Legal
Privacy Notice
Effective date: 17 May 2026 · Last updated: 21 June 2026
1. Who we are
EM AI Ltd, trading as Energy Modeller (“we”, “us”), acts in two capacities:
- As data controller— for personal data about our installer users (account, billing, usage).
- As data processor— for personal data about installers’ end customers (homeowners / business customers), which the installer collects and controls. We process it on the installer’s documented instructions to run the Service for them.
Registered office: 2 Edensmuir Court, Glenrothes, KY7 6GQ, Scotland (registered in Scotland, company number SC892873). ICO registration number: ZC176891. Contact: privacy@energymodeller.com.
2. What we collect
From installers (as controller): email, company name, website, phone, brand colours, MCS certificate number, billing details (handled by Stripe; we store only payment IDs and subscription state), service-account audit logs.
From installers’ end customers (as processor on behalf of the installer):name, address, postcode, email, phone, energy bill data, questionnaire responses, chatbot conversations, signature metadata (IP, timestamp, T&Cs hash), smart-meter consumption data (when authorised via n3rgy or similar).
3. Why we process it
- Service delivery— lawful basis: contract. Running the platform you signed up for.
- Billing— lawful basis: contract + legal obligation.
- Service improvement & analytics— lawful basis: legitimate interest, balanced against your privacy.
- Customer support— lawful basis: legitimate interest.
- Marketing emails(only to installers, not end customers) — lawful basis: legitimate interest (B2B) with opt-out in every email.
3a. How recommendations work — and how we keep your data siloed
When we generate a recommendation or quote for an installer, we process that installer’s own identifiable customer records (postcode, usage, quote activity, etc.) to return the result to that installer. We do this as the installer’s processor— on their data, for their eyes only, as part of delivering the Service they signed up for.
We do not pool one installer’s data with another’s. The results you see on your own leads and quotes are always computed from your own account’s data — never from another account’s identifiable customers, quotes or commercial figures. (If in future we introduce any platform-wide model improvement, it would use only aggregated, de-identified data that identifies no individual, and we would update this notice before doing so.)
What we do NOT do: we do not send installer or end-customer personal data to any third-party AI vendor for that vendor to train on. Our AI sub-processors (e.g. Anthropic, OpenAI) are used on no-training / zero-retention API terms — they process a request to return a result and do not retain it to train their models.
4. Who we share data with
We use the following subprocessors to deliver the Service. We hold data processing agreements with the processors that handle personal data; processors tied to an optional feature (e.g. voice, smart-meter data) or an installer-connected integration are covered by a DPA before that feature or integration is enabled:
- Vercel— hosting, edge network + file storage (US/EU)
- Neon— primary application database (PostgreSQL; UK/EU region)
- Upstash— cache, queues + transient state (EU region)
- Stripe— subscription billing + payment processing
- Resend— transactional email delivery (EU)
- Anthropic— Claude AI for chat, extraction, recommendations (no-training / zero-retention API terms; DPA in place)
- OpenAI— voice transcription + realtime voice (no-training / zero-retention API terms; voice is demo-only at launch — no real-customer voice processed yet)
- ElevenLabs— text-to-speech for the Em voice assistant (voice is demo-only at launch)
- PostHog(EU region) — product analytics + optional session replay (consent-gated; off by default; see section 8)
- Reonic / OpenSolar / Easy PV— design-tool integrations (only when installer explicitly authorises)
- QuickBooks / Xero— accounting integrations (only when installer explicitly connects)
- n3rgy / ElectraLink / Octopus— UK smart-meter consumption-data access (only with explicit end-customer consent; not enabled by default)
- Ideal Postcodes(IDDQD Ltd) — UK address autocomplete (processes only the address you type; UK/EU)
- PVGIS— European Commission solar irradiance dataset (postcode-level lookup, no personal data sent)
5. Retention
- Account data: lifetime of the account, then 6 years post-closure for tax / accounting compliance.
- Quote / share-link data: 30 days from creation, then auto-deleted (unless extended for legal / contractual reason).
- Signed-contract artifacts (signature metadata, T&Cs hash, quote figures hash): 7 years from signing, per UK tax + contract retention norms.
- Service-plan customer records: lifetime of the service plan + 6 years post-cancellation.
- Audit logs & server logs: 90 days rolling.
6. Your rights
Under UK GDPR you have the right to:
- Access your data
- Rectify inaccurate data
- Erase your data (subject to retention legal requirements)
- Restrict or object to processing
- Data portability (export)
- Complain to the Information Commissioner’s Office (ico.org.uk)
To exercise any of these, email privacy@energymodeller.com. We respond within one month (UK GDPR Art. 12(3)), and will tell you promptly if a request needs identity verification or an extension for complexity.
Installers can self-serve a machine-readable export of their account data at any time from their account settings. End customers (homeowners): because the installer is the controller of your data, send access or erasure requests to your installer; we action them on the installer’s instruction as their processor, or directly if you contact us and we route it to them.
7. International transfers
Some subprocessors (Vercel, Anthropic, OpenAI, ElevenLabs, Stripe) process data in the US. We rely on Standard Contractual Clauses + the UK Addendum and, where applicable, the EU-US Data Privacy Framework.
8. Cookies
We use a single httpOnly session cookie (__Host-em_session) for authentication, which is strictly necessary and needs no consent. We also use PostHog (EU region) for product analytics and session replay to understand how the product is used and improve it. PostHog is off by default and only starts after you accept non-essential cookies via the banner; it is disabled for our own staff sessions, does not auto-capture every click, and masks form inputs. Session replay is switched off entirely on customer- facing pages (proposal, intake, formal-quote). You can decline at any time and we respect Do-Not-Track.
9. Changes
Material changes to this Notice will be emailed at least 30 days before they take effect.