Privacy Policy (Application)

1. Data Controller

• Energycom d.o.o.
• Pod bregom 2, Donji Stupnik, Croatia
• OIB: 08368224742
• E-mail: info@energycom.hr

We act as the Controller of personal data processed in accordance with this Privacy Policy.

The Application uses technology provided by Green Energy Pal d.o.o. (Enpulse platform), which acts as a Data Processor on our behalf under a Data Processing Agreement.

2. Data we collect

We may collect and process the following categories of personal data:

• Account data: Full name, e-mail address, phone number
• Energy system data: Solar production, battery status, energy consumption, EV charging sessions, grid import/export
• Technical and device information: Device identifiers, IP addresses, app version, operating system, error logs
• Location data: Installation address (collected during system setup - used to retrieve local weather data and electricity tariffs)
• Third-party data: Data retrieved from connected systems such as Huawei FusionSolar, SolarEdge, Enphase and weather services - displayed exclusively to you, on your authorisation
• Push notification tokens: Device tokens used to send system alerts (e.g. power outage notifications) - collected only if you grant notification permission
• Customer support communication: Messages and information provided for resolving technical issues through support channels

3. How we use your data

We process personal data for the following purposes:

• Operating the Application and displaying your energy system data
• Generating energy reports, insights and savings estimates
• Sending system notifications (power outages, system alerts, maintenance)
• Retrieving weather data relevant to your installation location
• Responding to support requests and resolving technical issues
• Improving application performance through anonymised analytics
• Fulfilling legal obligations (accounting, taxes, regulatory requirements)

4. Legal basis for processing

• Performance of a contract — to provide the services contracted by you or your installer
• Legitimate interest — to manage and improve the platform, prevent fraud and ensure security
• Legal obligations — to fulfil tax, accounting and regulatory requirements
• Consent — for optional features such as push notifications (consent may be withdrawn at any time in the Application settings)

5. Data sharing

We share personal data only when necessary:

• Green Energy Pal d.o.o. (Enpulse) — technology platform provider and Data Processor
• Third-party API service providers — weather data (e.g. OpenMeteo), inverter data (Huawei FusionSolar, SolarEdge) - solely to display your own data
• Infrastructure providers — hosting, analytics, error tracking (under data processing agreements)
• Competent authorities — where required by law or a lawful legal process

We do not sell personal data to third parties.

6. International data transfers

When data is transferred outside the EU/EEA, we ensure appropriate protection through EU Standard Contractual Clauses (SCC) or equivalent legal mechanisms. The Enpulse platform infrastructure is located within the EU.

7. Data retention

• Account data — for the duration of the active account and up to 5 years after termination (for legal obligations)
• Energy monitoring data — for the duration of the active subscription
• Customer support communication — up to 2 years after case resolution
• Push notification tokens — until notification permission is revoked or the account is deleted
• Error data and analytics — anonymised after 90 days

8. Your rights under the GDPR

As an EU resident, you have the right to:

• Access your personal data
• Rectification of inaccurate or incomplete data
• Erasure of data ("right to be forgotten")
• Restriction of or objection to processing
• Data portability (receiving your data in a machine-readable format)
• Withdrawal of consent at any time (for consent-based processing)
• Lodging a complaint with the Personal Data Protection Agency (AZOP) at azop.hr

To exercise your rights, please contact us at: info@energycom.hr

9. Push notifications

If you grant notification permission, the Application may send you alerts about:

• Power outages or interruptions in the distribution network in your area
• System alerts from your energy devices
• Important service or account updates

You can withdraw notification permission at any time in the Application settings. Revoking permission does not affect the use of other Application features.

10. Analytics and error tracking

The Application uses third-party tools for analytics and error tracking to improve stability and performance. These tools collect anonymised technical data (device type, OS version, error logs). They do not collect personal data and are subject to their own privacy policies.

11. Data security

We implement appropriate technical and organisational measures to protect personal data, including:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of stored data
• Access controls and authentication
• Regular security reviews

12. Children's privacy

The Application is not intended for children under the age of 16 and we do not knowingly collect personal data from them. If you believe we have inadvertently collected data about a child, please contact us immediately.

13. Changes to this Policy

We may update this Privacy Policy from time to time. We will notify you of changes via push notification or e-mail, and the updated version will be published on our website. Continued use of the Application after changes take effect constitutes acceptance of the updated Policy.