on or through the

Services or otherwise.

Updates to this Privacy Policy

We may change this Privacy Policy. The “Last Updated” at the bottom of this page indicates

when this Privacy Policy was last revised. Any changes will become effective when we post

the revised Privacy Policy on the Services. Your use of the Services following these changes

means that you accept the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at

privacy@rinnai.com.au or Privacy Officer, Rinnai Australia Pty Ltd, 100 Atlantic Drive,

Keysborough, VIC 3173, Australia.

Because email communications are not always secure, please do not include credit card or

other sensitive information in your emails to us.

Last updated: 18 October 2022

Rinnai Australia Pty Ltd ABN 74 005 138 769