Privacy Policy

EQUILUX AI PTE LTD ("Equilux", "we", "us") respects your privacy. This Privacy Policy explains how we collect, use, disclose and care for your personal data when you use the Equilux mobile app, our AI energy coach, our admin portal and this website (together, the "Services"), in line with Singapore's Personal Data Protection Act 2012 ("PDPA").

By using the Services, you consent to us collecting, using and disclosing your personal data as described here. You can withdraw your consent at any time (see section 9).

1. Personal data we collect

Account data

• Your name, email address and password. We store passwords only as one-way hashes (Argon2) and never in readable form.
• If you sign in with Google or Apple, the account identifier, name and email address (which may be an Apple private-relay address) that the provider shares with us.
• Your profile photo (optional), timezone, language and country.
• The dates you joined and last signed in, and technical sign-in tokens.

Home and household data

• Your home's name, street address, postal code and country.
• Your home's approximate latitude and longitude. We work these out from your postal code and address to provide weather and solar forecasts.
• The names and email addresses of household members you invite to your home. If you add someone else, please make sure they are happy for you to share their details with us.
• Electricity tariff details you enter from your bill.

Connected device and energy data

When you link a smart meter, solar inverter, air-conditioner, EV charger or vehicle account, we collect:

• Login details for that provider's account. This means the username and password, access token or API key you give us. We encrypt these before storing them, and use them only to read data from and send commands to your devices.
• Account and device details. These include account and premise numbers, device names (such as room names), models, serial numbers, adapter MAC addresses and Wi-Fi network names.
• Readings. These include electricity and water consumption, solar generation and export, battery charge, charging power and sessions, your vehicle's battery charge level, air-conditioner on/off state, mode, set temperature, room and outdoor temperature, and humidity.
• A history of commands and automations you or your automation rules have run.

Taken together, readings over time can show patterns of when your household is home and using appliances. We treat this data as personal data.

AI energy coach data

• The messages you send to the energy coach and its replies, stored as your chat history.
• A summary of your home's energy data, attached to each message so the coach can answer accurately.

App and technical data

• Push notification tokens and basic device information (device type and name).
• IP address, browser or app information, and request logs, collected when you use the Services.
• Error reports when something goes wrong.

Website and enquiries

• The details you give us through the "Get Started" form, by email or by phone, such as your name, contact details and information about your home and energy setup.

We do not intentionally collect NRIC numbers, payment card details or other sensitive personal data. Please do not include these in chat messages.

2. How we use your personal data

We use your personal data to:

1. create and manage your account, verify your email address, and let you sign in securely;
2. connect to your devices and energy provider accounts, and display live and historical energy data;
3. carry out device commands you give and run the automation rules you set up;
4. produce energy insights, bill estimates, savings and carbon estimates, and weather and solar forecasts;
5. answer your questions through the AI energy coach;
6. let household members you invite access your home;
7. send you service messages, such as account emails, invitations and app notifications;
8. respond to enquiries, consultation requests and support requests;
9. keep the Services secure, prevent misuse, and diagnose and fix errors;
10. improve and develop the Services, using data that is aggregated or de-identified where practicable;
11. meet our legal and regulatory obligations.

We will not send you marketing messages to a Singapore telephone number unless you have given clear consent or an exemption under the Do Not Call provisions of the PDPA applies.

3. How the AI energy coach uses your data

The coach is powered by Google's Gemini models through Google Cloud Vertex AI, processed in Google's Singapore region. When you send a message, we send Google:

• your message; and
• a summary of your home's energy data.

We do not send your name, email address or provider login details. Under its Google Cloud terms, Google does not use this data to train its models.

The coach can start or stop EV charging, or change the charging current, only after you confirm the action in the chat.

AI responses may be inaccurate or incomplete. Please see our Terms of Service.

4. Who we share your personal data with

We do not sell your personal data. We share it only as needed with:

We may also disclose personal data:

• to household members you have invited, who can see your home's devices and data;
• to professional advisers;
• to a buyer or successor if our business is reorganised or sold;
• where required or permitted by law, for example to comply with a court order or a request from a public authority.

Your connected device and energy providers handle your data under their own privacy policies.

5. Transfers outside Singapore

Our main systems are hosted in Singapore. Some of the service providers above process data outside Singapore. When we transfer personal data overseas, we take appropriate steps to make sure recipients protect it to a standard comparable to the PDPA, as the Transfer Limitation Obligation requires. These steps include contractual safeguards, or recipients' certifications and data processing terms.

6. How we protect your personal data

We use reasonable security arrangements, including:

• encryption in transit (TLS);
• encryption of stored provider login details;
• hashed passwords;
• access controls and audit logs for administrative actions;
• private networking between our services;
• managed cloud infrastructure.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please keep your password confidential, and tell us promptly if you suspect unauthorised access to your account.

If a data breach is likely to cause you significant harm, we will notify you and the Personal Data Protection Commission as the PDPA requires.

7. How long we keep your personal data

We keep personal data only as long as necessary for the purposes above, or as required by law.

• Account, home, device and energy data are kept while your account is active.
• When you ask us to delete your account, or disconnect a provider, we will delete or anonymise the related data within a reasonable time. Data held in backups is overwritten as the backups expire.
• We may keep limited records longer where needed for legal, security or dispute-resolution purposes.

8. Accessing and correcting your personal data

You may ask us for:

• a copy of the personal data we hold about you;
• information about how it has been used or disclosed in the past year;
• corrections to any errors.

You can update most account and home details in the app. For other requests, contact our Data Protection Officer (section 11). We will respond as soon as reasonably possible, usually within 30 days. We may charge a reasonable fee for access requests, and will tell you the fee in advance.

9. Withdrawing consent and deleting your account

You can withdraw your consent at any time by contacting our Data Protection Officer. You can also:

• disconnect a device provider in the app;
• remove household members;
• delete chat sessions;
• turn off notifications in your device settings.

If you withdraw consent, we may no longer be able to provide some or all of the Services. We will tell you what this means before we act on your request.

To delete your account and associated data, email our Data Protection Officer from the email address registered to your account.

10. Children

The Services are intended for adults responsible for a home's energy setup. We do not knowingly collect personal data from children under 13. If you believe a child has given us personal data, please contact us and we will delete it.

11. Contact our Data Protection Officer

If you have questions, requests or complaints about this Privacy Policy or your personal data, contact:

Data Protection Officer EQUILUX AI PTE LTD 3A Pasir Ris Drive 6, #03-29 VIDACITY, Singapore 519422 Email: thomas.lim@equilux-ai.com Phone: +65 8685 7249

If you are not satisfied with our response, you may contact the Personal Data Protection Commission.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and change the "Last updated" date. For significant changes, we will also notify you in the app or by email. Continuing to use the Services after an update means you accept the updated policy.