Product Registration

1.1 This privacy policy (“Privacy Policy”) sets out our Personal Data collection and sharing practices for our Product Registration Tool (“PRT”). This Privacy Policy is intended to inform you (as a user of the PRT) of the ways in which we collect your Personal Data, how we use your Personal Data and the ways in which we will share any Personal Data you provide to us. It also explains the ways that you can manage your Personal Data, including the right to object to certain types of processing we carry out. See paragraph 6 below for more information on your rights as a data subject.

1.2 Mitsubishi Electric Europe B.V. (“we”/“our”/ us”) is the data controller for the PRT, which means we are responsible for processing your Personal Data.

1.3 If you have any questions about this Privacy Policy, please contact our Data Protection Officer using the details set out below:

Full name of legal entity: Title: Mitsubishi Electric Europe B.V., operating through its branch in England (registered number FC019156, BR003391) Data Management Team

DPO email address: dmt@meuk.mee.com

Postal address: Mitsubishi Electric Europe B.V., Travellers Lane, Hatfield, Herts, AL10 8XB United Kingdom

Telephone number: +44 1707 278877

1.4 The PRT may contain links to third‑party websites. If you follow a link to any of those third‑party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Data.

1.5 In this Privacy Policy when we refer to:

(a) “Applicable Data Protection Law” we mean:

(i) to the extent UK GDPR applies to our processing of your Personal Data, the law of the United Kingdom or a part of the United Kingdom; and

(ii) to the extent EU GDPR applies to our processing of your Personal Data, the law of the European Union or any member state of the European Union to which we are subject,

which in either case relates to the protection of Personal Data. (“EU GDPR” means the General Data Protection Regulation ((EU) 2016/679) and “UK GDPR” has the meaning given in the UK Data Protection Act 2018.)

(b) “Installers” means an independent professionally qualified engineer with recognised qualifications within the HVAC industry accredited under our Partner Programme who use the PRT to register installations.

(c) “Homeowners”, “Private Landlords”, “Social Landlords”, “Tenants”, “House Builders” means users who register or manage products installed at a Property.

(d) “Partner Programme” means our accreditation program for Installers who provide services in relation to the Products.

(e) “Personal Data” we mean as it is defined in Applicable Data Protection Law.

(f) “Product(s)” means the range of “Ecodan” air source heat pumps and Cylinders manufactured by Mitsubishi Electric and its affiliates.

(g) “Property” means the Property (located in England, Wales, Scotland or Northern Ireland) for which the Product(s) are installed.

(h) “you”/ “your” means collectively the users of the PRT Tool.

1.6 This Privacy Policy is intended to explain our privacy practices and covers the following areas:

(a) What Personal Data we collect about you

(b) How we share your Personal Data

(c) How we use your Personal Data

(d) How we store your Personal Data

(e) Contacting us & your rights in relation to your Personal Data

(f) Our Cookies Policy

(g) How changes to this Privacy Policy and the Cookies Policy will be made

2.1 We will collect and process the following Personal Data:

(a) Contact and Account Data

Personal Data that you provide to us. These are;

· Name

· Email address

· Telephone number

· Account type (Installer, Homeowner, Social / Private Landlord, Tenant, House Builder)

· Company name (if Installer, House Builder or Social Landlord)

· Password

(b) Property Data

Personal Data that you provide to us. These are;

· Property address

(c) Product Data

Personal Data that you provide to us. These are;

· Product model code

· Product serial number

(d) Installation Data

Personal Data that is provided to us. These are;

· If the Property is a New Build

· House builder company name (if applicable)

· Property type (Flat, House etc)

· Installation location

(e) Marketing data

· Your marketing preferences (Homeowner and Private Landlord only)

2.2   QR code scanning and technical data. As part of the product registration process, we may use QR code scanning to capture product serial numbers and model information. This process is designed to reduce manual data entry and improve accuracy. The QR code scanning functionality does not result in the collection of additional personal data from your device beyond standard technical information (such as IP address or basic log data) that is typically generated when accessing an online service, as described in our Cookies Policy.

2.3 We do not collect any special categories of Personal Data about you (details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any data about criminal convictions and offences.

3.1 We will share your Personal Data for the purposes we explain in this Privacy Policy to third parties.

3.2 We will share the Installer’s Company Name with Homeowners who claim a Product in the PRT that was originally registered by an Installer. This is necessary to help Homeowners identify the Installer responsible for the original installation and to support warranty period validation as per the Installers Partner status.

3.3 We share the Installers, Homeowners, Private Landlords, Social Landlords, Tenants, House Builders Personal Data with:

(a) Royal Mail AddressNow. When you start to enter an address, we use Royal Mail’s AddressNow service to validate and autocomplete the full address. This requires sending the partial address information (e.g., postcode or address fragments) to Royal Mail so they can return accurate address suggestions. We only send property address data to Royal Mail for this service. Royal Mail acts as an independent data

controller for this processing and handles this data in accordance with its own privacy policy, available at: https://addressnow.royalmail.com/; and

(b) Third party sub-processors, Microsoft. We store and process Personal Data in our Microsoft Dynamics 365 Customer Relationship Management (CRM) platform. Microsoft acts as our data processor, providing cloud hosting, data storage, workflow automation and analytics tools.

(c) Third party sub-processors, Kwiboo Limited. Kwiboo provides platform hosting and technical support services for the PRT. Kwiboo acts as our data processor and processes Personal Data strictly under our instructions.

3.4             International transfers

Some of our service providers may process Personal Data outside the United Kingdom or European Economic Area. Where this occurs, we ensure appropriate safeguards are in place to protect your Personal Data in accordance with applicable data protection law. These safeguards may include approved contractual protections, such as Standard Contractual Clauses, and additional assessments of the data protection standards applied by the recipient.

4.1 In this paragraph, we set out the purposes for which we use your Personal Data that we collect from your use of the PRT and, in compliance with our obligations under Applicable Data Protection Law, identify the lawful bases on which we rely to process the Personal Data.

4.2 These lawful bases are set out in Applicable Data Protection Law, which allows companies to process Personal Data only when the processing is permitted by the specific “legal grounds” set out in law.

4.3 The following table sets out the lawful basis we rely on for processing each type of Personal Data, as well as the purpose for the processing.

Where we rely on “consent”:

Where we rely on 'contractual necessity':

Where we rely on “legitimate interests”:

4.4            Where we process Personal Data to register products, administer warranties, provide warranty related communications, or support product servicing, our lawful basis for processing is contractual necessity. This processing is required in order to provide the warranty and associated services requested by you in connection with the registered product.

4.5             Where we send marketing communications, we rely on your consent (Homeowners and Private Landlords only). You can withdraw your consent at any time using the unsubscribe options provided in communications or by contacting us.

5.1  We retain Personal Data relating to the Product Registration Tool only for as long as necessary to fulfil the purposes for which it was collected, including product registration, warranty administration, customer support, and compliance with legal obligations. Personal Data relating to registered products is retained for up to 15 years, reflecting the anticipated product lifecycle and related legal and customer service requirements. Once Personal Data is no longer required for these purposes, it is securely deleted or anonymised in accordance with our data retention and disposal procedures.

Your rights

6.1 If you have any questions in relation to our use of your Personal Data, you should first contact us as per the “GDPR Contacting Us” form. Applicable Data Protection Law gives you the following rights in respect of Personal Data we hold about you. These rights may vary depending on our lawful basis of processing:

(a) request access to and to be provided with a copy of Personal Data, including the categories of your Personal Data we collect and disclose (right of access to your Personal Data);

(b) ask us to rectify any inaccuracies in the Personal Data we hold (right to rectify your Personal Data);

(c) ask us to delete any Personal Data that we no longer have a lawful ground to use (right of deletion of your Personal Data/right to be forgotten);

(d) where processing is based on consent, to withdraw your consent at any time so that we stop that particular processing (right to withdraw consent to processing);

(e) object to any processing based on the legitimate interest ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights (right to object to processing);

(f) ask us to restrict how we use your information (right to restrict processing); and

(g) ask us to transfer your Personal Data you gave us to another organisation, or to you (right of data portability).

6.2 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond within a month. If the request is complex, this timeline may be extended to three months.

6.3 If you are not satisfied with our use of your Personal Data or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office, the UK regulator, or any other competent data protection supervisory authority. You can contact them by calling 0303 123 1113. Or go online to ico.org.uk/make-a-complaint/ (opens in a new window; please note we are not responsible for the content of external websites).

Contacting us

6.4 If you have any questions in relation to this policy, please contact us as per the “GDPR Contacting Us” form or contact our Data Management Team whose details are at paragraph 1.3 above.

7.1 We use cookies in the PRT. To find out more about how we use cookies, please see our Cookies Policy.

8.1 We may change the content of the PRT and how we use cookies, and consequently our Privacy Policy and our Cookie Policy may change from time to time in the future. If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below.

8.2 This Privacy Policy was last updated on 30th March 2026. V0.1.