Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how GridSmart collects, uses, stores, discloses, and protects personal information in connection with the GridSmart Device, App, website, cloud platform, installation services, support services, warranty services, and energy optimisation services.

By using GridSmart products or services, you acknowledge that GridSmart may collect and use personal information as described in this Privacy Policy.

2. Information we collect

GridSmart may collect the following types of information.

2.1 Identity and contact information

This may include:

1. name;
2. email address;
3. phone number;
4. account login details;
5. installation address;
6. billing or service address; and
7. customer support history.

2.2 Property and installation information

This may include:

1. installation address;
2. property type;
3. homeowner, tenant, landlord, property manager, builder, or developer status;
4. site access information;
5. installer notes;
6. installation photos;
7. Device location;
8. hot water cylinder information;
9. electrical and plumbing configuration relevant to the Device;
10. safety or suitability notes; and
11. service and maintenance records.

2.3 Energy account and site information

This may include:

1. ICP;
2. electricity retailer;
3. electricity plan or tariff;
4. meter configuration;
5. controlled-load status;
6. network or distribution information;
7. solar, battery, inverter, or other energy asset information; and
8. relevant eligibility information for energy programmes.

2.4 Device and operational information

This may include:

1. Device ID;
2. serial number;
3. firmware version;
4. software version;
5. connectivity status;
6. Device status;
7. heating schedules;
8. Device settings;
9. control events;
10. diagnostic logs;
11. fault codes;
12. temperature information, if collected;
13. element activity, if collected;
14. energy-related operating data, if collected;
15. app settings and overrides; and
16. performance and reliability information.

2.5 App, account, and technical information

This may include:

1. app usage information;
2. login information;
3. customer preferences;
4. notification settings;
5. device type;
6. operating system;
7. IP address;
8. browser or app version;
9. security logs;
10. crash reports;
11. support interactions; and
12. other technical information required to provide and secure the Services.

2.6 Wi-Fi and network information

Where required to connect or support the Device, GridSmart may collect or process Wi-Fi or network information.

GridSmart should only collect Wi-Fi credentials where reasonably necessary to connect the Device or provide support. GridSmart should handle Wi-Fi credentials securely and should not disclose Wi-Fi credentials to Energy Partners for marketing or unrelated purposes.

2.7 Energy control and flexibility information

This may include:

1. control event participation;
2. control event timing;
3. response verification;
4. Energy Partner instructions;
5. flexibility programme participation;
6. tariff optimisation information;
7. settlement or reporting information;
8. opt-out status; and
9. programme eligibility information.

3. How we collect information

GridSmart may collect information:

1. directly from you;
2. through the App;
3. through the Device;
4. through installers or service agents;
5. through Energy Partners;
6. through customer support interactions;
7. through warranty claims;
8. through websites, forms, or digital tools;
9. through authorised third-party service providers; and
10. from publicly or commercially available sources where permitted by law.

4. Why we use information

GridSmart may use information for the following purposes:

1. to assess suitability for installation;
2. to install, configure, activate, and support the Device;
3. to provide the App and cloud services;
4. to monitor Device performance;
5. to optimise hot water heating;
6. to provide Smart Control;
7. to support tariff optimisation;
8. to support demand response, flexibility, grid-support, or energy programmes;
9. to verify control events and performance;
10. to administer participation in Energy Partner programmes;
11. to provide customer support;
12. to diagnose and fix faults;
13. to manage warranty claims;
14. to improve GridSmart products, services, algorithms, and customer experience;
15. to maintain cybersecurity and system integrity;
16. to comply with legal, regulatory, safety, and reporting obligations;
17. to communicate service, safety, account, and operational information;
18. to send marketing where permitted or consented to;
19. to create aggregated or anonymised insights; and
20. to support business planning, analytics, research, and commercial reporting.

5. Who we may share information with

GridSmart may share relevant information with:

1. electricity retailers;
2. electricity distribution businesses or lines companies;
3. aggregators;
4. flexibility service providers;
5. metering providers;
6. data service providers;
7. technology providers;
8. installers;
9. electricians, plumbers, or service agents;
10. cloud hosting providers;
11. software providers;
12. customer support providers;
13. payment providers, if applicable;
14. professional advisers;
15. insurers;
16. regulators or authorities where required or permitted by law;
17. business partners involved in providing GridSmart services; and
18. potential purchasers or investors in GridSmart’s business or assets, subject to appropriate confidentiality and privacy protections.

GridSmart will only disclose information that it reasonably considers relevant for the applicable purpose.

6. Energy Partner data sharing

GridSmart may share relevant information with Energy Partners for purposes including:

1. energy control;
2. hot water optimisation;
3. tariff optimisation;
4. demand response;
5. flexibility services;
6. grid-support services;
7. control event verification;
8. settlement;
9. reporting;
10. troubleshooting;
11. support;
12. compliance;
13. programme administration; and
14. service improvement.

GridSmart will not share your personal information with Energy Partners for their own marketing unless you have separately consented or the disclosure is otherwise permitted by law.

7. Aggregated and anonymised information

GridSmart may use and share aggregated or anonymised information for analytics, research, product development, commercial reporting, energy market insights, network planning, investor reporting, partner reporting, and service improvement.

GridSmart may retain aggregated or anonymised information indefinitely, provided it does not reasonably identify you.

8. Overseas storage and cloud providers

GridSmart may use cloud, software, support, and data providers located in New Zealand, Australia, or other countries.

Where GridSmart discloses personal information to overseas service providers, GridSmart will take reasonable steps to ensure that personal information is protected in a way that is consistent with applicable privacy obligations.

9. Security

GridSmart will take reasonable steps to protect personal information from loss, unauthorised access, misuse, disclosure, alteration, or destruction.

Security measures may include access controls, encryption, authentication, monitoring, logging, secure development practices, restricted access, and supplier security requirements.

No system is completely secure. You are responsible for keeping your app login details secure and maintaining reasonable security for your Wi-Fi network, router, mobile device, and email account.

10. Retention

GridSmart will retain personal information for as long as reasonably required for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Indicative retention periods may include:

1. account and contact information — while your account is active and for a reasonable period afterwards;
2. installation and warranty records — for the warranty period and a reasonable claims period afterwards;
3. Device and control event data — while required for service provision, support, settlement, reporting, compliance, analytics, and product improvement;
4. support records — for a reasonable business and legal period;
5. marketing consent records — while consent is active and for a reasonable evidence period after unsubscribe; and
6. aggregated or anonymised data — indefinitely where it no longer reasonably identifies you.

11. Access and correction

You may request access to, or correction of, personal information GridSmart holds about you by contacting:

info@gridsmart.co.nz

GridSmart may need to verify your identity before responding to a request.

12. Privacy breaches

If GridSmart becomes aware of a privacy breach, GridSmart will assess and respond to the breach in accordance with applicable law.

Where required, GridSmart will notify affected individuals and/or the Privacy Commissioner.

13. Marketing communications

GridSmart will only send marketing communications where it has the required consent or is otherwise permitted by law.

You can unsubscribe from marketing communications at any time using the unsubscribe function or by contacting info@gridsmart.co.nz.

Unsubscribing from marketing does not stop GridSmart from sending service, safety, warranty, legal, operational, or account communications.

14. Changes to this Privacy Policy

GridSmart may update this Privacy Policy from time to time.

GridSmart will take reasonable steps to notify you of material changes.

15. Contact

For privacy questions, access requests, correction requests, or complaints, contact:

info@gridsmart.co.nz