Privacy Policy for Water-Right, Inc.’s Wripli® Products

Approved by Management on June 13th, 2018

Effective July 1st, 2018

Purpose

Water-Right, Inc. (“Water-Right”) may need to collect and use certain information about the individuals who choose to use Water-Right’s Wripli Products. This information may include both personal information and non-personal information. “Personal Information” is information that identifies an individual or reasonably can be used to identify an individual (e.g. name, postal address, email address, telephone number, IP address, or any other identifier that permits the physical or online contacting of a specific individual). “Non-Personal Information” means information that on its own cannot be used to identify an individual (e.g. water usage data or product version data). This information may be necessary so that we can provide your requested services.

This Privacy Policy for Water-Right’s Wripli Products (“Privacy Policy”) describes the type of information that Water-Right’s Wripli Products collect, use, share, and store, how Water-Right uses the information, how and with whom Water-Right may share the information, how Water- Right may store the information, and steps taken to safeguard the information collected.

This Privacy Policy only applies to the information obtained by Water-Right through its Wripli Products. In this Privacy Policy, Water-Right’s Wripli Products include Water-Right’s line of Wi-Fi enabled water treatment devices (the “Device” or “Devices”) and services you receive on the Wripli Website, the Wripli Web App, and the Wripli Mobile App.

Water-Right contracts with third party Dealers (“Dealers”) who sell and service Water-Right devices throughout Dealer’s territory. Although Water-Right takes precautions when contracting with Water-Right Dealers, Dealers are not in any way operated or controlled by Water-Right.

Therefore, when interacting with a Dealer, any privacy policy of your Dealer will apply. Dealers may have their own privacy practices, which we recommend you review.

Consent

Water-Right needs to collect certain information from you to provide you services through its Website, Web App and Mobile App, as well as its supporting Dealer network. If you do not provide this information, Water-Right and your Dealer may not be able to serve you adequately. By using Water-Right’s Wripli Products, you agree to allow us to collect, use, share, and store your data in accordance with this Privacy Policy and as permitted or required by law.


Consent to International Data Transfers

Your personal information may be collected, processed and stored by Water-Right or its service providers in the United States. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in the United States may not be equivalent to those in your country. If you are using the Device in Canada, then you consent to the transfer of your personal data to the United States.

Sensitive Information

We will not ask for, and we ask that you not send us and you not disclose any sensitive personal information (e.g., social security numbers, financial information, or information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or membership with any organization) on or through the services or otherwise to us.

Information that Water-Right Collects

This section describes the information that Water-Right collects. To read about how that information is used, please see the next section titled “How Water-Right Uses Data”

The data collected includes, but is not limited to:

1. Account information, including personal and non-personal information, such as your name, address, phone number, and email address.

2. Device information, such as brand, model number, serial number, nickname for the Device, software and hardware version numbers, IP address, MAC address of the Device, RFID and/or Wi-Fi connection, and Device purchase date.

3. Information typically collected through web sites and applications, such as browser and Device information, application usage data, information collected through cookies and other technologies, and IP addresses.

4. Water quality data.

5. Real-time usage data, such as the (number of) times the Device is turned on or off, the type and/or number of cycles run by the Device, different modes used, and the date your Device was installed.

6. Direct adjustments to the Device, including settings.

7. Technical information from the Device, such as performance and configuration data.

8. Electronic information, such as sensor logs, trends, event data, status, error codes, application interaction data, crash reports, electronic data files downloaded manually or automatically from the Device, and other data.

9. Diagnostic information for your Device, specifically status, maintenance, alerts, and performance information. This may include maintenance schedule, planned maintenance, warranty coverage data, service intervals (scheduled interval for planned maintenance of component replacement activities for the Device), and service letters (describing special service actions recommended by Water-Right to correct a known problem with the Device).

10. Wi-Fi network information, such as the Device's IP Address.

11. Customer service information, such as personal and non-personal information related to providing your requested services and when your Device was serviced and by whom, and records of maintenance and repairs.

How Water-Right Uses Data

Account Creation and Product Registration

When you purchase a Water-Right Device, a Water-Right Dealer will ask you to provide personal and non-personal information. A Water-Right Dealer will collect your name, address, phone number, email address, and your Device’s brand model number, serial number, nickname for the Device, and Device purchase date. Your Dealer will use this information to register your Device, to create an account for you on the Wripli website, and to provide you with a temporary Wripli login and password. When you create a Wripli account, we collect and store your email address. From that point forward, your email address is used for communications from the Dealer. Without this information, Water-Right is unable to create your Wripli account. Without a Wripli account, you are unable to view the data collected by your Device, and your Dealer will not be able to provide your requested services.

Device and Account Information on Wripli Website

Water-Right will use your personal and non-personal information to create your account on the Wripli website and assign you a temporary login and password. To access your online account, you will need to log in to the Wripli website with your temporary login and password. The first time you log in, you will be prompted to create a new password, verify your account information, and view the data collected by your Device. This information is available on your password-protected Wripli account, and it is only accessible by you, Water-Right, and your Dealer. This information is necessary to establish an account so that Water-Right or a Dealer can provide your requested services.

Wripli Website and Mobile Apps

Like most companies, we use cookies and similar technologies on our website and mobile app. We may collect certain aggregate, non-personal information through software applications made available or used by us or when you otherwise use our online services. Aggregate, non-personal information does not relate to a single identifiable visitor. By collecting this information, we learn how many users visited our site and the pages accessed, which then allows us to improve our website for our visitors. Unless you disable such technologies, by using our website and online services, you agree that we can place these types of cookies and related technologies on your Device.

We may collect information typically collected through websites and applications, such as browser and Device information, application usage data, information collected through cookies


and other technologies, and IP addresses. Information collected through cookies includes what is necessary to direct you to the proper server, to help in the prevention of unauthorized access, to assist with your login and to direct you to your data on our servers.

Water-Right Device Sensors

After you have completed setting up your Device, it will begin to collect data related to its function and transmit that data to Water-Right’s central servers located in the United States. This information is necessary so that your Dealer can monitor the performance and diagnostics of your Device and so that we can provide your requested services.

We collect, use, and store data gathered from several sensors built into the Water-Right Device. These sensors collect data including, but not limited to, water quality, hourly water usage, gallons per minute (“gpm”), salt levels, the number of times the water softener has regenerated, sensor status, technical errors, and vacation mode. Every time your water is flowing, Water- Right records the time and gpm used during which your system was on. Water-Right collects, uses, and stores this information so you and the Dealer can detect when there is no or low salt in your Device, when water has not been used for a period of time, whether there is water flow, and if there are physical errors with the Device.

Detecting this information allows Water-Right to notify you if the Device needs to be regenerated, if there is no or low salt in the Device, usage history, or if there is a technical error with your Device.

Direct Adjustments to the Device

If you change settings like “vacation mode” or the “Time of Day” on the Device, it records and feeds that information to the Water-Right servers.

Technical, Electronic, and Diagnostic Information from the Device

Water-Right and the Dealer record your Device model and serial number, software version, technical information such as configuration data, electronic information such as sensor logs, and diagnostic information such as performance alerts. We collect this information to improve your experience over time and help troubleshoot any problem you may encounter with the Device.

Wi-Fi Network Information

To connect your Device to our services, or to access your Device over the Internet from a computer, a smartphone, or a tablet, you will need to connect it to your Wi-Fi network. During setup, the Device will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the Device, along with your IP address, so that you can access it and control it from your computer, smartphone, or tablet, and so that it can communicate with Water-Right servers.

Once connected to your Wi-Fi network, your Water-Right product regularly sends the data described in this Privacy Policy (excluding your Wi-Fi password) to Wripli to provide your requested services.


Customer Service

If you call or email Water-Right or your Dealer for services, questions, or comments, Water- Right may collect your name, phone number, and email address so we can respond to you. You may choose to provide additional information as well, such as your Device’s model number, serial number, nickname for the Device, Device purchase date, or Device installation date.

Product Research and Development

We may use the information we collect to provide, develop, and improve Water-Right’s Wripli Products, including making assessments and recommendations about products or water use. We may use your contact details to send you this information, to ask you to participate in surveys about your use, or to send you other communications from through your Dealer.

We may use information about your Device in an aggregated, de-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated, de-identified customer information about the active Wripli Devices to determine salt and water savings as an aggregate and aggregated water use data to study water use and patterns. We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

Security of Data

We implement security features to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. The data collected by your Device is encrypted during transmission to our servers. Depending on your location and type of data, Water-Right may process your personal information on servers that are not in your home country.

Information Shared With or Received from Third Parties

Water-Right may share information with third parties with your permission. For example, if a Dealer offers a rewards program in which you enroll.

The limited circumstances in which information from your Water-Right account may be shared with third parties are described below in the section titled "Circumstances in which Water-Right May Share My Information".

Any Water-Right data that you choose to share with a third party (including your Dealer) is governed by that third party’s privacy policy while in that party’s possession.

Any data that Water-Right receives from third parties will be processed and stored by Water- Right and will be treated in accordance with this Privacy Policy. This information may be processed in the same way as any other data that is a part of your Water-Right account or the Water-Right logs.


Circumstances in which Water-Right May Share Information

Under no circumstance do we share Personal Information with any third party for any commercial or marketing purpose unrelated to the activation and delivery of Wripli services without your consent.

The following are the limited situations where we may share Personal Information:

· With your consent: We may share Personal Information when we have your consent. For example, if you sign up for programs offered by our Dealers, then we may share certain information with the Dealer. This could include things like your registration information and the activation status of your Device.

· For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage. They may also assist with monitoring our servers for technical problems. These technicians (as well as Water-Right employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Water-Right purposes.

· As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat your data under the Privacy Policy in place at the time of its collection.

· For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so by law. For example, we may disclose information in response to legal process and we may disclose information in response to lawful requests by public authorities in the United States for the purposes of law enforcement and national security.

We may share non-personal information (for example, aggregated or de-identified customer data) publicly, with our Dealers, in advertising, or in publications such as trade journals and magazines. For example, we may publish trends about water use or water quality in the home. This information may also be shared with other users to help them better understand their water usage compared to others in the Water-Right community, raise awareness about consumption, or help us generally improve our services.

If you select an outside party for the purchase, installation, or service of your Water-Right Device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy the Device from a Dealer, the Dealer may collect personal information as part of the transaction. The party that installed the Device may retain information that you provided to them to assist them in servicing the Device if needed. Always check the privacy policies for any company that collects your personal information.


Can the Privacy Policy be changed?

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes on the Wripli website or by contacting you.

Privacy Choices

You are given the opportunity to (i) opt out of receiving communications from us, or (ii) remove your personal information from our records. If you wish to opt out of the collection of your information or of receiving further communications, please contact your Dealer. Please note that if you opt out of the collection of your information, the Wripli system will not work as designed to allow remote monitoring and management of your water treatment Device (including by you), though the water treatment Device will otherwise continue to function normally.

Corrections

You may contact your Dealer or Water Right to modify or correct any of your personal information that is under our control. You may also direct a written complaint regarding compliance with this Privacy Policy to us and, within a reasonable time upon receiving the written complaint, we will conduct an investigation into the matter. We will respond to the complaint within a reasonable amount of time.

Contact Information

Water-Right, Inc. 1900 Prospect Court

Appleton, WI 54914

800-777-1426

www.water-rightgroup.com

If you have any questions, please contact us at privacy@Water-Right.com.