JoRi Privacy Policy

Riello Privacy Notice for the “JoRi” application

This Privacy Notice describes the practices related to Personal Information collected through the Riello JoRi (the “App”). The Apps can be used to control remotely the comfort inside your house, monitoring the status of your Heating and AC system.

Riello S.p.A., via Ing. Pilade Riello no. 7, zip code 37045, Legnago (Italy), its subsidiaries and affiliates (collectively, “Riello”), part of the Carrier Global Corporation group of companies (collectively, “Carrier”), is committed to protecting the privacy of users of our mobile applications. It is important that our users understand how we collect, use and disclose Personal Information (as defined below). Riello, as the data controller, has implemented technical, administrative and physical measures to safeguard any personal information that we may collect. You can contact us via email: privacy.compliance.riello@carrier.com for any question regarding your privacy.

1 What Personal Information does Riello collect? How does Riello collect such Personal Information? “Personal Information” is information through which a natural person is identifiable or may be identified. Riello collects, uses and processes your Personal Information in order to provide you with services, products or information that you request.

The collection of Personal Information will be transparent to you, and you will have the opportunity to decide whether or not to provide it. If you choose not to provide any of the Personal Information requested, Riello may be unable to complete your transaction, or provide the information, services or products you have requested.

Riello collects information, including Personal Information, from you when you submit a form or request, or register a product with Riello, such as: name, physical address, your employer, phone number, e-mail address and number, as well as any other Personal Information you provide to Riello. Riello may also ask you to provide information about the product you are registering (e.g. a device identifier) or the person/company that installed or maintains it.

Riello may also collect information through your use of the App, such as:
Mobile Device Info: appVersion, mobile phone device language, if you permit or share Latitude and longitude (geo-location), Mobile phone operating system category IOS/android, channel ttid, push notification id;
User Profile: username: registered with email address, password – in the logs with Hash with salt, email address, the language preference setting in the mobile phone, zip code, country and, if you permit or

share, Longitude and latitude, Language Preference, phone number, First Name, Last Name, Residence Address, City, Phone Number.

if you have enabled push notifications, Riello collects your push notification id, if you registered using your email address, Riello collect it. Riello collects daily temperature. If you share feedback and suggestions features in the App, Riello collects information about your e-mail and feedback content.

Riello collects your usage data: during interaction with device or the App, it automatically collects usage data relating to visits, messages sent/received, types of features used, frequency of usage and other data related to device or App usage. If you permit or share, Riello collects upgrade status, upgrade text, GMT_Upgrading, city, country, residence address. In case of troubleshooting, Riello may access the last requests from the http interface and the mqtt.

Your mobile or internet services providers may have a conflicting privacy position or policy that permits them to capture, use and/or retain your Personal Information when you visit the Apps, but Riello is not responsible for and does not control how other parties may collect your Personal Information when you access the Apps.

Third party authentication. For authentication purposes, you can decide to log-in to our Apps using your social media account that you have in place with Google, Apple. Riello will in that case rely on the authentication method of that third party, and will not have access to your password and/or the content of your social media account. These third parties may have separate privacy notices in place, and Riello is not responsible for and does not control how other parties may collect your Personal Information when you access the Apps.

2 Why does Riello collect your Personal Information?

Our purpose in collecting this information is to provide customized services and content relevant to your specific needs and interests. Your information may be used by Riello to carry out our contractual obligations, authenticate you as a user and allow you access to certain areas of our Apps.
Except where used in support of a contract with you or to fulfil a legal obligation, our use of your Personal Information will be only for legitimate business interests as set out below. Personal Information collected on the Apps may be used to:

• Conduct basic business operations, such as communicate with customers and business planning;
• Provide requested information, items, or services;
• Respond to your request or further process your submitted form;

• Advertise products, services, promotions and events relating to Riello;
• Improve our products, services, Websites and Apps;
• Verify your identity to ensure security for one of the other purposes listed here;
• Respond to a legitimate legal request from law enforcement authorities or other governmentregulators;
• If you provide your contact details, to provide requested information or services;
• Protect against fraud or investigate suspected or actual illegal activity;
• Develop new offerings, improve the quality of our products, improve and personalize userexperience, and develop content based on your interests and those of our customers; or
• Conduct investigations to ensure compliance with, and comply with, legal obligations;
• enable you to successfully register and verify your account;
• enable you to use the device and ensure the normal operation;
• to enable you to report device errors to us and for Riello to communicate App fault informationto you when necessary.

3 Where is your Personal Information stored?

Because Riello is a global company with locations in many different countries, we may transfer your information from one legal entity to another or from one country to another within Riello in order to accomplish the purposes listed above. These countries include, at a minimum, the United States, the member states of the European Union, the United Kingdom, Switzerland, Canada, and other countries, including some in Asia. We will transfer your Personal Information consistent with applicable legal requirements and only to the extent necessary for the purposes set out above.

Riello relies on available legal mechanisms to enable the legal transfer of Personal Information across borders. To the extent that Riello relies on the Standard Contractual Clauses (also called the Model Clauses) to authorize transfer, Riello will comply with those requirements, including where there may be a conflict between those requirements and this Privacy Notice.

4 Does Riello use your Personal Information to contact you?

If permissible under local law, Riello may use the Personal Information you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you prefer not to receive such communications, please send an e-mail to privacy.compliance.riello@carrier.com.

Riello will ensure that any marketing communications sent by electronic means will provide a simple method for you to opt-out or unsubscribe. Please note that if you unsubscribe from marketing

Your Personal Information will also be maintained and processed by our service providers in the United States, the member states of the European Union, the United Kingdom, Switzerland, Canada, Asia, and in other jurisdictions, within an appropriate legal and contractual framework.

6 How does Riello secure Personal Information?

Riello is committed to ensuring the security and integrity of Personal Information. Riello has adopted reasonable physical, technical and administrative procedures to safeguard your Personal Information. However, due to the nature of Internet communications, we cannot guarantee or warrant that your transmission to us is secure.

7 How long do we keep your Personal Information?

The Personal Information you provide to Riello is only kept for as long as it is reasonably necessary for the purposes for which it was collected, taking into account our need to comply with contractual obligations, resolve customer service issues, comply with legal requirements and provide new or improved products and services to users. This means that we may retain your Personal Information for a reasonable period after you stopped using the Riello Apps. After this period, your Personal Information will be deleted from all systems of Riello without notice.

8 How can you correct, change or delete your information held by Riello?

You may request to access, update, correct, change, or delete your Personal Information at any time. Riello will use reasonable efforts to timely update and/or remove your Personal Information. To protect the user’s privacy and security, Riello will take steps to verify the user’s identity before making any requested access or change. To access, update, correct, change, or delete your Personal Information, to ask questions or to raise concerns regarding data protection and privacy, send an e-mail to privacy.compliance.riello@carrier.com.

Please note that while we will assist you in protecting your Personal Information, it is your responsibility to protect your passwords and access credentials from others.

9 IP Addresses

An Internet Protocol (IP) address is a number that is used by device on the network to identify your device every time you log on to the Internet.
Riello may collect and keep track of IP addresses to, among other things:

• Maintain App safety and security;
• Troubleshoot technical issues; and
• Better understand how the Riello App is used.

10 How may Riello use location data?

Riello is a global provider of Heating and A/C technologies. Our heating, ventilating, air-conditioning and refrigeration systems and services promote integrated, high-performance buildings that are safer, smarter and sustainable. As such, the following are some examples of when location data may be requested to provide some of the services that Riello has to offer:

• To improve building product capability, such as use your location data to dynamically adjust Heating and A/C system settings;
In all of these cases, Riello will ask permission to collect your location data and so the collection of this data will be transparent to you – you will have the opportunity to decide whether or not to provide your location data. If you choose not to provide your location data, Riello may be unable to provide the requested service or complete the requested transaction.

11 What additional information should specific users know?
Parents, Guardians, and Children: Our Apps and Websites are intended for visitors who are at least 18 years of age, or the age of majority in their jurisdiction of residence. Riello does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your Personal Information on this or any other Riello Websites or Apps.
Users from California: If you are a resident of California, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”), including the right to:
a) know what categories of personal information about you we have collected and used, including how the personal information was collected and the purpose for the collection and use;
b) know what categories of personal information are being sold or disclosed to third parties and, if sold or disclosed, the categories of third parties receiving it;

c) access specific personal information collected about you;
d) request that your personal information be deleted.
Requests to exercise rights under the CCPA are subject to verification by Riello and are also subject to certain restrictions provided by the CCPA. We will not discriminate against California residents for exercising any of their applicable CCPA rights. While California residents have the right to opt-out of the sale of their personal information under CCPA, Riello does not sell personal information to third parties. If our practices change, we will update this Privacy Notice and take any necessary action to comply with applicable law.
California residents who wish to exercise their CCPA rights can contact Riello at privacy.compliance.riello@carrier.com . You can also contact us at 1-833-617-0050. When contacting us to exercise your rights, please put “California Privacy Rights” in the subject and body of your request and describe the nature of your request.
Annually California residents may request and obtain information that Riello shared with other businesses for their own direct marketing use within the prior calendar year (as defined by California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which Riello shared this information in the immediately preceding calendar year. To obtain this information, please send an e-mail message to privacy.compliance.riello@carrier.com with “California Shine the Light Privacy Request” in the subject line as well as in the body of your message.
Users from the European Union and other countries with privacy laws: You have the right to lodge a complaint with your national or state data protection authority, which may also be known as a supervisory authority. You also have the right to: (i) request access to and correction or erasure of your Personal Information; (ii) seek restrictions on; or (iii) object to the processing of certain Personal Information and seek data portability under certain circumstances. To contact Riello about a request to access, correct, erase, object or seek restrictions or portability, please e- mail privacy.compliance.riello@carrier.com.
Users from the US: Riello does not collect Social Security Numbers through its Apps or Websites.

12 How might Riello change this Privacy Notice?

As Riello expands and improves its Websites and its Apps, or as legal requirements change, we may need to update this Privacy Notice. This Privacy Notice may be modified from time to time without prior notice. We encourage you to review this Privacy Notice on a regular basis for any changes. The date of the latest version will be identified at the bottom of the policy.

13 How can you contact Riello?

If you have any comments or questions or if there are other things we can do to maximize the value of this App, please email marketing.riello@carrier.com.
If you wish to access, correct, update or erase your Personal Information, or if you have questions about Riello’s privacy practices in general or a complaint, please e-mail privacy.compliance.riello@carrier.com. In the event that you are located in a country that is governed by the General Data Protection Regulation and would like to contact the local Data Protection Officer, please note that in your e-mail and your inquiry will be directed to the appropriate person.

Last updated: June 10th , 2022