Privacy notice

1. Who is responsible

Energy Lens (Pty) Ltd, trading as PowerSync, is the responsible party for the personal information described here. We decide why and how it is processed.

Our Information Officer is The Information Officer, contactable at info@powersync.co.za. Our full particulars, including registration number and address for service, are on the company disclosures page.

2. What this notice covers

It covers everyone whose personal information we process in running the programme: residents who enrol, people who write to us, installers we appoint, and people who work for the municipalities and companies we deal with. Where a section applies to one group only, it says so.

It also covers this website. This site sets no advertising or analytics cookies, loads nothing from a third-party origin, and does not track you across other sites. There is no cookie banner because there is nothing to consent to. The resident app sets cookies that are strictly necessary to keep you signed in; those are described in section 9.

3. Where the information comes from

From you — when you enrol, when you write to us, and when you use the app.
From your controller — electrical measurements and state, automatically, while you are in the programme.
From the installer — the record of the work done at your home, including photographs of your distribution board before and after.
From your municipality — confirmation that a supply point is on its network and eligible, where it provides that.

We do not buy personal information, and we do not enrich what you give us from data brokers or social networks.

4. What we process, why, on what basis, and for how long

POPIA requires a lawful basis for each purpose. Most of what we do is necessary to perform the agreement between us, which means it is not something you can consent to separately without leaving the programme. Only the last row rests on consent, and it is optional.

Category	What	Purpose	Lawful basis	Retention
Identity and contact	Name, email address, mobile number, physical address of the supply point.	To identify you, arrange installation, operate your account, send service messages, and contact you about your own device.	Necessary to conclude and perform the agreement between us (section 11(1)(b)).	For the duration of your participation, then five years, to meet the record-keeping periods in the Companies Act 71 of 2008 and the Consumer Protection Act.
Supply point	Meter number, municipal account reference where you give it, municipality and suburb.	To confirm that your home is on a participating municipal supply, and to attribute measured reduction to the right network.	Necessary to perform the agreement (section 11(1)(b)).	As for identity and contact.
Device telemetry	Electrical measurements from the geyser circuit and the main incomer, controller state, connectivity, firmware version, and each instruction sent to the device with its outcome.	To operate the control, to show you what happened, to answer support accurately, to verify the load reduction, and to detect faults.	Necessary to perform the agreement (section 11(1)(b)), and our legitimate interest in a programme whose results can be audited (section 11(1)(f)).	Identifiable telemetry for 24 months. After that it is aggregated or de-identified, and the de-identified series is kept indefinitely for measurement.
Consent records	Each consent you gave, the version of the wording, the date and time, and the channel it was given through.	To prove that participation was voluntary and informed. This record protects you as much as us.	Legal obligation and our legitimate interest in demonstrating compliance (sections 11(1)(c) and 11(1)(f)).	Five years after your participation ends.
Installation record	Installer identity and registration number, device serial number, certificate of compliance reference, date, and photographs of the distribution board before and after the work.	Traceability of electrical work, safety, warranty and dispute resolution.	Legal obligation and performance of the agreement (sections 11(1)(c) and 11(1)(b)).	Five years after the controller is removed, in line with the retention expected for electrical certification records.
Support correspondence	Messages you send us and our replies.	To answer you, and to see whether the same fault is recurring.	Performance of the agreement and our legitimate interest in improving the service.	Three years from the last message in the thread.
Programme updates	Your email address and mobile number, flagged as having opted in.	Occasional news about the programme. This is optional and separate from service messages.	Your consent (section 11(1)(a)), withdrawable at any time.	Until you withdraw consent, then a suppression record so we do not contact you again.

We do not process special personal information as defined in section 26, and we do not process the personal information of children knowingly. The programme is entered into by the account holder for a supply point.

5. What we do not do

We do not sell personal information. There is no circumstance in which we would.
We do not share it for advertising, and we run no advertising technology.
We do not give your household’s identifiable consumption to your municipality. It receives aggregated programme results.
We do not use your data to build a profile of your household for any purpose other than running and measuring the programme.
We take no automated decision that has a legal effect on you or affects you substantially, within the meaning of section 71. The controller’s switching decisions are automated, but they are bounded by your hot-water floor and your boost button and they do not decide anything about you.

6. Who else sees it

Only the operators below, only for the role stated, and only to the extent the role needs. Each is bound by a written agreement requiring confidentiality and security measures, as section 21 requires.

Operator	Role	Where it processes
Vercel Inc.	Hosting and content delivery for this website and the resident app	United States, with edge delivery worldwide
Railway Corp.	Hosting for the programme API and its database	United States and the European Union
Clerk Inc.	Authentication — sign-in for the resident app	United States
Resend Inc.	Transactional and service email delivery	United States
The mobile network operator and SIM provider for each controller	Carriage of the controller's data connection	South Africa
Appointed installers	Installation and removal of the controller at your home	South Africa
Your municipality	Aggregated programme results only — not your household's identifiable data	South Africa

We may also disclose information where the law requires it, to establish or defend a legal claim, or to protect someone’s life or safety. If we are ever compelled to disclose your information we will tell you, unless we are prohibited from doing so.

7. Information that leaves South Africa

Some of the operators above are outside South Africa, so your personal information is processed abroad. Section 72 permits this in defined circumstances. We rely on two of them:

Section 72(1)(a) — each of those operators is bound by an agreement with us that imposes data-protection obligations substantially similar to Chapter 3 of POPIA, including a prohibition on onward transfer to a third country that does not provide an adequate level of protection.
Section 72(1)(b) — for the processing that is necessary to perform the agreement between us, such as sending you an email or keeping you signed in to the app.

Device telemetry and the programme database are held in the operators’ infrastructure as described above. If we move a system to a South African region we will update this notice and say when.

8. How it is protected

Everything travels over encrypted connections, and is encrypted where it is stored.
Each controller has credentials of its own and may only publish and subscribe on the topics belonging to that device. One compromised device cannot read or command another.
Every instruction we send a controller carries a time after which it is no longer valid, so a captured or delayed instruction expires rather than being replayed later.
Access to production data is limited to the people who need it, and is logged.
This website serves a strict content security policy, sends no data to third-party origins, and loads its fonts from its own domain.

If a security compromise occurs in which your personal information has been accessed or acquired by an unauthorised person, we will notify you and the Information Regulator (South Africa) as section 22 requires, in writing, with what we know and what you should do.

9. Cookies and similar technology

This marketing website sets no cookies. The resident app sets cookies that are strictly necessary: a session cookie to keep you signed in, set by our authentication provider, and local storage on your device holding the app’s offline queue and your display preferences. None of it is used for advertising or for tracking you elsewhere, and none of it is shared.

10. Your rights, and how to use them

To be told what we hold: Ask, and we will tell you what personal information about you we hold, and who we have given it to. This is section 23 of POPIA and it is free to ask.
To have it corrected or deleted: If something is wrong, out of date, misleading, excessive or was obtained unlawfully, ask us to correct or delete it. That is section 24. We act on it, and we tell you what we did.
To object: You may object to processing that rests on legitimate interest, on reasonable grounds relating to your situation. Section 11(3)(a).
To withdraw consent: Where processing rests on your consent — programme updates — you may withdraw it at any time without affecting what was lawful before you did. Section 11(2)(b).
To leave the programme: Withdrawal from the programme is not a data right; it is simpler than one. It is a setting in the app, it needs no reason, and it costs you nothing.
To complain: To us first, at info@powersync.co.za, and to the Information Regulator (South Africa) whether or not you have come to us. Their complaints address is complaints.IR@justice.gov.za and their site is inforegulator.org.za.

Write to info@powersync.co.za. We will acknowledge within five business days and answer within thirty days. Where a request must be made on the prescribed form, the PAIA manual explains which form and where to send it. We may ask you to confirm your identity, because handing your information to someone who is not you would be the worse failure.

11. Complaints

Come to us first if you want the problem fixed quickly, but you do not have to. You may complain directly to the Information Regulator (South Africa):

Email complaints.IR@justice.gov.za · Website inforegulator.org.za

12. Changes to this notice

This notice is versioned. When we change it materially we raise the version, change the effective date, and tell participating residents through the app and by email before the change takes effect. We do not make a material change retrospectively, and we do not treat continued use as agreement to a change we did not tell you about.