Last updated: July 2026

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This Privacy Policy applies to the Escea SmartHeat mobile application (“SmartHeat” or “the App”). For our general website privacy policy, please visit escea.com.

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Escea Limited (“Escea”, “we”, “us”, or “our”), incorporated in New Zealand (17 Carnforth Street, Dunedin 9018), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information when you download and use the SmartHeat application to control your Escea fireplace.

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This Policy applies to users in New Zealand, the European Union, the United Kingdom, the United States (including California), and all other regions where the App is available.

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By downloading or using the App, you acknowledge that you have read and understood this Policy. If you do not agree, please do not use the App. For questions, contact us at info@escea.com.

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1. Information We Collect

1.1 Information You Provide

When you register for or use the App, you may provide:

• Name and email address (account registration)
• Password (stored in encrypted form — we do not have access to your plain-text password)
• Device and fireplace pairing information

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1.2 Information Collected Automatically

When you use the App, we automatically collect certain technical information:

• Device identifiers and model information
• Operating system type and version
• App usage data (features used, session frequency, error logs)
• IP address
• Approximate location (derived from IP address or, if you grant permission, device GPS for fireplace connectivity purposes)

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You can disable location access in your device settings at any time. Note that some App features (such as local network-based fireplace control) may not function correctly without it.

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1.3 Information We Do Not Collect

We do not intentionally collect:

• Sensitive personal information (health data, government identifiers, financial data)
• Personal information from children under the age of 16
• Login credentials in plain text

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2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing and operating the App and its features
• Enabling you to connect and control your Escea fireplace
• Maintaining the security, stability, and performance of the App
• Diagnosing and resolving technical issues
• Improving App functionality through internal analytics and reporting
• Sending push notifications related to your account or App features (you may opt out in your device settings)
• Complying with applicable legal obligations

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3. Lawful Bases for Processing (EU & UK GDPR)

Where we process personal information relating to individuals in the European Union or United Kingdom, we rely on one or more of the following lawful bases:

• Performance of a contract — processing is necessary to provide the App’s core functionality (account creation, fireplace control, and technical support).
• Legitimate interests — for maintaining App security, diagnosing technical issues, improving performance through pseudonymous analytics, and preventing fraud. These interests do not override your rights.
• Consent — for linking your account to a smart home platform (Amazon Alexa or Google Home) and for non-essential push notifications. You may withdraw consent at any time, either by unlinking the platform or through your device settings.
• Legal obligations — where processing is required to comply with applicable law.

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4. Disclosure of Personal Information

We do not sell your personal information. We may share your information with trusted third-party service providers who assist us in operating the App, including:

• Cloud hosting and infrastructure providers
• Analytics tools used for App performance monitoring
• Customer support platforms (such as Zendesk)
• Crash reporting and diagnostics tools

These providers process personal information only as directed by us and are required to maintain appropriate confidentiality and security. We may also disclose personal information where required by law, or to protect the rights and safety of Escea or others.

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Where you choose to link your fireplace to a smart home platform, we also share information with Amazon or Google as described in Section 5. Those companies act as independent controllers of the information they receive.

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5. Smart Home Integrations (Amazon Alexa and Google Home)

The SmartHeat App lets you link your Escea account to Amazon Alexa and Google Home so you can control your fireplace through those platforms. Linking is optional and only happens when you choose to set it up. We rely on your consent as the lawful basis for this integration, and you can unlink at any time.

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Linking and What We Share

When you link your account to Alexa or Google Home, we share the information needed to connect and operate your fireplace: your fireplace’s reported state (for example, whether it is on or off), a unique identifier for your Escea account, and the authentication tokens used to establish and maintain a secure connection between your account and the platform.

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What We Store

For Amazon Alexa, we store the access and refresh tokens that keep your account connected. These tokens are tied to your Escea account, refresh automatically while the link is active, and are deleted automatically when they expire. For Google Home, we do not store any information received back from Google.

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Voice Commands and Platform Data

Voice commands (such as asking Alexa or Google to turn your fireplace on) and any information you provide directly to Amazon or Google are processed by those companies as independent data controllers under their own privacy policies, not ours. We recommend you review the Google Privacy Policy (policies.google.com/privacy) and the Amazon Privacy Notice (amazon.com/privacy).

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Unlinking

You can unlink your fireplace at any time, either in the SmartHeat App or from within Alexa or Google Home. When you unlink Alexa, the stored tokens stop refreshing and expire. We do not hold any Google data to remove. Any information retained by Amazon or Google after you unlink is governed by their privacy policies, not ours.

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6. International Data Transfers

Escea is based in New Zealand. Some of our third-party service providers process data in other countries, including the United States.

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New Zealand has been recognised by the European Commission as providing an adequate level of data protection, so personal information may be transferred from the European Economic Area (EEA) to New Zealand without additional safeguards.

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Where personal information is transferred to service providers in the United States or other countries not covered by an adequacy decision, we rely on the European Commission’s Standard Contractual Clauses (SCCs) or equivalent lawful transfer mechanisms, together with additional safeguards where required.

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7. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by law. Specifically:

• Account data is retained for as long as you maintain an account with us. Upon account deletion, your personal data is removed from active systems within a reasonable period, subject to legal retention requirements.
• Diagnostic and connection logs that record only fireplace serial numbers do not identify an individual — serial numbers link to retailers, not to customers — and are retained for operational and diagnostic purposes.
• Other automatically collected data, such as your IP address and approximate location, is retained only for as long as necessary for security, connectivity, and analytics purposes, after which it is deleted or anonymised.
• Data retained for legal compliance (such as warranty records) is kept for the duration specified at the time of collection and deleted thereafter.

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When personal data is no longer required, it is permanently deleted. Further details of our data retention practices are available on request.

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8. Your Rights (EU & UK GDPR)

If you are located in the European Union or United Kingdom, you have the following rights regarding your personal information:

• Right of access — to request a copy of the personal information we hold about you.
• Right to rectification — to request correction of inaccurate or incomplete information.
• Right to erasure — to request deletion of your personal information (“right to be forgotten”).
• Right to restrict processing — to request that we limit how we use your data.
• Right to object — to object to processing based on legitimate interests.
• Right to data portability — to receive your data in a structured, machine-readable format.
• Right to withdraw consent — where consent is the basis for processing, you may withdraw it at any time.
• Right to lodge a complaint — with your local data protection supervisory authority.

To exercise any of these rights, please contact us at info@escea.com or through our EU Representative (see Section 14). We will respond within one month.

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A list of EU data protection authorities is available at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

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9. Your Rights (California — CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA):

• Right to know — the categories and specific pieces of personal information collected, the sources, purposes, and categories of third parties with whom it is shared.
• Right to access — the personal information we hold about you.
• Right to deletion — of personal information we have collected, subject to legal exceptions.
• Right to correct — inaccurate personal information.
• Right to opt out — of the sale or sharing of personal information. Escea does not sell personal information.
• Right not to be discriminated against — for exercising your privacy rights.

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To exercise your California privacy rights, please email info@escea.com. We will respond to verified requests within 45 days.

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10. Security

We implement reasonable and appropriate technical, administrative, and physical safeguards to protect your personal information from loss, misuse, unauthorised access, disclosure, alteration, or destruction. While no system is completely secure, we continuously review and improve our security practices.

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Transmission of data to and from the App is at your own risk. We recommend accessing the App only within secure network environments.

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11. Do-Not-Track and Global Privacy Control

The App does not currently respond to Do-Not-Track (DNT) signals from mobile operating systems, as no uniform technical standard for DNT has been finalised. We will update this Policy if a recognised standard is adopted that we are required to follow.

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Where applicable under California law, we recognise browser-based Global Privacy Control (GPC) signals on our website. GPC is not currently applicable to mobile applications.

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12. Children’s Privacy

The SmartHeat App is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided personal information to us, please contact us at info@escea.com and we will take prompt steps to delete that information.

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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App’s functionality, or applicable law. The updated version will be indicated by a revised “Last updated” date at the top of this Policy. Where changes are material, we will provide notice through the App or by other appropriate means.

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14. Contact Us

For questions or concerns about this Privacy Policy or how your information is handled:

Escea Limited

17 Carnforth Street

Dunedin 9018, New Zealand

info@escea.com

+64 3 478 8220

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For individuals located in the European Union, Escea has appointed the following representative under Article 27 of the EU GDPR:

EU Representative

Mike Van Loon — European Sales Manager

Escea Fireplaces, Boulevard du Régent 54 PMB, Bruxelles, 1000

mike.vanloon@escea.com

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EU residents may contact our representative for matters relating to the processing of their personal data or to exercise any rights under the GDPR.

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