Privacy Policy - Homevolt

1. Introduction

Homevolt AB (”Homevolt”, “we” or “us”) values and protects your personal integrity, which means that we always collect and handle personal data responsibly and with your privacy in mind.

This privacy notice provides information about the personal data Homevolt collects, processes and discloses, the purposes for which personal data is processed and your rights in relation to the personal data processed by Homevolt. This privacy notice is directed towards Homevolt customers, applicants for a position with Homevolt, representatives of Homevolt’s business partners (including but not limited to suppliers and installation companies) and website visitors.

Homevolt will process personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Homevolt is the data controller for the processing of your personal data, which means that Homevolt determines the purpose and means for the processing of your personal data.

If you have any questions related to this privacy policy or Homevolt’s processing of your personal data, you may contact us by using the contact information stipulated below.

2. Data controller and contact details

Company name	Homevolt AB
Registration number	559409-7957
Address	c/o Polarium Energy Solutions AB Solnavägen 3 H 6 tr 113 63 Stockholm
E-mail	privacy@homevolt.com

If you have questions regarding our processing of your personal data or if you wish to exercise your rights, you can contact us by emailing privacy@homevolt.com or by sending a letter to the address above, attention: Privacy Homevolt.

Please note that personal data of Homevolt consumers will be separately processed by the company from which the consumer purchased the Homevolt product(s). Such company acts as a separate controller and will provide separate information about the processing of personal data in their privacy notices. Please visit the website of the company from which you purchased the Homevolt product for more information or contact your contact person from the company.

3. What personal data Homevolt processes, the purpose and legal basis

Processing of personal data for installation of Homevolt products
[Only relevant for installation company and not relevant for consumers / users of Homevolt]
Purpose	Homevolt provides an app for the installation of the battery, used by the installation company. In order to get the battery connected to the site (the grid and potential solar panels) and online some personal information needs to be collected.
Categories of data	Information about site (such as connection to grid and / or solar panels, fuse size) and the Wi-Fi the battery is connected to and information about installation company (which can entail personal data from case to case).
Legal basis	Art. 6 (1) lit. f GDPR based on our legitimate interest to ensure that your battery is installed and working properly. Our overall assessment of these interests is that they are necessary and proportionate for the purpose. More information about our legitimate interest assessment can be provided upon request.

Processing of personal data to offer and administer Homevolt-ID, Homevolt cloud account and the Homevolt Companion App
Purpose	The purpose of the processing is to allow users to: register the Homevolt-ID and connect the battery to the personal account; in the Homevolt app: enable users to manage their battery, to see their own battery’s usage history, to be able to manage user’s access and manage security; and through the Homevolt cloud: make battery information and usage data available to both the user and for third parties services to access through API, upon request by the user, for provision of services provided by the third party.
Categories of data	Email-address, password 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 your usage of the app, logins, errors, etc.
Legal basis	The personal data we process when you register a Homevolt account or request access to Homevolt cloud is necessary to confirm your identity and prevent your account from being misused or duplicated. Art. 6 (1) lit. b GDPR, since the processing is necessary to fulfill a contract with you relating to the use of Homevolt’s cloud solution. Art. 6 (1) lit. f GDPR based on our legitimate interest to ensure that your data, the app etc. is secure and in order to provide good customer service, e.g., by offering you the opportunity to update your personal data in the Homevolt app. Our overall assessment of these interests is that they are necessary and proportionate for the purpose. More information about our legitimate interest assessment can be provided upon request.

Processing of personal data for providing customer support and other inquiries
Purpose	To support customers with potential questions or issues with Homevolt’s product(s) or the Homevolt Companion App. Data provided in a support matter may also be used for analytics purposes, to ensure that we provide an efficient support service. We anonymize the personal data where possible.
Categories of data	Personal data as provided by the customer from case to case, for example name, email address and serial number to the Homevolt product(s).
Legal basis	Art. 6 (1) lit. 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.
Specific retention period	Emails from customers that are sent to our support email address will be stored up to three years from the date the matter was resolved.

Processing of personal data for general improvement of Homevolt
Purpose	Homevolt uses personal data for generating statistics and analyses in order to improve our services and enhance the user experience, as well as ensuring stability in our services. Personal or technical data from your devices used for such purposes are pseudonymized, meaning that you may not be identified as an individual person based on the statistics or analyses generated as a basis for the improvement of our services.
Categories of data	Personal data contained in technical analyses, logs and information on the use of the Homevolt Companion App or Homevolt battery. As far as possible data is anonymized for service improvement purposes.
Legal basis	Art. 6 (1) lit. 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. If you are located in Germany and have given consent to the processing of data from position sensors as described above, the legal basis is Art. 6 (1) a GDPR (consent).

Processing of personal data for recruitment
Purpose	If you apply for a position in Homevolt, we will process your personal data as part of considering your job application. The data is collected from the applicant or from the references provided. By applying for a position in our company and sending us documentation, we consider you to request our assessment of the provided documentation, to carry out interviews and call your references with a view to entering into an employment agreement. If you consent, we may store information about you in a “talent pool” for future job openings.
Categories of data	Contact details, CV, your application, certificates, references (which you provide) and other information you may provide in your CV, personal letter or during interviews, etc.
Legal basis	During the recruitment process – Art. 6 (1) lit. 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@homevolt.com. Once a candidate is chosen the personal data is processed in accordance with Art. 6 (1) lit. b GDPR, since the processing is necessary to enter into a contract with you. If you have given your consent to store your applicant data in a talent pool after a recruitment process for longer than a year for potential future vacancies, the legal basis is Art. 6 (1) a GDPR (consent). You may withdraw your consent at any time by contacting us using the contact details provided in this policy.
Specific data sharing	If an external recruitment agency is used for the specific position, we will share applicant data with such agency. Such agency will process applicant personal data as separate data controller or as a processor bound by a data processing agreement, depending on the situation.
Specific retention period	As regards personal data about job applicants, the personal data will be stored during the recruitment process. If the applicant is not employed in Homevolt, relevant personal data will be stored up to two years after the position was filled for the purpose of handling potential disputes; and potentially longer if the job applicant has consented to another retention period for future recruitments. If the applicant is employed part of the personal data will be kept as part of the personnel file.

Processing of personal data for administration of Homevolt’s relations to corporate customers, suppliers and other business partners
Only relevant for representatives of Homevolt’s corporate customers, suppliers and other business partners
Purpose	In order to create and maintain relations with business customers, suppliers and other partners Homevolt need to process data about individuals working for, or otherwise connected to such organizations. This is usually contacts for various topics such as sales representatives, counterparts in negotiations, participants in meetings, etc.
Categories of data	Contact details to individuals at supplier, partner or business customer. Personal data contained in contracts, ongoing commercial correspondence, invoices, minutes of meeting etc.
Legal basis	Art. 6 (1) lit. f GDPR, based on our legitimate interest in administering our relations to business customers, suppliers and other partners, including to communicate with our contact persons. More information about our legitimate interest assessment can be provided upon request.

Processing of personal data through use of cookies
Purpose	Homevolt uses cookies and other information gathering methods to improve the Homevolt website and enhance the user experience. You can find more information regarding cookies, etc. at 10. Cookie Policy for homevolt.com.

Processing of personal data for compliance with statutory requirements and legal obligations
Purpose	From time-to-time Homevolt may need to adhere to requests from public authorities or other statutory requirements. This could be requests from the police, courts, public authorities, or for handling employee health, etc.
Categories of data	Depending on the request, this could include any type of personal data we process. In each case we try to keep the sharing of personal data to a minimum.
Legal basis	Art. 6 (1) lit. c GDPR, processing is necessary for compliance with a legal obligation

Processing of personal data to ensure the rights of Homevolt or third parties
Purpose	Homevolt may need to establish, exercise or defend legal claims we believe to have, or that are directed towards us by customers, suppliers, partners, other third parties or public authorities.
Categories of data	Dependent on claim and situation but could include any category of personal data that we process.
Legal basis	The legal basis of the processing is Art. 6 (1) lit. f GDPR based on our legitimate interest in establishing, exercising or defending legal claims for the enforcement of our rights or the rights of third parties. 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.

5. How Homevolt protects your personal data and where the personal data is processed

Homevolt will store your personal data only as long as it is necessary to fulfill the purposes for processing as defined above.

With regards to consumer data, Homevolt will as a main rule delete personal data within three years after termination of the contract for use of Homevolt’s app, account and/or cloud solution.

If the legal basis for the processing of personal data is your specific consent, Homevolt will cease the processing of personal data if your consent is withdrawn. You may withdraw your consent at any time.

Notwithstanding the retention periods stated elsewhere in this Privacy Notice, continued storage of personal data may be necessary due to statutory obligations to which Homevolt is subject, e.g., storage for accounting purposes, or due to Homevolt’s legitimate interests, e.g., for the purpose to establish, exercise or defend a legal claim. Anonymized information, i.e., information that cannot be linked to a natural person, may also be subject to continued storage.

Information related to the battery and the usage/support thereof is stored for the time of the warranty plus one (1) year. Note that this however does not typically constitute personal data.

6. How Homevolt shares your personal data

Homevolt will only disclose personal data to third parties if and when there is a legal basis for such disclosure.

Homevolt uses third parties to collect, store or otherwise process personal data on our behalf, including in relation to our hosting services, customer support, etc. The relationship to such suppliers is governed by data processor agreements, which among other things regulates confidentiality and information security for your personal data.

Homevolt may disclose personal data to public authorities to comply with statutory requirements or orders from public authorities, e.g., to comply with obligations under the applicable accounting or tax legislation. The relevant public authorities will be the data controller for the personal data disclosed in such instances.

If you want Homevolt battery data to be used in third party applications, the required data will be disclosed based on you giving access to such a third party to connect to your Homevolt-ID and cloud account. The party receiving such data will become a separate data controller.

7. What your data protection rights are

Here you can read more about your rights in relation to your personal data.

Right to information and access. You can request information regarding whether we are processing your personal data and ask to receive a copy of your personal data (known as a data subject access request or DSAR) together with certain additional information regarding how we process your personal data.

Right to rectification. By having access to personal data, you may be able to ensure the accuracy of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Note that some historical data needs to be processed, i.e., cannot not always be corrected for historical periods. You may yourself correct some personal data throughout the Homevolt app.

Right to object. You have the right to object to the processing of your personal data which is based on our legitimate interest. If we cannot demonstrate compelling and legitimate grounds to continue processing the personal data, we must cease the processing. You always have the right to object to our processing of your personal data for direct marketing purposes.

Right to restriction of processing. In some cases, you have the right to request a restriction of the processing of your personal data, which means that the data is marked so that, in the future, it can only be processed for certain limited purposes. This is possible, for example, if you have objected to the processing, if you have disputed the accuracy of your personal data, or if the processing is unlawful. By requesting a restriction of our processing, you have the right to stop us from processing your personal data for a certain period of time for other purposes than, for example, to defend legal claims.

Right to deletion. This enables you to ask us to delete or remove personal data in certain cases. Note that we may not always be able to comply with your request of erasure for specific legal reasons. If this is the case, we will notify you at the time of your request.

Right to transfer your personal data to you or a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format, provided that the information requested to be transferred is provided by you is processed on the basis of fulfilling an agreement or based on consent, and provided that the processing of personal data is carried out by automated means.

Right to withdraw your consent. In those cases where we process your personal data based on your consent, you have the right to withdraw your consent at any time. When you withdraw your consent, we will stop any processing of personal data which is based on your consent. If you withdraw your consent, we may not be able to provide certain products or services to you for which we rely on your consent.

Right to complain to a supervisory authority. If you believe that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. If you are a resident of an EU or EEA member state, you may do so in the state of your residence. However, the responsible lead supervisory authority for Homevolt is the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten). You find links to some of the Data Protection Authorities in the list below.

Sweden	Integritetsskyddsmyndigheten	www.imy.se
Netherlands	Authoriteit Persoonsgegevens	https://www.autoriteitpersoonsgegevens.nl/
Germany	Per Bundesstaat	https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html

You can read more about your rights on the websites of the Data Protection Authorities. If you wish to exercise any of the rights set out above, reach out to Homevolt via email at privacy@homevolt.com

8. Automated decision making

We do use your personal data for any automated decision-making process (including profiling).

9. Changes to the privacy policy

Homevolt’s privacy notice is available at Homevolt’s website and when registering a Homevolt-ID. If Homevolt makes changes in the processing of personal data, the policy will be updated on the Homevolt website and in the Homevolt app. In case of changes in the processing of personal data that require your consent, we will collect your consent prior to initiating such processing.

10. Cookie Policy for homevolt.com

Cookies and tracking technologies

Homevolt uses cookies and tracking technologies on our website to enable us to analyze the use of our website, 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.

Manage cookies

You can easily choose how cookies are handled by your device via your browser settings, including to refuse or delete all cookies. Please note that if you choose to refuse cookies, our services and website may not function properly and certain services will not be provided. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

***

Last updated: June 2024