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Energy Services Privacy Notice

For managed charging, demand response, storage and virtual power plant enrollment · Last updated: 25 August 2026 · Version 1.0

This notice explains what information we collect when you enrol a site, home or piece of equipment — an EV charger, battery, solar system, HVAC unit or other flexible load — into an energy program delivered through GravOS, and what we do with it.

1. Who is responsible for your information

Graviti AI operates GravOS in two ways, and which applies determines who is legally responsible:

  • Where we run the program directly. If you enrolled with Graviti AI through a GravOS-branded portal, we are the controller (“business” under US state privacy law) and this notice governs.
  • Where we power a utility's or aggregator's program. If you enrolled through your utility, retailer or another provider, that organisation is the controller and we act as their processor (“service provider”), handling your information only on their documented instructions. Their privacy notice governs your relationship with them; this notice explains what we do on their behalf.

Controller: Graviti AI. Data protection contact: privacy@gravitienergy.ai. Postal correspondence address available on request.

2. Information we collect

CategoryExamplesSource
Enrollment & contactName, service address, email, phone, business name and role where applicableYou
Utility accountUtility name, account number, meter or service point identifier, rate schedule or tariff, service territoryYou, or your utility with your authorisation
Energy usage dataInterval consumption and export data from your meter (typically 15-minute, 30-minute or hourly), historical billing usage, peak demandYour utility, with your authorisation
Equipment & asset dataMake, model, serial number, firmware version, rated power and capacity, installation date, configuration and limitsYou, your installer, or the manufacturer
Device telemetryState of charge, power flow, energy throughput, voltage, temperature, availability, fault and alarm codes, connectivity statusYour equipment
Control & event dataDispatch signals sent, your settings and limits, opt-outs and overrides, event participation and delivered responsePlatform
Incentive & paymentMeasured performance, incentive calculations, payment details, and tax identifiers where payments must be reportedYou / platform
Support & communicationsMessages, call notes, photographs of equipment or installationYou
TechnicalIP address, portal or app device information, logsAutomatically

A note on energy usage data. Interval meter data can reveal patterns about activity at a premises. We treat it as sensitive, restrict internal access to those who need it, and use it only for the purposes set out below.

3. Utility data authorisation

Most programs require access to your utility account and interval usage data. We obtain it only after you authorise it — through your utility's data-sharing mechanism, a signed authorisation form, or an approved data platform, depending on your territory.

  • The authorisation states which data is shared, for what purpose, and for how long.
  • You can revoke it at any time, through your utility's portal or by contacting us. Revoking may mean we can no longer verify performance or calculate incentives, and may end your participation in the program.
  • We do not use your utility data for advertising, and we do not sell it.

4. Why we use it, and our legal basis

PurposeLegal basis (UK/EU GDPR)
Verify eligibility and enrol you in a programPerformance of a contract
Connect to and monitor your equipmentPerformance of a contract
Forecast, optimise and dispatch your equipment within your settingsPerformance of a contract
Measure and verify your performance in program eventsPerformance of a contract; regulatory obligation of the program
Calculate and pay incentives; meet tax reporting dutiesPerformance of a contract; legal obligation
Report aggregate capacity and performance to a utility, ISO/RTO or program administratorPerformance of a contract; legitimate interests
Maintain safety, protect equipment and diagnose faultsLegitimate interests; vital interests where safety is at stake
Improve forecasting and optimisation modelsLegitimate interests, using aggregated or de-identified data wherever possible
Support, service messages and event notificationsPerformance of a contract
Marketing about other GravOS servicesConsent

5. Automated dispatch and your controls

Participation means GravOS may send automated control signals to your equipment — for example to shift charging, discharge a battery during a peak, or curtail a flexible load. This is the service you enrolled in. Importantly:

  • You set the boundaries. Reserve levels, comfort or readiness limits, depth-of-discharge and cycle limits, and blackout periods are configured by you and enforced by the platform.
  • You can opt out of an event through the app or portal, subject to the program's rules on frequency and notice.
  • Safety limits are enforced in deterministic code, not by predictive models, and cannot be overridden by an optimisation decision.

These are operational decisions about equipment. They are not automated decisions about you that produce legal or similarly significant effects, and we do not carry out profiling of that kind. Incentive calculations follow the published program formula and can be reviewed by a person on request.

6. Who we share information with

  • Your utility, retailer, ISO/RTO or program administrator — for enrollment, eligibility, dispatch, settlement and measurement. This is essential to programs that pay you.
  • Aggregators or channel partners, where your enrollment came through them.
  • Equipment manufacturers and their cloud services, where control or telemetry runs through the manufacturer's API.
  • Installers and service providers, to commission or repair equipment at your request.
  • Payment and tax reporting providers, to pay incentives and meet reporting duties.
  • Cloud hosting, storage and communications providers, under written contract.
  • Auditors, regulators and authorities, where required, including program verification and audit.
  • A successor entity, in a merger, acquisition or asset sale, subject to this notice.

A current list of the service providers who process personal information on our behalf is available on request from privacy@gravitienergy.ai.

We do not sell your personal information and we do not share it for cross-context behavioural advertising.

7. How long we keep it

We keep operational records for 24 months by default. Historical records that support settlement, audit, dispute resolution and long-term performance analysis are kept for three to five years, with the exact period set according to the requirements of the utility, program administrator or customer. Financial records are kept for longer because tax law requires it.

RecordRetention
Enrollment and account recordsWhile enrolled, then 24 months
Interval usage and device telemetry (operational)24 months
Event, dispatch and performance records3–5 years, as required for settlement and audit
Historical usage retained for program analysis3–5 years, depending on program and customer requirements
Incentive payment and tax records7 years, as required by tax law
Support correspondence24 months

Program and regulatory retention rules may oblige us to keep certain records even after you withdraw. Beyond these periods we aggregate or de-identify the data.

8. Your rights

UK, EEA and Switzerland

Access, rectification, erasure, restriction, objection, portability, and withdrawal of consent at any time. You may complain to your supervisory authority — in the UK, the Information Commissioner's Office (ICO); elsewhere, your national data protection authority.

United States

Depending on your state: to know, access, delete and correct your information; to opt out of sale, sharing and targeted advertising; to limit use of sensitive personal information; and not to be discriminated against for exercising these rights. We honour Global Privacy Control signals where required. Authorised agents may act for you with proof of authorisation.

Some rights are limited where we must retain records for program settlement, audit or legal compliance. Where we cannot fully honour a request we will explain why.

To exercise your rights, email privacy@gravitienergy.ai.

9. Withdrawing from a program

You may withdraw at any time as set out in the Program Enrollment Terms. On withdrawal we stop sending control signals and stop collecting new telemetry. We retain historical records where program rules, audit or law require, and any incentives already earned are settled under the program's terms.

10. Security

We use encryption in transit and at rest, per-device credentials and identity, role-based access control, network segmentation, signed firmware and software updates, audit logging of every control action, and outbound-only device connectivity so equipment need not be exposed to the internet. If a breach affects your personal information we will notify you and the relevant regulator where the law requires it.

11. Children

Energy programs are for adults who can contract for utility service. We do not knowingly collect information from children.

12. Changes to this notice

We may update this notice. Material changes will be notified before they take effect, and where a change affects the basis on which your data is used we will seek fresh authorisation where required.

13. Contact us

Privacy and rights requests: privacy@gravitienergy.ai
Program support: support@gravitienergy.ai
General enquiries: info@gravitienergy.ai
Postal correspondence address available on request.

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