HeatGo and its Affiliates (as hereinafter defined) (“I”, “us”, “my”, or “HeatGo”) are committed to protecting your privacy. HeatGo Privacy Policy (this “Policy”) describes my practices in connection with information privacy on Personal Data (as hereinafter defined)I process through your use of my products and services (collectively, the “Services”), for instance the HeatGo Mobile Application (the “App”) .

Before you start using the Services, please carefully read this Policy which details my purposes for collecting and processing your Personal Data, as well as howI use, store, share and transfer your Personal Data. In this Policy you will also find ways to exercise your rights of access, update, delete or protect your Personal Data.

You are not obliged to provide tomeyour Personal Data (as defined below). However,I may be unable to provide you with certain products and/or Services if you decline to provide such data.

If you are a children under the age of 13 (or such other age provided by applicable law in your country/region of residence), please read this agreement with your legal guardian or parent and make sure that you and your guardian or parent have clear understanding about my privacy protection practices.

In this Policy:

Affiliate means any company, firm or legal entity that: (1) is directly or indirectly controlled by HeatGo; or (2) directly or indirectly controls HeatGo; or (3) jointly with HeatGo, controls the same company; or (4) is, directly or indirectly, under common control of the same company with HeatGo. Affiliates shall include, without limitation, HeatGo’ parent companies, subsidiaries, and such subsidiaries under common control of the same parent company as HeatGo.

Personal Datameans information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other informationI have access to about that individual.

Personal Sensitive Data includes personal biometric information, communication records and contents, and precise location information, etc. according to various data protection laws and regulations. WhenI collect Personal Sensitive Data from you,I will generate an explicit notification for your consent beforeI collection personal sensitive data about you.

Smart Devices refers to those 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: ASHP, GSHP, Heatpump, etc.

1. What Personal Data DoI Collect?

In order to provide the Services to you,I will ask you to provide necessary Personal Data that is required to provide those Services. If you do not provide your Personal Data,I may not be able to provide you with the Services.

1) Information You Voluntarily Provide to Us

     · Registered Account Data: When you register an account with us,I may collect your account name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with the Services,I may further collect your nickname, country code, language preference or time zone information into your account.

     · Feedback: When using feedback,I will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

Information based on additional functions:

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

Additional functions based on location information:

When you enable the location-based functions through permission settings on your mobile device,I will collect and process your location information to enable these functions, such as pairing with your Smart Devices. You can cancel the location authorization after the device's pairing is completed.

You may opt-out the using of location infomation: "Setting(on your phone) - (“Apps”or”App Manager”) - HeatGo - Switch on/off Location Information"

Additional services based on camera:

You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device. Please be aware that even if you have agreed to enable the camera permission,I will only obtain information when you actively use the camera for scanning codes.

You may opt-out the using of camera permission: "Setting(on your phone) - (“Apps”or”App Manager”) - HeatGo - Switch on/off Switch on/off Camera"

Additional services for accessing and uploading pictures based on photo albums (picture library):

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

You may opt-out the using of photo album permission: "Setting(on your phone) - (“Apps”or”App Manager”) - HeatGo - Switch on/off Switch on/off Photo Album"

Additional services based on storage permission (Android):

The purpose is to ensure the stable operation of the App by utilizing the storage permission. After you give or indicate the permission to read/write your mobile device’s storage,I will access pictures, files, crash log information and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.

You may opt-out the using of storage permission: "Setting(on your phone) - (“Apps”or”App Manager”) - HeatGo - Switch on/off Storage"

Additional services based on Notification permission:

The reason whyI ask you the permission is to send you notifications about using the products or services, especially if you need to receive invitation messages, authorization messages, and feedback responses, etc .

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

Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning on the permission, including control the Smart Device, acquiring device status, device discovery, and device network configuration. In these functions,I will communicate with terminal devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission,I will only use Bluetooth for communication in these scenarios: display the device status on the home page and Smart device panel; perform device control on the home page and device panel;I would use it on the home page and the add device page for discovering equipment, equipment distribution network.

You may opt-out the using of Bluetooth via "Setting(on your phone) - (“Apps”or”App Manager”) - HeatGo - Disable/Enable Bluetooth permission".

Please note that if you turn on any permission, you authorizemeto collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission,I will take it as a cancellation of the authorization, andI will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect previous collection and use of information based on your authorization.

2) InformationI Collect Automatically

     Mobile Device Information: When you interact with my Services, in order to provide and maintain the common operation of my Services, improve and optimize my Service, and protect your account security as well,I may automatically collect mobile device information, such as mobile device model number, IP address, wireless connection information, the type and version of the operating system, application version number, push notification identifier, log files, and mobile network information. Meanwhile,I will collect your software version number.

     Usage Data: During your interaction with my websites and Services,I automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of my websites and Services.

     Log Information: When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, preference language setting, operating system version, date or time of access, so thatI can facilitate and accurately identify problems and help you solve them in timely manner.

Please note that one cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such  information will be treated as Personal Data. UnlessI have obtained your consent or unless otherwise provided by data protection laws and regulations,I will aggregate or desensitize such information.

3) Smart Devices Related Information:

When you use a smart device,I will collect some basic and pre-embedded information of the Smart Device and the information generated during your use of the Smart Device.

     Basic Information of Smart Devices: When you connect your Smart Devices with the Services,I may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

     Information collected during the process of connecting to a Smart Device: Based on the type of Smart Device you need to connect, whether the Smart Device is connected via Wi-Fi, via Wi-Fi after establishing a local connection via Bluetooth, via Bluetooth or via Zig-bee,I will collect the Mac address of the smart device.

     Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with the Services,I may collect different information reported by your Smart Devices such as fault name, fault time, fault equipment and fault status.

2. Purposes and Legal Basis for Processing Personal Data

The purpose for whichI may process information about you are as follows:

     Provide You Services:I process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services and Services that you have requested. The legal basis for this processing is to perform my contract with you according to our User Agreement.

     Improve my Services:I process your mobile device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyze the efficiency of my operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform my contract with you according to my User Agreement.

     Non-marketing Communication:I process your Personal Data to send you important information regarding the Services, changes to my terms, conditions, and policies and/or other administrative information. At the same time,I will also send you information related to equipment operation and maintenance, such as equipment maintenance suggestions and measures. You can check the “App Notification” in the App ("Me > Message Center > Setting”) to manage these communications. When you decide not to enable the Notifications function,I will no longer process your information for such purpose. The legal basis for this processing is to perform my contract with you according to my User Agreement.

Data Analysis: In order to analyze the usage of the productsI provide and improve your user experience,I will analyze the data you provide us,I need to check your problems when you encounter any malfunctions during the usage of the product, under such circumstance,I will send an authorization application message for equipment debugging and problem resolution with your consent. The legal basis for such processing is based on your consent.

     Legal Compliance.I disclose information ifI are legally required to do so, or ifI have a good faith belief that such use is reasonably necessary to:

     a) comply with a legal obligation, process or request;

     b) enforce my User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;

     c) protect the rights, property or safety of us, my users, a third party or the public as required or permitted by law;

     d) detect, prevent or otherwise address security, fraud or technical issues.revent or otherwise address security, fraud or technical issues.

If there is any change in the purposes for processing your Personal Data,I will inform such change to you with a prominent notice on my website or App Message Center of such changes of purposes, and choices you may have regarding your Personal Data.

3. Who doI Share Personal Data with?

At HeatGo,I only share Personal Data in ways thatI tell you about. Without your consent,I will not disclose your Personal Data to third-party companies, organizations, or individuals except in the following cases:

     To my 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 my 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 my websites and Services.

     To subsidiaries or affiliates within my corporate family for purpose of regular business activitiesbased on my instructions and in compliance with applicable law, this Privacy Policy and other appropriate confidentiality and security measures.

     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 my 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 my website of any change in ownership, and choices you may have regarding your Personal Data.

     AsI believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:

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

(b)Enforce my Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof;

(c) Protect my operation and business sustems;

(d)Protect the rights, property or safety of us, my users, a third party or the public as required or permitted by law;

(e)Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.

Except for the third parties mentioned above,I only disclose your Personal Data to other third parties with your consent.

Data Transfer

HeatGo operates globally, and Personal Data may be transferred, stored and processed outside of the country or region where it was initially collected （The server is currently located in Frankfurt, Germany）. Also, the applicable laws in the countries and regions whereI operate may differ from the laws applicable to your country of residence.

Under the Personal Data protection framework and in order to facilitate my operation,I may transfer, store and process your Personal Data in jurisdictions other than where you live.

We protect Personal Data in accordance with this Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws.

The European Commission has determined that certain countries outside of the European Economic Area (EEA), the UK or Switzerland can provide adequate protection of Personal Data. Where Personal Data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection,I ensure that the transfer is governed by the European Commission’s standard contractual clauses. You can review the agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see here.

If you would like further details on the safeguardsI have in place under the data transfer, you can contactmedirectly as described in this Privacy Policy.

Data Subject Rights

We respect your rights and control over your Personal Data.

Response Fee Timeframe: You do not have to pay any fee for executing your personal rights. Subject to applicable data protection laws in relevant jurisdictions, your request of privacy rights will be fulfilled within 15 business days, or within 30 calendar days due to different response requirement.

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 my database or otherwise letmeknow what limitations you would like to put on my use of your Personal Data. Please note thatI may ask you to verify your identity before taking further action on your request, for security purposes.

You may exercise any of the following rights:

     Right of Access: Request access to the Personal Data thatI process about you via "Me - Setting - Export Personal Information";

     Right of Rectification: Requestmeto correct inaccurate or incomplete Personal Data about you:

1) Modify your account number (email address or phone number) via "Me - Setting - Change phone number/ Change Email";

2) Modify the nickname via "Me - Personal";

     Right of Deletion: Request to delete of Personal Data about you via "Me - Setting - Security setting - Account cancellation", when you confirm the deletion of your account, your Personal Data will be deleted accordingly.

     Right of Restriction of Processing Personal Data: Request to restrict, temporarily or permanently, on my processing of some or all Personal Data about you via "Me-Feedback", or send over the email request to sales@axen-heatpump.com;

     Right of Opt-out/Objection: Opt-out or object to my use of Personal Data about you where my use is based on your consent or my legitimate interests, please kindly check the following "consent withdraw" section.

1) For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library), Bluetooth settings, notification settings and other related functions;

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

3) Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected;

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

If you have more questions please do not hesitate to contact sales@axen-heatpump.com to elaborate your privacy rights.

Security Measures

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. HeatGo provides various security strategies to effectively ensure data security of user and device.

     As for device access, HeatGo proprietary 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 withmeis no longer secure (for example, if you feel that the security of any account you might have withmehas been compromised), you could immediately notifymeof the problem by emailing sales@axen-heatpump.com .

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Policy, unless there is a specific legal requirement formeto keep the data for a longer retention period.I determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends,I will destruct your Personal Data.

     For as long as you requiremeto fulfill the products and services you request frommeas defined in the User Agreement;

     Personal Data will no longer be retained when you request to remove your Personal Data,I will accordingly complete the task.

WhenI are unable to do so for technical reasons,I will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Children’s Privacy

Protecting the privacy of young children is especially important 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), andI request that these individuals do not provide any Personal Data to us.I do not knowingly collect Personal Data from any child unlessI first obtain permission from that child’s parent or legal guardian. IfI become aware thatI have collected Personal Data from any child without permission from that child’s parent or legal guardian,I will take steps to remove that information.

Changes to this Policy

We may update this Policy to reflect changes to my information practices, at least on an annual basis. IfI make any material changesI will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective.I encourage you to periodically review this page for the latest information on my privacy practices.

Contact Me

If you have any questions about my practices or this Policy, please contact me as follows:

Email: heatgo2025@gmail.com