PRIVACY POLICY (Mobile Technician Pro)

This PRIVACY POLICY ("Privacy Policy") describes how GENERAL Inc. ("GNL", "we", "us", "our") collects and processes your Personal Information (if any, as defined in Section 1 below) when you use GNL’s Mobile Technician Pro mobile application(s) we distribute (together with all services and content provided to you by GNL in connection with the mobile application, the "App") in connection with your diagnosis or identification of errors and abnormalities in GNL’s air conditioners (“HVAC Units”), or your use of other functions.

WHAT INFORMATION WE COLLECT THROUGH THE APP

"Personal Information" is information that identifies you as an individual or relates to an identifiable individual.

We might collect the following Personal Information through the App:

• Contact Information, such as your name, address, e-mail address, and telephone/fax number (work or personal)
• Online Identifiers, such as IP address and device identifiers (a unique ID to identify you)
• Authentication Information, such as information used to register for, access, verify, or secure your account, including your user name, login ID, email address, password, authentication tokens, one-time passcodes, two-factor authentication data, and similar information.

If/When Personal Information above are connected to other data, as listed below, the following data may also be treated as Personal Information and may be subject to this Privacy Policy:

• Data regarding your device, such as device category (mobile or tablet), model name/brand, OS version, language settings
• App usage data, such as when you update the App
• Region (country and city) from which your activity originated

HOW WE COLLECT PERSONAL INFORMATION

We (including our service providers) might collect Personal Information through or in connection with the App.

For example, we might collect Contact Information when you provide them to us directly when contacting us regarding the App, your Personal Information, or the Terms of Service/Privacy Policy.

We and our service providers might collect Online Identifiers automatically from you when you access/use the App.

We might need to collect Personal Information to provide the requested services on the App to you.

If you do not provide information requested, we may not be able to provide the services.

PERSONAL INFORMATION OF OTHER PEOPLE

If you disclose any Personal Information relating to other people to us or to our service providers in connection with the App, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the App (or otherwise) to us.

HOW WE USE PERSONAL INFORMATION

We may use your Personal Information for the following purposes:

Providing the functionality of the App and fulfilling your requests.

• To provide the App's functionality to you, such as allowing you to diagnose abnormalities regarding the HVAC Units through the App.
• To send administrative information to you, such as changes to the App's terms, conditions, and information about updates to the App.
• To send service-related communications, such as responding to your inquiries about problems relating to the App.
• To identify the causes of cloud system downtime and failures when they occur.
• To manage customer complaints and other issues.
• To enable and administer updates, patches, and upgrades to the App
• To maintain service continuity, including backup, disaster recovery, and business continuity measures
• To monitor the performance, availability, and reliability of the App and related systems.
• To improve and develop the App or other services and products.
• To create and administer your account for the App.
• To authenticate your identity and manage access to the App.
• To manage your login credentials, password resets, and account recovery.

We will engage in these activities to manage our contractual relationship with you, and/or to take steps at your request prior to entering into a contract, and/or to comply with a legal obligation.

Where relevant, we also process Personal Information our legitimate interest, such as ensuring the ongoing functionality, security, support, reliability, quality, and improvement of the App and related services.

Accomplishing our business purposes.

• For enhancing, improving, repairing, maintaining, or modifying the App and underlying services, as well as undertaking quality and safety assurance measures (including fixing bugs and errors within the App) to ensure the App provides a certain level of service to you.
• For identifying usage trends, including, understanding which features of the App are used by you.
• For audits, to verify that GNL's internal processes function as intended and to address legal, regulatory or contractual requirements.
• For fraud prevention and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.

We engage in these activities to manage our contractual relationship with you, and/or to comply with a legal obligation, and/or because we have a legitimate interest in operating, maintaining, securing, auditing, improving, and protecting the App, the underlying services, and our business operations, including understanding how the App is used, ensuring service quality, and preventing fraud and security incidents.

HOW WE DISCLOSE PERSONAL INFORMATION

We disclose Personal Information about you:

• To the entities directly or indirectly controlling, controlled by or under common control with GNL ("Affiliates") for the purposes described in this Privacy Policy.
• To our service providers (e.g., Google) who provide services such as data analytics, information technology and related infrastructure provision, platform hosting/maintenance/troubleshooting, customer service, product development, auditing, advisory and other services.
• To a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our, or any of our Affiliates', business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• To additional recipients, as agreed by you and us.

We also use or disclose Personal Information, as necessary or appropriate:

1. to comply with applicable law, including laws outside your country of residence;
2. to comply with legal process;
3. to respond to requests from public and government authorities, including public and government authorities outside of your country of residence;
4. to enforce our Terms of Use;
5. to protect our operations;
6. to protect our rights, property or safety, and/or that of you or others;
7. to allow us to pursue available remedies or limit the damages that we may sustain.

SECURITY AND RETENTION

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

If you have reason to believe that your Personal Information is no longer secure, please immediately notify us in accordance with Section 14 below.

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the App to you (for example, as long as you keep using the App);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

YOUR PRIVACY RIGHTS

If you would like to request to access, update, correct, or delete your Personal Information provided to us, object to the processing of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you can do this by emailing or writing to us as detailed in Section 13 below.

We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.

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.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

ADDITIONAL INFORMATION REGARDING THE EUROPEAN ECONOMIC AREA (the “EEA”): You may also lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work, or where an alleged infringement of applicable data protection law occurs.

The data protection authority of the UK is the Information Commissioner's Office (ICO), and a list of the EEA data protection authorities is available at here: LINK .

CROSS BORDER TRANSFERS

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App you understand that your information will be transferred to countries outside of your country of residence, including Japan, 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.

As required by applicable law, we implement safeguards to protect your Personal Information when we transfer it outside your country of residence.

• For transfers from within the UK, Switzerland and/or EEA to outside the UK, Switzerland and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
• Some countries outside of the European Economic Area (the “EEA”) are recognized by the UK government, Swiss government, and the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these “specified countries” is available at here: LINK ). The UK recognizes the EEA member states, the specified countries and certain other countries as providing an adequate level of data protection according to UK standards (the full list is available at here: LINK ). Switzerland recognizes EEA member states and the countries available at here: LINK .
• For transfers from the EEA, Switzerland, and/or the UK to countries not considered adequate by the European Commission, Switzerland, or the UK government (as applicable), we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with Section 13 below (“How Can You Contact Us“”).
• For transfers from Japan to countries not considered adequate by the Japanese government, we have also put in place adequate measures, such as data transfer agreements containing provisions required under Japanese law, to protect your Personal Information.

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 website or service to which the App link.

The inclusion of a link on the App does not imply endorsement of the linked site or service by us.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as, Google, Apple, or any other app developer, app provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the App.

USE OF THE APP BY MINORS

The App is not directed to individuals under the age of majority, and we do not knowingly collect Personal Information from individuals under the age of majority.

For example, in many countries, such as the EEA, UK, and Switzerland, the age of majority is 18.

If you are unsure what the age of majority is for your jurisdiction, please contact us in accordance with Section 13 below.

UPDATES

We may make changes to this Privacy Policy at any time, so please review it periodically.

We will update the effective date of the Privacy Policy at the time a change is made.

The "Last Updated" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.

Any changes will become effective when we post the revised Privacy Policy on the App.

HOW CAN YOU CONTACT US?

We are responsible for Personal Information used under this Privacy Policy.

If you have any questions or complaints about this Privacy Policy, or how we process your Personal Information, please contact us below.

• Japan: Mail
• Other regions: Inquiry Form

ADDITIONAL INFORMATION FOR CALFORNIA RESIDENTS

Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), we are providing the following additional details regarding the categories of Personal Information that we might collect, use, and disclose about California residents.

Sources of Personal Information

We might collect Personal Information from our interactions with you, for example, when you utilize the App or otherwise interact with us, and we might collect Personal Information directly from the HVAC Units.

Categories of Personal Information Collected and Disclosed

The following chart details which categories of Personal Information about California residents we may collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, contact information, IP address, and other online identifiers	Affiliates, third-party service providers, and legal authorities
Personal information, as defined in the California customer records law, such as name and contact information	Affiliates, third-party service providers, and legal authorities
Characteristics of protected classifications under California or federal law, such as primary language	Affiliates, third-party service providers, and legal authorities
Commercial information, such as transaction information and payment history	Affiliates, third-party service providers, and legal authorities
Internet or network activity information, such as browsing history, search history, and interactions with our online services	Affiliates, third-party service providers, and legal authorities
Audio, electronic, visual, and similar information	Affiliates, third-party service providers, and legal authorities
Professional or employment-related information	Affiliates, third-party service providers, and legal authorities
Geolocation data, such as GPS coordinates of a property or outdoor HVAC Unit, if the user chooses to provide them, and approximate location derived from IP address	Affiliates, third-party service providers, and legal authorities

Use of Personal Information

We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:

• Fulfill your requests and respond to your inquiries;
• Develop, improve, repair, provide and maintain our products and services;
• Personalize, advertise, and market our products and services;
• Conduct research, analytics, data analysis, data aggregation, and data anonymization;
• Maintain our property and our records, and undertake quality and safety assurance measures;
• Conduct risk and security control and monitoring, and detect and prevent fraud;
• Perform identity verification, accounting, audit and other internal functions, such as internal investigations and record-keeping;
• Carry out corporate transactions, such as mergers, joint ventures or acquisitions; and
• Comply with law, legal process, and internal policies, and exercise and defend legal claims.

Under the CCPA, if a business sells Personal Information, it must allow California residents to opt out of the sale of their Personal Information.

However, we do not sell and have not sold Personal Information, as "sale" is defined in the CCPA.

For example, and without limiting the foregoing, we do not sell the Personal Information minors under 16 years of age.

Individual Rights and Requests

If you are a California resident, you may request that we:

• Disclose to you the following information covering the 12 months preceding your request:
• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting Personal Information about you; and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.
• Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at www.generalww.com/global/contact/form/input-servicetool.html, or +1-888-888-3424.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.

We may need to request additional Personal Information from you, such as the telephone number and email address, in order to verify your identity and protect against fraudulent requests.

If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

You have a right to be free from unlawful discrimination for exercising your rights under the CCPA.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above.

As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:

• Proof of your registration with the California Secretary of State to conduct business in California; and/or
• A power of attorney from the California resident pursuant to Probate Code sections 4121-4130.

If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

• Verify the resident's own identity directly with us; or
• Directly confirm with us that the resident provided you permission to submit the request.