Your privacy matters.

This document sets out the privacy policy of Poweraudit Pty Ltd ABN 52 664 548 396 (referred to in this privacy policy as 'Poweraudit', 'we', 'us', or 'our').

We take our privacy obligations seriously and we've created this privacy policy to explain how we store, maintain, use and disclose personal information.

By providing personal information to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy.

We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.

The personal information we collect may include the following:

• (a)name;
• (b)mailing or street address;
• (c)email address;
• (d)telephone number and other contact details;
• (e)credit card or other payment information;
• (f)your power usage;
• (g)your power meter reading for your property;
• (h)billing information from your power supplier;
• (i)images of the exterior of your property;
• (j)information about your personal and household circumstances;
• (k)information in connection with client surveys, questionnaires and promotions;
• (l)information you submit through our AI chat or online messaging features, including chat prompts, transcripts, timestamps, related session metadata and, where you have opted in, redacted analytics derived from those chats;
• (m)your device identity and type, I.P. address, geo-location information, page view statistics, performance diagnostics, error telemetry, session replay data on selected pages where consented, advertising data and standard web log information;
• (n)information about third parties;
• (o)electricity bills, interval data, tariff data, network tariff information, solar export data and other energy-related documents or datasets you provide to us;
• (p)account numbers, National Metering Identifier (NMI), meter identifiers and similar service or supply identifiers contained in those documents or datasets;
• (q)information generated from our review and analysis of those documents or datasets, including extracted data fields, summaries, classifications, comparisons and recommendations; and
• (r)any other information provided by you to us via our website or our online presence, or otherwise required by us or provided by you.

We will collect your personal information in a lawful and fair way. We will only collect your personal information where you have consented to it, or otherwise in accordance with the law.

How we collect information from you

We may collect personal information where you:

• (a)contact us through our website;
• (b)submit questions or messages through our AI assistant or chat features;
• (c)receive goods or services from us;
• (d)upload or otherwise provide us with electricity bills, interval data, tariff data, meter data, solar export data or other energy-related documents or datasets during the course of providing our goods or services;
• (e)submit any of our online enquiry forms;
• (f)communicate with us via email, telephone, SMS, social applications or otherwise;
• (g)interact with our website, social applications, services, content and advertising; and
• (h)invest in our business or enquire as to a potential purchase in our business.

How we collect information from third parties

Where possible, we collect your personal information directly from you. However, there may be occasions when we collect personal information about you from someone else. For example, another individual in your household.

How you provide information for someone else

If you are providing personal information on behalf of someone else, you must have the consent of that person to provide their personal information to us to be collected, used, and disclosed in accordance with this privacy policy.

How we collect information from cookies

We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, cookies, session storage, local storage or similar tracking technologies that allow us to track, analyse and improve website usage. Cookies and similar technologies store information on your computer, mobile phone or other device and enable the creator of the cookie or identifier to recognise your browser or device across visits. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser, however some features may not function as intended.

We use website analytics and performance tools as part of operating our website. Where you opt in to optional analytics, we may also use behavioural analytics, feature delivery, session replay and error monitoring tools. These tools may use cookies, local storage, session storage and similar identifiers to understand how visitors use our services and to help us improve them.

We collect and use personal information for the following primary purposes:

• (a)to provide goods, services or information to you;
• (b)for record keeping and administrative purposes;
• (c)to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing goods or services to you;
• (d)to improve and optimise our service offering and customer experience;
• (e)to extract, classify, summarise and analyse information contained in electricity bills, interval data, tariff data, meter data, solar export data and other energy-related information you provide to us, including by using business or commercial artificial intelligence and automation tools, so that we can review your energy profile, prepare reports, compare options, identify patterns in usage and costs, and support our recommendations and customer service;
• (f)to review, monitor and improve our AI assistant, including understanding the questions users ask and the responses provided, using redacted transcript analytics where you have opted in to optional analytics;
• (g)to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
• (h)to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
• (i)to consider an application of employment from you.

Where we use AI and automation tools for bill or energy data analysis, we do so through business or commercial services configured for organisational use rather than publicly available consumer chatbot accounts. Where applicable under our contractual arrangements and service settings, customer inputs and outputs are not used to train the provider's public AI models unless we tell you otherwise or obtain consent where required.

AI-generated outputs are used as an assistive tool only. Relevant outputs are reviewed by our personnel before they are relied on in delivering our services.

We may also use your personal information for:

• (j)secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
• (k)such purposes where we reasonably believe that use of your personal information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
• (l)any other purpose for which we receive consent from you; or
• (m)any other purpose which is permitted or required under applicable privacy laws.

We respect your privacy, and we will take reasonable steps to keep your personal information confidential and protected. We may disclose your personal information to:

• (a)our professional advisors such as lawyers, accountants and auditors;
• (b)third-party providers who help us operate our website, hosting, analytics, observability, AI assistant, business or commercial AI analysis workflows, document processing, CRM, communications or technology systems, and other AI, cloud or software service providers we use from time to time;
• (c)our related entities; or
• (d)any third parties you have consented personal information to be disclosed to.

We may also disclose personal information to third party contractors as required for us to provide our goods and services to you, such as cloud-service providers, IT professionals, business or commercial AI service providers, marketing agencies and debt collection agencies.

Without limiting the above, we may disclose or make available electricity bills, interval data, tariff data, meter data, solar export data and related personal information to business or commercial AI, document processing and cloud-service providers that help us extract, classify, summarise or analyse that information on our behalf for the purposes set out in this privacy policy.

Where we use such providers, we seek to use services configured for organisational or commercial use rather than publicly available consumer chatbot accounts, and we seek contractual or technical controls appropriate to the service. Where applicable under our arrangements with those providers, we seek to ensure that customer inputs and outputs are not used to train public AI models unless otherwise disclosed to you or permitted by law.

We take care to work with such third parties who we believe maintain an acceptable standard of data security and require them not to use your personal information for any purpose except for those activities we have asked them to perform on our behalf.

We will not otherwise disclose your personal information unless:

• (e)you have consented to us disclosing your personal information for particular circumstances;
• (f)as needed in an emergency or in investigation suspected criminal activity;
• (g)we are required to disclose under a subpoena, court order or other mandatory reporting requirements;
• (h)we reasonably believe that disclosure of your information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
• (i)it is reasonably necessary for the establishment, exercise or defence of a legal claim; or
• (j)it is otherwise authorised or required by law.

We use our best endeavours to store all personal information we collect securely and to work with service providers that maintain appropriate technical and organisational safeguards. Some information may be stored on servers located in Australia, however our service providers may also operate infrastructure, support teams, backup systems or disaster recovery environments in other countries.

Where you use our AI assistant or chat features, your questions, transcripts, related metadata and operational logs may be processed or stored by technology providers we engage to operate those services. Where you opt in to optional analytics, we may also store redacted transcript analytics, behavioural analytics and replay data for selected pages to help us improve our website and services.

Where you provide us with electricity bills, interval data, tariff data, meter data, solar export data or related documents, those materials and related metadata may be processed or stored by business or commercial AI, cloud or document processing providers we engage to help us provide our services.

Where practicable, we seek to minimise the personal information provided to these systems and use redacted or de-identified information where appropriate.

Our website analytics, observability, hosting, CRM, communications and AI providers may process information across multiple countries, including countries outside Australia. The countries in which such overseas recipients are likely to be located may include [insert countries or regions, if practicable]. By using our services and providing your personal information, you acknowledge that overseas recipients may process or store your personal information in accordance with this privacy policy and applicable law.

When you communicate with us through a social media service, the relevant social media provider and its partners may collect and hold your personal information overseas according to their own privacy terms.

We may at times send you marketing communications which will be done in accordance with the Spam Act 2003 (Cth) (Spam Act).

If we do, we may use email, SMS, social media, phone or mail to send you direct marketing communications.

Where consent is needed, we will ask you for your consent before sending you marketing communications, except where you:

• (a)have explicitly opted-in to receiving email marketing from us in the past; or
• (b)were given the option to opt-out of email marketing when you initially signed up for one of our platforms and you did not do so.

You can, at any time, opt out of receiving marketing materials from us by using the opt-out facility provided (e.g., an unsubscribe link on emails we send you) or by contacting us via the details provided at the end of this privacy policy. We will implement such a request as soon as possible, however, cannot guarantee that such a response will be immediate.

The information we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process, discuss and distribute such information.

Our process of de-identification would leave only the following attributes linked to your personal information:

• (a)your household data (number of people in the home);
• (b)your power usage via our power audit sensor system device;
• (c)your power usage via your power metre;
• (d)your power usage cost; and
• (e)your postcode.

("De-Identified Information")

We will use your De-Identified Information to calculate the average power usage in your suburb and compare this data to other users in the same suburb. Subject to clause 5 of this privacy policy, we will not disclose your personal information with a third party.

We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.

If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.

If you wish to complain about how we handle your personal information held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable timeframe.

For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below: