Privacy 
Policy

Last Update: 9 September 2025


1. Introduction

Electryone AI respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we safeguard your information, your rights, and how the law protects you. Please read this Privacy Policy carefully before using any of the services or functionalities provided by Electryone AI.

Electryone AI Limited is registered in England under company number 14508320 (“Electryone”, “we”, “us”, or "our"). This privacy policy applies to the services we provide directly through our website (https://www.electryone.ai/), platform, or via a mobile application available on the App Store or Google Play (collectively referred to as the "Platform").

We also offer our services via other companies under their branding. This policy also explains how our partners may use your information. For ease of reference, we shall refer to any service we offer directly or via a partner as the “Service”.

2. Service and reason for processing your data

We provide a Platform that allows energy asset owners, energy asset installers, manufacturers, energy retailers, service providers and end-users (collectively known as “Users”,“you” or “your”) to control and manage the energy use of energy assets to shift consumption to greener, cheaper periods or export stored energy during expensive periods, within the constraints of the grid and your personal preferences (the “Service” we provide).

The personal information that we collect enables us to:

1. deliver and improve the Service;
2. support you to use the Service;
3. work with your energy company, OEM, TSO, DSO or other relevant party to deliver the Service; and
4. Provide enhanced services and rewards to you (in partnership with third-parties).

Before using the Service, we will ask for your consent before we process your data. We only collect the personal data required to enable us to deliver and support our Service to you.

3. Personal data we collect

To deliver our service, we may collect personal data, including but not limited to:

• Identity and Contact Data about you and how to contact you. This may include:
  • First name and last name
  • Your username or similar identifier in the platform
  • An encrypted version of your password
  • Your social media username (if you interact with us via social media)
  • Your home address, e-mail address(es) and telephone number(s)

• Profile and Consent Data which comprises preferences (for marketing and other notifications), feedback and survey responses you have provided and partly anonymised analytical information about how you use our app. This may include:
  • Your preferences on how and when we can contact you
  • Preferences on your subscriptions to digital marketing and non-marketing communications
  • A record of where you have provided or withdrawn consent to share your data with third-parties
  • Feedback to surveys and questionnaires
  • Feedback provided during design research programmes
  • Partly anonymised data from app and website analytics platforms

• Hardware Data about your energy assets (e.g., Battery storage, EV charger) so we know when to control the asset. This may include:
  • The make, model, trim, registration or licence and VIN of your vehicle
  • The battery size and charging capabilities of your assets
  • The make, model and configuration of your assets
  • The state of charge of your assets
  • The location of your assets
  • If your assets and charger are connected
  • If your assets are charging/powered on
  • If your assets is in a manufacturer service mode
  • If your vehicle is stationary
  • Current and desired temperature

• Energy Data such as your energy retailer, tariff and meter reference number so we can apply the right tariff and grid information to your supply, and, with your explicit consent, collect and use your smart meter data. This may include:
  • Smart meter data (half-hourly consumption and export where available), tariff details, MPAN, meter serial number and meter type (obtained via our smart-meter integration partner).
  • Your energy retailer name and price plan or tariff name
  • Your home energy consumption and production
  • Billing information about your supply such as your energy retailer account number
  • MPAN or Meter Serial Number

• Third-Party Account Data which allows us to link your Electryone account to your battery, vehicle, charger or energy retailer accounts. This may include:
  • Encrypted username and password or access token for a third-party service kept in a secure enclave
  • Account identifiers or references to identify your account in a third-party’s system
  • These data will only be requested and stored after you have provided consent

• Technical Data about the device you use to connect to our platform, your time zone and locale to enable us to tailor the user experience for your asset and to ensure we support the assets you want to use to access the app and platform. This may include:
  • Connection information such as IP address
  • Device geolocation
  • Client information such as the type and version of the asset, operating system, browser and any plugins you may be using
  • Your time zone and locale

• Transaction and Financial Data about your energy usage and for any services you purchase through the platform. This may include:
  • Details of the products and services you have purchased from us
  • Details of how much energy used to charge your electric vehicle, and when this charging happened
  • Payment information made to us from you, including references to your account stored in our payment providers’ system

• Tracking Data which includes information we or others collect about you from cookies and similar tracking technologies such as web beacons, pixels and mobile identifiers. This may include:
  • Includes information we or others collect about you from cookies, user attribution and similar tracking technologies

We may use, collect, and share aggregated data which may be derived from your data, but, as this data does not directly or indirectly reveal your identity, it is not considered personal data in law. For example, we may aggregate your and other users’ battery storage  data to help utilities plan their charging networks.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the Service you have with us but we will notify you if this is the case at the time.

4. How we use your personal data

We only use your personal data when it is lawful to do so. Most commonly, we process your data in the following circumstances:

• Legitimate Interests: When it is necessary for our legitimate business interests (or those of a third party) and your rights do not override these interests. Before processing, we carefully assess any potential impact on you and ensure your rights are respected. For more details about how we evaluate these interests, feel free to contact us.
• Contractual Obligations: When processing is required to fulfill a contract we have with you or to take steps at your request before entering into a contract.
• Legal Compliance: When it is necessary to comply with a legal or regulatory obligation.

We do not use your personal data for automated decision-making or profiling.

4.1 Purposes for using your personal data

Below, we outline the various purposes for which we use your personal data, along with the legal bases we rely on for processing. Where applicable, we also identify our legitimate interests.

Please note that in some cases, we may process your personal data based on more than one lawful ground, depending on the specific purpose. If you would like more information about the specific legal basis we rely on for processing your data, feel free to contact us.

4.2 Promotional offers

We may use your Identity, Contact, Technical, Usage and Profile Data to decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or subscribed to our Services and you have not opted out of receiving that marketing.

4.3 Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4.4 Opting out

We aim to provide you with choices when it comes to how your personal data is used, especially for marketing and advertising. If at any time you wish to stop receiving marketing messages from us or third parties, you can contact us.

Please note that opting out of marketing messages does not apply to personal data that you have provided to us during product/service transactions or experiences.

4.5 Cookies

Cookies are small pieces of data that are stored on your device when you visit our website. They are not used to identify you personally, but to learn about your usage and browsing behaviour.

You can configure your browser to refuse all or some cookies, or to notify you when websites set or access cookies. However, if you disable or refuse cookies, some parts of our website may not function properly. For more information about the cookies we use, please refer to our cookie policy.

4.6 Change of Purpose

Your personal data will only be used for the purposes it was collected for. However, we may use your data for another reason if it's reasonably compatible with the original purpose. Please contact us if you would like an explanation on how the new purpose is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, where required or permitted by law, in compliance with the above rules.

5. Disclosure of your personal data

The data we collect will be stored and used by us and will only be shared with third parties when necessary to provide you with the service, and only as outlined in this privacy policy.

All third parties will be subject to a due diligence assessment and a written agreement with specific terms regarding data security and privacy.

Your personal data may be shared for the reasons and parties set out below:

5.1 Providing our Service

To provide and enhance our Service, Electryone may share your personal information with selected third parties, including service providers, professional advisors, and authorities.

We may also share anonymized data, which does not include your personal information and has location data obfuscated to a larger area, with third parties such as energy companies and distribution system operators. This ensures that you cannot be identified by a third party from any data shared directly from us.

5.2 Legal reasons

We may share personal data to comply with legal obligations, such as court orders or warrants from law enforcement or tax agencies. Sharing may also occur without your permission when a person's life is at risk, or to initiate or defend a legal claim, which may involve disclosure to solicitors, professional advisors, or a court.

5.3 Supporting our Users

To provide you with efficient support, we may need to share your personal data, which may include Identity, Contact, Technical, and Hardware Data as outlined in Section 3, with our suppliers and subcontractors. This data sharing will be limited to the specific details of your inquiry and any supporting information to ensure effective resolution.

5.4 Providing enhanced services and rewards

We may offer you enhanced services and rewards, which may be delivered in partnership with third-party providers.

To confirm eligibility for these services, we may share Energy Data and Contact Data about you with these third-party energy companies:

• Electricity network companies, who deliver the electricity network in your local area;
• Electricity market operators who help balance the grid on behalf of energy generators, network companies and consumers; and
• Energy service providers who provide aggregation or access services to energy markets.

We may also share your email address and contact details to enable us to deliver an enhanced service and/or reward to you.

You can opt-out of any of these enhanced services at any time.

5.5 Business transfer

In the event that we sell, transfer, or merge parts of our business or assets to a third party, we may disclose your information to them. We may also acquire or merge with other businesses. If a change in ownership occurs, the new owners may use your personal data in the same way as outlined in this privacy policy.

We require that all third parties respect the security of your personal data, handle it in accordance with the law, and only process it for specified purposes and in accordance with our instructions. We do not allow them to use your personal data for their own purposes.

5.6 Other reasons

We may share limited personal information with third parties if we determine that it is necessary to meet our legitimate interests, or promotes your interest and does not breach data protection laws. We will make an assessment before sharing any data.

We may also share your contact details with third parties for marketing purposes if you have given consent via your account or another method. We may also share your details with third parties if this is necessary to fulfil a contract with you.

If a third party who has not agreed to our terms of use or privacy policy interacts with our Platform, it is the responsibility of the account holder on our Platform to inform the third party of the integration before they interact with the Service.

6. International Transfers

Our external third parties are located throughout Europe, so their processing of your personal data may involve transferring data between countries.

While this privacy policy is governed by UK and EU GDPR, we ensure a similar degree of protection is afforded to your personal data transfers by implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the relevant country which give personal data the same protection it has in the UK and EU.

Please contact us if you would like more information on the specific mechanism we use when transferring your personal data.

7. Security of your personal data

We have implemented security measures to protect your personal data from unauthorized access, accidental loss, alteration, disclosure, or misuse. Access to your data is restricted to employees, agents, contractors, and third parties who have a legitimate business need and are bound by confidentiality obligations.

We have established procedures to respond to any suspected data breaches. Both you and any applicable regulator will be notified of a breach in accordance with legal requirements.

We will take appropriate technical and organizational measures to protect your data against loss, misuse, or alteration.

To protect your account and personal information, ensure that your password is not easily guessed. You are responsible for maintaining password confidentiality. We will never ask for your password except when you log in.

We will not ask you to share sensitive information, such as bank details, for identity verification purposes. If anyone claiming to represent us requests such information, please contact us immediately using the provided contact details below.

8. Retaining and deleting personal data

Your personal data is retained only as long as it's necessary for the purposes it was collected, including legal, regulatory, tax, accounting, or reporting requirements. This retention may be extended in the event of a complaint or potential litigation. We periodically conduct ad-hoc reviews to delete unnecessary data.

To determine the appropriate retention period, we consider various factors, including the amount, nature, and sensitivity of the data; potential risk of harm from unauthorized use or disclosure; the purposes of processing; and applicable legal requirements.

Users can request account deletion by contacting us. However, there may be circumstances where we're legally required to retain some data, such as participation in a Grid Support project. For any questions about data we cannot delete, please contact us.

In some cases, your personal data may be anonymized for research or statistical purposes, which we may use indefinitely without further notice.

9. Your legal rights

You have the following rights concerning your personal data:

1. The right to access: You can request a copy of the personal data we have about you to verify that we are handling it lawfully.
2. The right of rectification: If you believe our data about you is inaccurate or incomplete, you can request that we correct it. We may need to verify the accuracy of the new information you provide.
3. The right of erasure: You can ask us to delete your personal data if there's no good reason for us to keep processing it, if you've successfully objected to our processing, if we've processed your data unlawfully, or if we're required to erase it by law. Note that there may be legal reasons why we can't always fulfill your erasure request.
4. The right to object: You can object to us processing your personal data if we're relying on a legitimate interest (or that of a third party) and you feel it impacts your fundamental rights and freedoms. You can also object if we're processing your data for direct marketing. In some cases, we may have compelling legitimate grounds to continue processing your information that override your objection.
5. The right to restrict processing: You can ask us to suspend processing your data if:
   • You want us to verify its accuracy
   • Our use of the data is unlawful, but you don't want us to erase it
   • You need us to keep the data for legal claims, even if we no longer need it
   • You've objected to our use of your data, and we need to verify if we have overriding legitimate grounds to use it

1. The right of data portability: You can request that we transfer your personal data to you or a third party in a structured, commonly used, machine-readable format. This right only applies to automated information you initially consented for us to use or that we used to fulfill a contract with you.
2. The right to withdraw consent: If you've given us consent to process your data, you can withdraw it at any time. This won't affect the legality of any processing we did before you withdrew consent. However, withdrawing consent may mean we can't provide certain products or services to you.

Contact us if you would like to exercise any of these rights.

We may charge a reasonable fee if your request is unfounded, repetitive, or excessive, or we may refuse to comply with your request.

We may ask you for specific information to confirm your identity and your right to access your data. This is to ensure that your data isn't disclosed to someone who doesn't have the right to it. We may also ask you for more information to speed up our response.

We try to respond to all legitimate requests within a month. If your request is complex or you have made multiple requests, it may take us longer. If this happens, we'll let you know and keep you updated.

10. Job applicant’s privacy

In order to process your application, we ask you to provide certain personal data, also referred to as personally identifiable information (PII). The legal basis for processing your PII is by consent and therefore providing it is voluntary, however, some are required for us to properly consider your application. If you were not successful in your application, we will keep a copy of it for a period of 6 months from the closing date of the role you have applied for.

We may collect, store, and use the following categories of information about you during the application phase:

• Personally Identifiable Information: We collect your personal contact details such as name, address, email address and telephone number. We also collect contact information for your references; it is your responsibility to obtain consent from your references before providing their personal information to us.
• Sensitive Data: We ask you not to disclose any sensitive personal data during the application phase as we do not feel this required.
• Internet or Other Electronic Network Activity Information: Our website uses cookies - see Section 4.

We may use third party service providers to assist with our application procedure and only share data where appropriate measures are in place to protect the security of your data

11. User research

We undertake regular user research in order to guide the development of our Service. The data collected will only be used for research purposes and never sold to third parties. We record the user interviews to enable post-review, however these are deleted as soon as they are no longer relevant or after a period of three years (whichever is soonest). If we transcribe your interview, then we will retain this following the expiry of three years, however we will anonymise all personally identifiable information. We will, at all times, keep research source materials secure.

12. Children’s privacy

These Services do not address anyone under the age of 16. We neither target, or knowingly collect personally identifiable information from children under 16. In the case we discover that a child under 16 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to perform the necessary actions.

13. Third-party users

There may be occasions when a third-party who has not agreed to our terms of use or privacy policy will interact with our service, either by way of an integrated vehicle or an integrated charger. It is the responsibility of the account holder to ensure that third-parties are made aware of the integration prior to interacting with our service.

14. Contact us

If you have any questions about this privacy policy or our practices, please contact us via email at support@electryone.ai or by post at 3rd Floor, 86-90 Paul St, Shoreditch, London, United Kingdom, EC2A 4NE. We aim to acknowledge complaints within 5 working days and provide a resolution promptly. If you remain unsatisfied, you have the right to escalate your complaint to the UK Information Commissioner’s Office (ICO) (www.ico.org.uk). The data protection authorities in the European Union are here. For countries that are not compliant with the UK or EU GDPR, you may contact the relevant authority in your country.