Wisebreeze – Privacy Policy

Welcome to Wisebreeze, a mobile application that, with the use of the accompanying AC controller, allows users to control their AC from the convenience of their mobile device. We, at Twitoplast Ltd. (an Israeli active company) (“Wisebreeze”, “we”, “us”, “our”) respect your privacy.

This Privacy Policy (the “Policy”) explains our privacy practices regarding your personal data and the data collected by the Wisebreeze AC Controller (the “Controller”) and provided by you in the accompanying Wisebreeze app (the “App”, which together with the Controller will be called the “Wisebreeze System” or the “System”). It describes how we collect personally identifiable information, use it and share it, and the rights and options available to you with respect to your information.

We are committed to safeguarding your privacy by achieving the highest standards of privacy and security, as well as being transparent about how we use and process your data.

It is your decision to provide us with your personal information. You are not legally obligated to provide us with this information, but in order to provide you with the Wisebreeze System’s functionality, we shall need access to the specific and rather limited information detailed below.

This policy is combined into our User Agreement [https://wisebreeze.com/wp-content/uploads/2021/06/User- Agreement.pdf] (the “Terms”) and form an integral part of it.

In short…

The following key points of the Privacy Policy are only brought for your convenience. They are not a substitute for the full Policy.

Information we We collect information you provide us under the registration process. We also collect measurements of your room temperature data when you use your AC and it is turned on. These measurements will be sent through the App, to our cloud server every time you control the AC from your App.
Using the information we We use the information we collect to operate the system and provide its features and functionalities.
Sharing the information we collect. We may share your information with third parties, mainly when you actively choose to share such information, by registering with your personal Wisebreeze user account to third party apps, and with our licensors, contractors and service providers, allowing you to make the most of the Wisebreeze System that help you seamlessly controlling your AC from your mobile
Aggregated We may use the information we collect from you to create de-identified (anonymous), statistical or aggregated information, and make it available to others for any purpose.
We retain your information for as long as we deem necessary for the purpose it was first obtained. If you withdraw your consent to us processing your data, we will erase your personal data from our systems.
We implement measures to reduce the risks of damage and unauthorized access or use of information, but these measures, just like any security measure, cannot provide absolute information security.
Children We do not knowingly or intentionally collect information about children who are under 13 years of age.
Changes to the Policy. We may change this Policy at any time but will seek your prior approval for any material

Wisebreeze – Privacy Policy

Identity and Contact Information of the Data Controller and its Representative

The Data Controller is –

Twitoplast Ltd. (an Israeli active company No. 511213571), 5 HaHaroshet St. I.Z. Sgulla, Petach Tikva, 4900710, Israel.

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, including the processing of your personal information, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, you can contact us at support@wisebreeze.com.

If you are in the European Union / United Kingdom, you may address privacy-related inquiries to our EU / UK representative pursuant to Article 27 GDPR:

EU: EU-REP.Global GmbH, Attn: Twitoplast, Hopfenstr. 1d, 24114 Kiel, Germany

UK: DP Data Protection Services UK Ltd., Attn: Twitoplast, 16 Great Queen Street, Covent Garden,

London, WC2B 5AH, United Kingdom twitoplast@eu-rep.global

www.eu-rep.global

We also have assigned a Data Protection Officer (DPO). Our DPO is Twitoplast LTD. CTO: David Twito

INFORMATION WE COLLECT

Registration. Only registered users may use the App. In order to register to our App, you shall need to provide us with your full name and email address.

Wisebreeze Device Information. Upon using the App together with the accompanying AC controlling device (the “Controller”), we shall collect measurements of your room’s set temperature (“Measurements”) when you choose to set or change them from your mobile device via the App to our cloud server.

Inquiries. If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your name, mobile phone number, e-mail address and other contact information, depending on the nature of your inquiry. We need your name to be able to associate your request with the answer and to address you personally. The phone number or e-mail address is needed for communicating our answer to you.

Analytic Information. When you access or use the App as a registered user, we may use third party analytic tools to automatically collect unidentified information about your use of the App. This information includes your session durations, the content you accessed on the App, your interactions and user-interface clicks, and the frequency and scope of your use of the App.

We specifically use Google Firebase to analyze the use of our System and App. Google Firebase gathers information about the use of the System and App by means of sending events to Google Analytics server. The information gathered relating to our System and App is used to create reports about the use of our System and

App in order to personalize your experience and improve our System and App. By using our System and App, you consent to have non-personal unidentified data used and processed by Google as described above. You can withdraw consent for this use of your data at any time, but this withdrawal shall only be applied to future activities. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Device information. We may collect information about your mobile device, including its model, its operating system, unique device identifiers, browser you use its version and language (i.e., locale) preferences, mobile network information and the Internet Protocol (IP) address through which you accessed the App. This information will be used for statistical, service improvement purpose only.

Cookies. A cookie is a small piece of information that is placed on your device when you visit certain websites.

Currently we are NOT intending to use cookies but in case we will implement in the future such a tool, we will use cookies or similar technologies to analyze trends, administer our App and services, track users’ movements around our App, and to gather demographic information about our user base as a whole. This will give us the possibility to improve our App and to provide you with a better user experience.

The data collected in this way will be pseudonymized by technical measures. It is therefore no longer possible to link the data with a specific user. The data will not store together with other personal data of the users.

Most of the cookies we if and when we will use, will be the so-called “session cookies”. They will be automatically deleted at the end of your visit. Other cookies, so called “persistent cookies”, will remain stored on your device until you delete them. These cookies will enable us to recognize your browser the next time you visit our App.

You have the right to object the use of persistent cookies. You can control the use of cookies at the individual browser level. You can set your browser in such way that you are informed about the setting of cookies and allow cookies only in individual cases, you can exclude the acceptance of cookies for certain cases or generally and you can activate the automatic deletion of cookies when closing the browser. Please be aware that, when cookies are disabled, the functionality of the App may be limited.

CHILDREN’S PRIVACY

We do not knowingly or intentionally collect information about children who are under 13 years of age.

IF YOU ARE UNDER THE AGE OF 13 YOU MAY NOT USE THE APP IN ANY WAY.

YOUR RIGHTS

At any point while we are in possession of or processing your personal data, you have the following rights:

Right to access – Request information on your personal data held by us as further detailed

Right to data portability – Gain access to your information by requesting a backup of your data in order to transfer such data to other companies or
Right to rectification – Correct your personal data in the App that is inaccurate or

Right to object – Object or withdraw your consent from your data processing at any

Right to be forgotten – Request the deletion of your data as further detailed

Right to complain – Lodge a complaint with the relevant supervising data protection authority if you believe we are processing your personal data under violation of applicable data protection

If you wish to exercise any of your abovementioned rights, please contact us at: support@wisebreeze.com.

USING COLLECTED INFORMATION

Your consent serves as the legal basis for processing your information. You may withdraw your consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.

We may use the information we collect from you for the following purposes:

Generating reports based on your Measurements, aimed at providing you with a better way to track your AC temperature patterns or settings;
Operating the App and providing its features and functionalities;

Sending you updates and other communications related to the App;

Offer you certain services regarding your AC;

Generating statistical and aggregated information about users of the App;

Providing you with support, handling complaints and contacting you when we believe it is

Enforcing the Terms and this Policy and preventing misuse of the

Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or
Taking any action in any case of dispute involving you, with respect or in relation to the

SHARING INFORMATION COLLECTED

We may share the information collected from you, as outlined in this Policy, with others, in any of the following instances:

We may use anonymized information for internal research purposes only;
We may use the information we collect from you to create de-identified (anonymous), statistical or aggregated information, and make it available to others for research purposes;
We may share your data with our licensors, contractors and service providers strictly for the purpose of helping us with the internal operation of the system and solely to the extent When they no longer need your data to fulfil the service or purpose, they will dispose it;
Upon your prior approval, we may share your data with certain services providers to offer you services regarding your AC;
If we believe that you may have breached the Terms, abused your rights to use the App, or violated any applicable law: Your information may be shared with law enforcement agencies and other competent authorities and with our counsels and any third party as may be required to handle any result of your wrongdoing, if we believe it is necessary or justified;
We may share your data to the extent required by law, or if we believe that sharing information is necessary to prevent imminent physical damage to body or
We may share your data if the operation of the App is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided however, that those entities agree to be bound by the provisions of this Policy, with respective changes taken into consideration;

We may share your data in any case of dispute, or legal proceeding of any kind between you and us, or between you and other users, with respect to the App or your use thereof. In any case other than the above, your information will only be shared with others if you provide your explicit prior consent, and we shall not share your personal data with third parties for marketing purposes without your prior explicit consent.

RETAINING AND DELETING COLLECTED INFORMATION

We may delete your information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

Please note that merely uninstalling the App won’t delete your account and its details, including all the information maintained on it and information sent to third party apps, which may still remain with us and with other third-party apps. If you wish to actively delete your information stored on our servers, please contact us at: support@wisebreeze.com. In order to process your request, we may require additional information or corroborative documents from you, to verify your account and confirm your identity.

Once we complete processing your request for deletion, we will delete your information from our systems. However, be advised that following such deletion, some information, though not accessible in the ordinary course of business, may still be retrievable from back-up copies or may still residually reside in our systems. You should also bear in mind that aggregated and analyzed information will not be deleted as it is merged with other information.

TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store and process information in the EU and in other countries throughout the world, such as the United States. We may also process information using cloud services. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services, solely to the extent that such countries are observing applicable privacy regulations and ensuring that your privacy rights remain protected.

If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then by using the App you are hereby providing us with your express consent to such cross-border transfer.

ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION AND OBTAINING A COPY OF IT

You may ask to access the personal information about you that is stored in our systems, or have us update, correct or delete such information. You may also be entitled to obtain from us the personal data you provided us (excluding data we obtained from other sources) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact us at: support@wisebreeze.com.

INFORMATION SECURITY

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. We follow industry best practices when transferring and storing your data. We will use all reasonable efforts to prevent any misuse, loss or alternation of your data. However, we cannot ensure or guarantee that the App will be totally immune from information security risks and that any transmission of personal information is at your own risk.

You must also make sure that your information is safe and secure. We are not responsible if you circumvent any privacy settings or security measures on our App. Even if we provide you with (or you have chosen) a password

for access to certain parts of our App, you are responsible for keeping this password confidential. Do not share your password with anyone.

CALIFORNIA RESIDENTS

The following disclosure is made pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our App, other parties, such as Google, may collect personally identifiable information about your activities over time and across different websites or online services.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this Policy, from time to time, to reflect changes in law, our data collection and data use practices, the features of the App or advances in technology. It is our policy to post any changes we make to this Privacy Policy on this page and the changes will be effective upon our publication of the updated Privacy Policy except as described below. You are encouraged to review this Policy periodically and to check the “Effective Date” at the bottom of this Policy for the most recent version, to inform yourself about how your personal information is collected, used and shared when you use the App. If we make material changes to how we treat your personal information we shall post a notice on this page thirty (30) days prior to the change becoming effective. However, changes made to comply with applicable laws will be effective immediately.

Effective date of the policy: 20/07/2021