Allume Energy (UK) Ltd

1. Allume Energy Pty Ltd (ACN 605 671 494) is a business registered in Australia and is committed to keeping your information safe and secure in accordance with the Australian Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles contained therein and any applicable State or Territory law governing your privacy. If you are based in the UK, the controller of your personal information (or “personal data”) is Allume Energy (UK) Ltd, whose registered address is 125 Wood Street, London, United Kingdom, EC2V 7AW. In this Privacy Policy, when we refer to “the Company”, we mean either Allume Energy Pty Ltd or Allume Energy (UK) Ltd.
2. Please read this Privacy Policy carefully as it contains important information about our use of your personal information, for example if you engage with us directly, if we receive your personal information via a third party (such as an installer), or if we receive your personal information via our SolShare™ product.

1. The Company may collect and use the following kinds of personal information:
   1. If you live in a property where SolShare has been installed, your address, Unique Property Reference Number, and energy usage;
   2. If you browse our website or interact with us (including as a current or potential customer or installer that we work with):
      1. information about your use of the website or online portal (including your log-in details and history; IP address; browser type; version and language; operating system; pages viewed while browsing the website or portal; page access times; “cookies”; and referring website address);
      2. your personal details (including name; phone contact details; address information; email; and payment information);
      3. Data related to your transactions and relationship with us such as:
         1. email address, name, username and phone number;
         2. details of services and products that you have purchased;
         3. payments to and from the Company;
         4. data related to your role as an installer of our products; and
         5. the portfolio of properties including performance reports and maintenance logs managed under our services,
      4. If you submit a security vulnerability report to us (including through our Product Security Incident Response Team (PSIRT) process):
         1. your name/nickname (where provided);
         2. contact details, including email address and telephone number (where provided);
         3. details contained within vulnerability reports, correspondence and supporting documentation;
         4. records of communications regarding the reported vulnerability;
         5. details regarding acknowledgement preferences; and
         6. any other personal information you choose to provide in connection with a vulnerability report;
      5. For those who apply to work with us:
         1. the information you have provided to us in your curriculum vitae, covering letter and application form. This may include: name; title; address; telephone number; personal email address; date of birth; gender; employment history and qualifications; and
         2. any information provided to us during an interview or application process.

      If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application successfully.

2. Your personal information may be collected in a variety of ways, including but not limited to:
   1. when SolShare is installed in the property where you live, the installer of SolShare will upload your address and energy usage to our portal. We will also receive ongoing information about your energy usage from SolShare via its internet connection;
   2. when you access the Company’s website or online portal or otherwise interact with the Company, including by visiting our offices;
   3. when you submit a security vulnerability report, contact our PSIRT, or otherwise communicate with us regarding an actual or suspected security vulnerability affecting our products, services or systems;
   4. when you apply for a job or provide us services (including as an employee or contractor), this could include collecting personal data from you, a recruitment agency, background check providers and referees;
   5. when the Company otherwise provides products and/or services to you;
   6. when you interact with us.

1. The Company may use your personal information for the following purposes. If your personal data is protection by UK data laws, we have also included our lawful basis of processing:

   Purpose	Legal Basis under UK Law
   Providing our products and services. This includes supplying the SolShare product as well as any other products and/or services, communicating with and receiving information from third party providers, and collecting payments from you.	(a) Performance of a contract with you. (b) Necessary for our legitimate interests - where you act on behalf of our customer whom we have contracted with. (c) Necessary for our legitimate interests - to recover debts due to us.
   To manage our relationship with you which may include reaching out regarding your use of the products and/or services, handling any comments, complaints or enquiries from you, and to administer rewards, surveys, competitions or other promotional activities or events conducted, sponsored or managed by us or our business partners.	(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests - to keep our records updated and manage our relationship with you. (d) Necessary for our legitimate interests - to study how customers use our products/services, to develop them and grow our business.
   Website and online portal access. This includes enabling the functioning of and your access to the website and online portal, measuring usage and traffic statistics to the website and online portal as well as to administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Performance of a contract with you. (b) Necessary for our legitimate. interests - where you act on behalf of our customer whom we have contracted with. (c) Necessary for our legitimate interests - for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise. (d) Necessary to comply with a legal obligation.
   To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.	Necessary for our legitimate interests - to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
   To send you relevant marketing communications and make recommendations to you about goods or services that may be of interest.	(a) Necessary for our legitimate interests - to carry out direct marketing, develop our products/services and grow our business. (b) Consent, having obtained your prior consent to receiving direct marketing communications.
   To receive, assess, investigate, validate, remediate and respond to reports of actual or suspected security vulnerabilities affecting our products, services, systems or infrastructure, including communicating with reporters and issuing/publishing security updates.	(a) Necessary for our legitimate interests to maintain the security, integrity and resilience of our products, services and systems and to protect customers and users. (b) Necessary to comply with a legal obligation.
   Internal business practices, including improving our goods and services.	Necessary for our legitimate interests – to develop our goods and services.
   To protect the copyright, trademarks, or other intellectual property or legal rights, property or safety of the Company, the website, and its customers or third parties.	Necessary for our legitimate interests – to protect our intellectual property and other rights.

   When you apply to work for the Company:

2. In connection with your application to work with us:
   1. We will use your personal data to:
      1. Assess skills, qualifications, and suitability for the role.
      2. [Carry out background and reference checks, where applicable.]
      3. Communicate with you about the recruitment process.
      4. Keep records related to our hiring processes.
      5. Comply with legal or regulatory requirements.
   2. Under UK data laws, it is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract of employment or engagement with you.
   3. We may also collect, store and use the following types of more sensitive personal information:
      1. [Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.]
      2. [Information about your health, including any medical condition, health and sickness records.]
      3. [Information about criminal convictions and offences.]
   4. We will use your sensitive personal information in the following ways:
      1. We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
      2. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
   5. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
3. The Company may disclose your personal information in the following circumstances:
   1. to the system owner (usually the freeholder, housing provider, body corporate, or government body that manages or controls you building), and their representative and agents;
   2. to resellers or other providers of our SolShare product, including the SolShare installer;
   3. to other companies in our group;
   4. to third parties that provide goods and services to us (including website and data hosting providers, cybersecurity service providers, payment system operators and HR service providers) and to our professional advisers and agents (including accountants, insurers, lawyers and auditors);
   5. to any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
   6. in the event that we or our assets may be acquired or considered for acquisition by a third party, to that third party and its advisors;
   7. to third parties that require the information for law enforcement or regulatory purposes or to prevent a serious threat to public safety; and
   8. otherwise as permitted or required by law.

1. The Company will take commercially reasonable steps to destroy or permanently de-identify personal information if it is no longer needed including for the purposes of providing our Services to you, satisfying any legal, regulatory, tax, accounting or reporting requirements and where the Company is not required to retain that information by law. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
2. The Company has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
3. The Company has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

This section only applies to those with data rights under Australian law.

1. We request that you advise the Company of changes to your personal information that you have provided to the Company as it is essential that your personal information is accurate, complete, and up-to-date in order for the Company to provide Services to you.
2. By request, you may contact the Company and ask to know what sort of personal information is held about you, for what purposes, and how it is collected, held, used and disclosed.
3. By request, you may access your personal information by contacting the Company at privacy@allumeenergy.com. Where permitted by law, the Company reserves the right to charge a reasonable administration fee for this access. No fee will be charged in the UK.
4. The Company may consider that there is a sound reason under the Privacy Act, Freedom of Information Act or other relevant law, to refuse your request.

This section only applies to those with data rights under UK law.

1. You have a number of rights under UK data protection laws in relation to your personal data. You have the right to:
   1. Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
   2. Request correction of the personal data that we hold about you. 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.
   3. Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
   4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
   5. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
   6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
   7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
   8. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
      1. If you want us to establish the data's accuracy;
      2. Where our use of the data is unlawful but you do not want us to erase it;
      3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
      4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
2. If you wish to exercise any of the rights set out above, please contact the Company using the details below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
4. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

1. The Company retains, collects and maintains your personal information for statistical analysis purposes (whether for commercial or non-commercial purposes). The Company may share, distribute and/or transfer information which you have provided to the Company to third parties, after that information has been de-identified.

1. Sensitive information is defined in the Privacy Act and under UK data protection law to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
2. Sensitive information will be used by the Company only:
   1. for the primary purpose for which it was obtained;
   2. for a secondary purpose that is directly related to the primary purpose;
   3. with your consent; or
   4. where required or authorised by law.
3. In the UK, we will generally only use sensitive information where we have your explicit consent, or where required or permitted by law.

1. Allume Energy Pty Ltd and Allume Energy (UK) Ltd may share your personal data which will involves transfers between Australia and the UK (respectively).
2. The Company may use cloud services, and as such, its servers may be located in Australia or overseas. Your personal information may be transferred and stored in Australia and other foreign jurisdictions which the Company may direct the data to be stored.
3. Regarding Personal Data Subject to Australian Law: In addition to the above, the Company will transfer personal information to someone who is in a foreign country where:
   1. the Company reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles;
   2. the individual consents to the transfer;
   3. the transfer is necessary for the performance of a contract between you and the Company, or for the implementation of pre-contractual measures taken in response to your request;
   4. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between the Company and a third party;
   5. all of the following apply:
      1. the transfer is for your benefit;
      2. it is impracticable to obtain your consent to that transfer; and
      3. if it were practicable to obtain such consent, you would be likely to give it; or
   6. the Company has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles.
4. Regarding Personal Data Subject to UK Law: Where personal information is transferred outside the UK (including to Australia), the Company will take steps to meet the requirements of UK data protection law. Where data is transferred to countries that have not been deemed by the UK to provide an adequate level of protection for personal data, this will generally mean putting in place appropriate safeguards (such as an International Data Transfer Agreement) with the recipient. Please contact us if you would like more information about these safeguards.

1. As a valuable customer, if you have any complaints in relation to this Privacy Policy or privacy practice, please feel free to contact the Company via privacy@allumeenergy.com.
2. A complaint should identify whether it is about:
   1. the collection of personal information;
   2. the use of personal information;
   3. the disclosure of personal information;
   4. the security or storage of personal information;
   5. the accuracy of personal information;
   6. a refusal to give access to or provide about their personal information; or
   7. a refusal to change or delete personal information.
3. The Company values your opinions and takes complaints very seriously. Upon receiving written notice of your complaint about privacy, the Company will respond in a timely manner to advise you of the outcome following its enquiring into the same. You will also be invited to respond to its outcome. If a response is received, the Company will assess your response and advise if it has changed its view. If you are unsatisfied with the final outcome, the Company will advise further options including, if appropriate, making a complaint with the Office of the Australian Information Commissioner. If you are based in the UK, you have a right to complain to the UK Information Commissioner’s Office (ICO) at any point.

1. The Company aims to give you a highly personalised experience when using the Website and the Services. In order to do so, the Company may use your personal information to send you advertisements to your email address. If you decide you do not want to receive these emails containing advertisements, you can request to unsubscribe from the mailing list by clicking ‘Unsubscribe’ at the bottom of the email.

1. The Company uses cookies, web beacons and measurement software (the Cookies) on the Website and our online portals as described below:
   1. "Strictly Necessary Cookies" that are required for the operation of our Website. These essential cookies are always enabled because our Website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our Website. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our Website.
   2. "Functionality Cookie" which store details about your use of the Website to provide you with a personalised experience tailored to you, for example remembering your preferences and greeting you by name;
   3. "Analytical Cookies" to analyse Website traffic, trends and reporting statistics to improve the Website and our services;
   4. "Targeting Cookies" to provide you with targeted marketing communications relevant advertisements when you visit the Website through third party services, such as Google Ads.
2. You may reject or delete the use of Cookies through the settings on your browser or mobile settings.
3. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

   Cookie Name	Purpose	Duration
   _ga	This cookie is an Analytical Cookie (set by Google Analytics) which enables us to tell visitors apart using a randomly generated identifier, and to measure how many people visit the Website and how they use it.	400 days
   _ga_YCB6CX20MG	This cookie is an Analytical Cookie (set by Google Analytics 4) which enables us to keep track of a visit to the Website, so we can count sessions and see how visitors move between pages.	400 days
   __hstc	This cookie is an Analytical Cookie (set by HubSpot) which enables us to track visitors to the Website, including the visitor identifier, the times of the first, previous and current visits, and the number of visits.	180 days
   hubspotutk	This cookie is an Analytical Cookie (set by HubSpot) which enables us to recognise a visitor, and to match a form you submit on the Website to your earlier browsing activity.	180 days
   __hssrc	This cookie is an Analytical Cookie (set by HubSpot) which enables us to work out whether you have restarted your browser, so we can tell when a new visit begins.	Session
   __hssc	This cookie is an Analytical Cookie (set by HubSpot) which enables us to keep track of the current browsing session and the number of pages viewed within it.	30 minutes
   _gcl_au	This cookie is a Targeting Cookie (set by Google Ads) which enables us to measure and attribute conversions, such as form submissions, to our Google advertising campaigns.	90 days
   _fbp	This cookie is a Targeting Cookie (set by Meta) which enables us to deliver and measure our advertising on Facebook and Instagram, and to measure how visitors who arrive from those ads use the Website.	90 days

1. The Website may from time to time have links to other websites not owned or controlled by the Company. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that the Company is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

1. This section 14 does not apply to UK users. If your personal information is processed by our UK Company, you have rights under the UK General Data Protection Regulation. This Privacy Policy is non-contractual, and does not affect your statutory rights.
2. Waivers
   1. In limited circumstances, the Company may allow you to waive application of this Privacy Policy. A waiver of this Privacy Policy must be in writing and signed by the Company. The Company anticipates that the waiver of this Privacy Policy would only be in exceptional circumstances, and the Company encourages that you consider the circumstances leading to the waiver request prior to submitting such a request.
3. Governing Law & Jurisdiction
   2. This Privacy Policy is governed by the laws of Victoria, Australia. In the event of any dispute arising out of or in connection with this Privacy Policy, you agree that the exclusive venue for resolving any dispute shall be Melbourne, Victoria, Australia.

1. This Privacy Policy is available online via www.allumeenergy.com.au.
2. The Company reserves the right to modify or amend this Privacy Policy at any time, for any reason, and without any notice, by posting a revised version on its website. Any changes to this Privacy Policy will become effective when the Company posts the revised Privacy Policy on the website. If you are based in Australia, your use of the website following these changes means that you accept the revised Privacy Policy.
3. This policy was last modified on 13/10/2026.

1. Please contact the Company if you have any questions regarding this Privacy Policy. Our email is: privacy@allumeenergy.com