Privacy Policy ✓ What Data Polarium® Collects and how it's Used

1. Overview

This Privacy Policy describes how we at Polarium Energy Solutions AB and subsidiaries of Polarium (jointly“Polarium”) and our products may process your personal data. Below, we’ll refer to it simply as a “policy.”

2. Purpose

This policy describes how Polarium typically may process personal data as well as what data our products generate and collect. If you make a “data subject access request” we are obliged to inform you more specifically about what personal data we process about you specifically. See more under “right to access”.

3. Scope

This policy covers:

Any use of our website
Any use of our app
Any purchase from us
Any use of our products or services

For information about data generated by our products and services that do not constitute personal data, please see Polarium Data Act Notice.

4. Roles and responsibilities

Who is responsible for performing the work described? Who is responsible for reporting the work? This section defines the policy’s audience, i.e. who will be qualified to perform the work described

Role

Responsibility

Data Protection Manager

	Monitor compliance with this Privacy Policy and applicable data protection laws. Provide guidance on data protection obligations. Act as the primary point of contact for supervisory authorities and data subjects.

Data Controllers / Process Owners

	Determine the purposes and lawful basis for processing personal data. Ensure that processing activities under their responsibility follow this policy and legal requirements.

Data Processors (Internal or External Service Providers Acting on Behalf of the Controller)

	Process personal data only on documented instructions from the Data Controller. Implement appropriate technical and organizational measures to protect personal data.

All Employees and Contractors Handling Personal Data

5. Your personal data and your rights

Many data protection laws give individuals rights in relation to their personal data. These laws include the General Data Protection Regulation, or GDPR. Some rights apply only if Polarium uses a specific “legal basis” to process your data. We explain each legal basis below.

Right to access: You are entitled to know what personal data we are processing about you, for what purposes we are processing the personal data, and with whom we share your personal data, among other details. You also have the right to gain access to your personal data and request a copy of such data. You can request a “data subject access request” to get this information by reaching out to privacy@polarium.com. With respect to system generated data a majority of the data is available via our services shared with you as a customer. Unavailable data will be made available upon request, like personal data.

Right to rectification: If you notice that we have incorrect or incomplete personal data about you, you can always request that we correct or complete such personal data.

Right to erasure and restriction: In certain instances, you may request that we delete your personal data or restrict our processing of it for a specified period. Please note that deletion or restriction of your personal data may result in us not being able to provide you with access to our website or all its services, provide you with information, or respond to your messages and questions.

Right to object: In some instances, you have the right to object to the processing. For example, you may object to the processing that we perform based on our legitimate interests or for direct marketing purposes.

Right to data portability: In cases when we base our processing on your consent or the fulfilment of an agreement with you, you are entitled to extract your personal data in a structured, commonly used and machine-readable format and to transfer the personal data to another controller.

Withdrawal of consent: If you have given your consent to the processing of your personal data for an explicit purpose, you may always withdraw your consent. If you wish to withdraw your consent, please get in touch with us using the information provided below.

If you have questions regarding how we process your personal data, you are welcome to contact us at privacy@polarium.com. If you have any objections or complaints about the way we process your personal data, you also have the right to file any complaints you may have regarding our processing of your personal data with the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten), or the supervisory authority in any other EU member state.

6. Personal data we may collect about you

The data collected and processed by Polarium Energy Solutions AB depends on the relationship you have with us and how you engage with us. Polarium Energy Solutions AB does not collect any data without a valid legal basis and purpose.

The following are the different categories of personal data and product data that we may process together with information about what data such a category may entail.

6.1 About you

Contact Information: Your name, email address, physical address, phone number, employer, job title
Communication data: Communication with us via our sales, marketing and service functions
Marketing Preferences: Information about your preferences for receiving marketing communications from us.
Payment data: Payment methods and billing address
Purchase data: Data about your purchases of our product and services
Website Device and Usage Data: information about your interactions with our website, including cookie data, IP address or other identifiers, browser type, and operating system. (Please see section on Cookie Policy)
Job applicant data: your CV, references, personal letter and any other data provided during your application.
Product generated personal data: household energy consumption and production, household power infrastructure (ie fuse sizes, partial power topology, grid owner and power distributor and general application usage information)
Other data: Any information you may have voluntarily chosen to share.

6.2. About your use of our product/s and service/s

Metadata: device identifiers, firmware version
Telemetry data: Battery charge/discharge levels, energy flow, grid connection state and error codes
User interaction data: App settings, scheduling preferences and remote-control actions, connectivity configuration (WiFi)

6.3. Data we get from third parties

We may collect personal data or company data from available sources when relevant for legal proceedings

7. Purpose of using your personal data

This section includes information about:

Purpose of processing your personal data;
Legal justifications (each referred to as the legal basis) according to the General Data Protection Regulation for each purpose; and
Categories of personal data we use for each purpose.

Below is a general explanation of each “legal basis” to help you understand the table:

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.

Note that most of our Products are sold to professional end users and as such processing of personal data of natural persons is very limited. If you have any questions about this please contact us at privacy@polarium.com.

Purpose of processing your data	Legal basis that allows the purpose	Categories of personal data used for this purpose	Data retention
For delivery and installation of Polarium products	Art. 6 (1) b GDPR, where the processing of personal data is necessary for the performance of a contract to which a Customer is a party, specifically to deliver and install the purchased Polarium products in accordance with the agreed terms.	Corporate Customers: Contact information to a relevant person at the Customer. End Users: Polarium will not process personal data about end users for delivery and installation of Polarium Residential Products.	For as long as necessary to fulfil relevant purpose(s). Unless otherwise agreed, all personal data will be purged no later than seven years after the termination of the contractual relationship with the customer.
To enable the use of and administer Polarium digital services (end users)	Art. 6 (1) b GDPR, where the processing is necessary for performance of a contract with you, specifically in order to provide access to and administer the Polarium digital services as agreed under the contractual relationship.	Email-address and password for the Customer Contact Person (typically not a natural person end-user) and information about the battery such as settings, energy consumption and diagnostics data as well as non-granular information about approximate positioning (through the cellular connection). If the battery is connected to a Wi-Fi network, the network’s SSID and password are processed. We may also collect data about individual’s usage of the app, logins, errors, etc.	For as long as necessary to fulfil relevant purpose(s). Unless otherwise agreed, all personal data will be purged no later than seven years after the termination of the contractual relationship with the customer.
Providing customer support, warranty claims and other inquiries or obligations with the Customer Contract	Art. 6 (1) b GDPR, where the processing is necessary for performance of a contract with you. Otherwise, the processing of your data otherwise occurs on the basis of Art. 6 (1) lit. f GDPR, based on our legitimate interest in providing you with the best possible customer support. Our overall assessment of the processing is that it is necessary and proportionate for the purpose. More information about our legitimate interest assessment can be provided upon request.	Personal data as provided by the customer from case to case, for example name, email address and serial number. For Corporate Customers with professional end users typically this would be the contact person(s) at the Corporate Customer.	For as long as necessary to fulfil relevant purpose(s). Unless otherwise agreed, all personal data will be purged no later than seven years after the termination of the contractual relationship with the customer.
Product development	Art. 6 (1) f GDPR, where our legitimate interest is to optimize and ensure the stability of our services. Our overall assessment of the processing is that it is necessary and proportionate for the purpose. More information about our legitimate interest assessment can be provided upon request.	Personal data contained in technical analyses, logs and information on the use of the Polarium Home Companion App or Polarium Home battery. Typically this data will be anonymized prior to use for product development purposes, unless necessary to store for another purpose.	For as long as necessary to fulfil relevant purpose(s). Unless otherwise agreed, all personal data will be purged no later than seven years after the termination of the contractual relationship with the customer.
Managing applications for recruitment purposes	During the recruitment process – Art. 6 (1) f GDPR – our legitimate interest to handle the applicant’s personal information to find the best candidate for the open position. For more information about our legitimate interest assessment, please contact privacy@polarium.com Once a candidate is chosen the personal data is processed in accordance with Art. 6 (1) b GDPR, since the processing is necessary to enter into a contract with you.	Contact information, CV, Personal Letter, result of personally tests and other tests, other information that may be provided during a recruitment process.	Data will be stored until conclusion of a recruitment process for the person that signs an employment contract. Other candidates’ data will be stored longer to allow Polarium to defend itself against legal claims (for example discriminatory claims based on the Swedish Discrimination Act) or if candidate gives its consent to remain as a candidate for future positions.
Compliance with legal requirements	Art. 6 (1) c GDPR, where the processing of personal data is necessary for compliance with a legal obligation.	Depending on the situation, this could include any type of personal data we process. In each case we try to keep the processing of personal data for this purpose to a minimum.	Certain legislations require us to keep certain data for a certain period of time for example Bookkeeping Act, Annual Report Act, etc.)
For billing, account management and other administrative matters	Art. 6 (1) b GDPR, processing necessary for the performance of a contract. Art. 6 (1) c GDPR, processing necessary for compliance with legal obligations (e.g., tax and accounting).	Identification and contact details, payment information, transaction records, account details, and other administrative data. We only process what is required to manage accounts, issue invoices, and meet statutory retention obligations.	For seven years for compliance with the Swedish Bookkeeping Act.
Marketing and communication activities	Art. 6 (1) a GDPR (consent), where we send direct marketing that requires prior consent (e.g., newsletters). Art. 6 (1) f GDPR (legitimate interest), where communication is necessary for our business relationship (e.g., transactional or service-related emails).	Contact details (e.g., name, email address, phone number), preferences, communication history. We only use the data necessary to provide information or offers that are relevant to the individual.
Website development and enhancement	Art. 6 (1) f GDPR, legitimate interest in ensuring the proper functioning, security, and continuous improvement of our website and online services.	Technical data such as IP address, device information, browser type, operating system, access times, and usage patterns. Data is anonymized or pseudonymized where possible, and collected only to the extent necessary for functionality and improvement.
Dispute management
Cookies	Please see our separate Cookie Policy below.

8. Sharing your personal data

Polarium will only share product related data when legal basis and purpose supports it.

For Polarium Home this means the following:

Recipients: grid operators, energy aggregators, service providers
Scope of shared data: device-level telemetry
Legal basis: Access is limited to devices under agreement with the end-user and only shared with explicit user consent provided to the end user by the recipient
Identifiers: Minimum necessary data and personal identifiers are shared to provide means for contact and delivery of services (metering point ID and email)

9. Retention of data

Polarium retains personal information in accordance with customer instructions and agreements, and only for as long as necessary to deliver the Polarium Service and support its legitimate business purposes. These purposes include maintaining service performance, making data-driven decisions about new features and offerings, ensuring legal compliance, and resolving disputes. Unless otherwise agreed, all personal data will be purged no later than seven years after the termination of the contractual relationship with the customer.

For Polarium Home, data retention is handled as follows:

Raw data is retained for six months, unless it supports the aforementioned business purposes.
Aggregated data is retained for the duration of the contractual relationship. Anonymized versions of aggregated data may be retained beyond the end of the business relationship for statistical and product development purposes.

10. International transfers of data

When transferring personal data to countries outside the EU/EEA that do not have an adequate level of protection for personal data, as determined by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data. You can contact us at privacy@polarium.com if you would like to obtain a copy.

11. Protection of your personal data

We are committed to protecting the personal data of our users. We use appropriate technical and organizational measures to ensure the security of your personal data in the best possible way. However, you should be aware that no system is ever completely secure.

We have implemented various safeguards to prevent unauthorized access and unnecessary storage of personal information in our systems. This includes policies for pseudonymization, encryption, access, and retention.

To protect your app account, we recommend the following:

Create a strong password that you only use for your Polarium account.
Never share your password with anyone.
Restrict access to your computer and browser.
Sign out after using the Polarium service on a shared device.

If other people have access to your Polarium Home Companion App, they can access personal information, settings, and the Polarium service available with your account.

Only allow people to use your account if you agree to share that personal information with them. This decision is your responsibility. Other people’s use of your Polarium account may affect your personalized recommendations and may be included in the download of your data.

12. Automated decision making

We do not process your personal data for any automated decision making.

13. Changes to this Policy

We may make changes to this policy from time to time. If we make changes to this Policy, we will make a new version available on our website.

14. Contacting Polarium

If you have any questions or concerns about this policy, you can contact our Privacy Department in one of the following ways:

E-mail: privacy@Polarium.com
Mail: Polarium, Solnavägen 3H, 113 63, Stockholm

Polarium Energy Solutions AB acts as controller and is such responsible for the personal data processed under this policy.

By accepting this Privacy Policy, you acknowledge that you have read and understood its contents, including the use of your data for marketing activities and segmentation as described herein.

15. Studio Mobile (mobile applications)

This privacy policy covers the use of the Studio Mobile applications for Android and iOS. It may not be applicable to other software produced or released by Polarium Energy Solutions AB. Polarium Energy Solutions AB does not collect any statistics, personal information, or analytics from our users, other than built in mechanisms that are present for all the mobile or embedded applications in their respective main distribution channels.

16. Polarium Home App

The Polarium Home app uses a third-party analytics tool to help us understand how the app is used and to improve the user experience. This tool collects data such as feature usage and session information. The processing is based on our legitimate interest (Art. 6(1)(f) GDPR). Data is anonymized or pseudonymized where possible and is not used to identify users personally. The analytics provider acts as a data processor on our behalf and is bound by a data processing agreement in compliance with GDPR.

17. Cookie Policy

Polarium Energy Solutions AB and our service providers use cookies and tracking technologies on our website to enable us to analyze the use of our website and services, to improve and personalize your experience of our website and services which may be tailored to you based on your browsing behavior and other information held about you.