This document describes how we at Polarium Energy Solutions AB and subsidiaries of Polarium (jointly “Polarium”) handle the data generated by our products and services, in compliance with EU Data Act (Regulation (EU) 2023/2854). For personal data, our Privacy Policy applies.

• Connected Product: An item that obtains, generates or collects data concerning its use or environment and that can communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the user.

• Related Service: A digital service which is connected with the product at the time of the purchase in such a way that its absence would prevent the connected product from performing one or more of its functions, or which is subsequently connected to the product by the manufacturer or a third party to add to, update or adapt the functions of the connected product.

• User: The natural or legal person who owns or operates the product or service.

• Data Holder: Polarium, as the party storing or processing the product/service data. has the right or obligation, in accordance with this Regulation, applicable Union law or national legislation adopted in accordance with Union law, to use and make available data, including, where contractually agreed, product data or related service data which it has retrieved or generated during the provision of a related service.

The product primarily propagates all telemetry and other product related data to the Polarium Home cloud services hosted on AWS EU West.
After installation and configuration the product emits a stream of device information essential for the intended services to function. As long as the device has internet connectivity data is streamed in near real-time.

Secondary, user data is generated by the app via the collection of usage and behavior related information.

The system uses a relational store for account and device metadata, a time-series store for telemetry, object storage for files and backups, and a log store for operational logs. All data is encrypted at rest and in transit.

Technical and operational data: battery charge/discharge levels, energy flow, grid connection state, error codes.

Environmental data: temperature, voltage, frequency

User interaction data: app settings, scheduling preferences, remote control actions.

Metadata: device identifiers, firmware version, timestamps.

Granularity: Variable depending on mode. During Service Mode (typically
installation and during troubleshooting) the device emits:

• During Service Mode (typically installation and during troubleshooting) the device emits:
  • • node_data: 60 message per Pulse device installed per minute
    • ems_data (Data related to operations for charging, discharging and control of the
      device): 6 messages per minute
    • metric_data: 12 messages per minute
    • settings_data: 1 message per minute
    • status_report: 1 message per minute
• During Normal Mode (standard operations mode) the device emits:
  • node_data: 1 message per measurement device installed per minute
  • ems_data (Data related to operations for charging, discharging and control of the
    device): 6 messages per minute
  • metric_data: 1 message per minute
  • settings_data: 1 message per minute
  • status_report: 1 message per minute
• During FCR mode (when the device has been configured for FCR services):
  • Normal operations messages
  • fcr_data: 12 messages per minute

Volume: approximately 5MB per device per day.

Format: MQTT/protobuf

Aggregation: Aggregations of data are made per 15 minutes, per month and then per year.
Detailed granularity is kept for 6 months to allow troubleshooting, and is then downsampled. Some data is kept to allow for warranty claim verification.

Storage location: AWS EU West

Security: Encrypted at rest (AES-256) and in transit (TLS 1.3/1.2).

Polarium will retain personal information in accordance with customer instruction, customer
agreement and for as long as necessary to provide the Polarium Service and for Polarium’s
legitimate and essential business purposes, such as:

• Maintaining the performance of the Polarium Service.
• Making data-driven business decisions about new features and offerings.
• Compliance with our legal obligations.
• Dispute resolution.
• Unless otherwise agreed, Polarium will purge all personal data at the latest 7 years after
  termination of contractual relationship with a customer.

For Polarium Home the following applies:

• Telemetry (raw): 6 months, then downsampled.

• Telemetry (aggregated): for the contract term to support history views; anonymised
  statistics may be kept thereafter.

• Account & device metadata: for the contract term + up to 12 months for
  billing/dispute handling.

• System logs: retained for 60 days for troubleshooting/forensics.

• Warranty records: as required by applicable law or contract.
  • If a longer period (e.g., up to 7 years) is required by law or for defence of legal
    claims, Polarium documents the basis and limits access to that purpose only.

We will use the data to:

• To enable the use of and administration of Polarium digital services (end users)
• Provide customer support, warranty claims and other inquiries
• Product and service development
• Comply with legal obligations

Below is a general explanation of each “legal basis” allowing Polarium to process this data.

• Legitimate interest: If Polarium or a third party has an interest in using
  your personal data in a certain way that is necessary and justified, taking into account
  possible risks to you and other Polarium users. This includes, for example, using your usage
  data to improve the Polarium service for all users. You may always contact us learn more
  about a specific reason.

• Performance of a contract: Where it is necessary for Polarium (or a third
  party) to process your personal data in order to: enter into a contract with you or perform
  the obligations arising from a contract with you.

• Consent: When Polarium asks you to actively consent to Polarium’s use of
  your personal information for a specific purpose.

• Compliance with legal obligations: If Polarium needs to process your
  personal data to comply with a law or regulation that applies to us.

Customer can request access to their data by submitting a requested to Polariums customer support.
The data can be exported in JSON format via the support request.
Users can request deletion via a support request, deletion occurs within 14 days from active systems and within 30 days from backups.

Polarium Energy Solutions AB, Solnavägen 3H (6th floor) 113 63 Stockholm, Sweden

For questions about information under this notice, please contact digital@polarium.com.