Privacy Policy

This privacy policy describes how Variablegrid Adaptive Power Inc. collects, uses, and protects information across its products and services, including its mobile application, connected EV charging equipment, energy management systems, customer onboarding processes, and any programs or services offered to customers.

Collection of Information

Variablegrid collects information when you interact with our products and services, including our mobile application, connected devices, and customer onboarding processes.

This information may include:

• Device and technical information, such as your IP address, device type, and operating system.
• Usage information, including how you interact with our application or services, the pages or features you access and the time and duration of your activity.
• Account and contact information, such as your first and last name, email address, and phone number.
• Address and location information related to your installation or service address, including city, province or state, and postal or ZIP code.

Variablegrid does not collect precise real-time geographic location data from your mobile device. Where our application or website uses cookies or similar technologies capable of identifying, locating, or profiling you, these technologies are disclosed and, where required by law, are activated only with your consent.

We may also request additional personal information where needed to provide our services, support your account, or complete registration or onboarding processes. Any information you provide will be collected and used in accordance with this privacy policy.

Use of Information

The information we collect is used to:

• Provide, operate, and maintain our products and services.
• Set up and manage customer accounts and installations.
• Communicate important information, including service updates, required notices, and support-related communications.
• Improve the performance, functionality, and user experience of our products and services,
• Provide customer support and respond to inquiries.
• Administer programs, services, or offerings that you choose to participate in.
• Meet legal, regulatory, and contractual obligations.
• Calculate, validate, and administer usage-based benefits, incentives, or rewards where applicable.

Some services or programs may require the collection and use of device and usage data in order to function as intended.

Connected Device and Charging Data

As part of providing our services, Variablegrid collects information from connected devices, including EV chargers and energy management systems.

This may include:

• Device identifiers such as serial numbers and system IDs.
• Installation location or service address.
• Charging session data, including energy usage (kWh), duration, and timestamps.
• System performance and diagnostic information.
• Connectivity status between devices and the network.

This information is used to:

• Enable and manage device functionality.
• Ensure safe and reliable operation.
• Provide customer support and troubleshooting.
• Administer programs, services, or benefits associated with the use of the equipment, including verifying participation and usage where applicable.

Certain features or services may depend on continuous communication between connected devices and our systems. Interruptions in connectivity may impact the availability or performance of those services.

Where Your Information Is Stored

Personal information is stored in Canada on cloud infrastructure located in Montréal, Québec and is remotely accessed by authorized Variablegrid personnel located in Canada. As a result, personal information collected from Québec residents may be communicated outside Québec for the purposes described in this policy. Variablegrid applies the same safeguards to personal information regardless of where it is accessed and does not transfer personal information outside Canada in the course of providing its services.

Compliance with Quebec's Loi 25

Variablegrid complies with Quebec’s Loi 25 on the protection of personal information. We follow best practices in transparency, explicit consent, data access, correction, and portability.

You have the right to:

• Access personal information we hold about you
• Correct any inaccurate or incomplete information
• Withdraw your consent at any time
• Request the deletion of your data
• Receive computerized personal information that you provided to us in a structured, commonly used technological format (data portability)
• Be informed of any significant use or disclosure of your personal information
• File a complaint with Quebec’s Commission d’accès à l’information (CAI) in case of non-compliance

To exercise your rights, please contact us at: support@variablegrid.com

Variablegrid has designated a person in charge of the protection of personal information, as required by Québec law. Unless this responsibility has been delegated in writing, it is exercised by Variablegrid's Chief Executive Officer, who may be reached at support@variablegrid.com.

Third-Party Access

We may share information with third parties that support the delivery of our products and services, including:

• Service providers that provide hosting, infrastructure, customer support, or payment processing.
• Partners involved in delivering programs, services, or benefits.
• Professional advisors, auditors, or compliance providers.
• Authorities where required by law.

We only share personal information where necessary to provide our services, administer programs or meet legal obligations. Aggregated or anonymized data may be shared for reporting, analytics, or program administration purposes.

Withdrawing Consent and Opting Out

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to applicable legal or contractual restrictions and reasonable notice, by contacting us at support@variablegrid.com. Withdrawing consent may limit or prevent our ability to provide certain products, services, or programs.

Data collection depends on how your equipment is set up:

• Enrolled in a program: Variablegrid collects the information described in this policy as necessary to administer the program and any associated benefits.
• Connected, but not enrolled in a program: Variablegrid collects only limited device and service data as necessary to support warranty coverage, provide troubleshooting and customer support, maintain safe and reliable operation, and meet legal or regulatory obligations.
• Connectivity disabled: where a customer is not enrolled in a program and elects to disable connectivity, the charger operates without connection and Variablegrid does not collect data from the device.

Data Retention Policy

Variablegrid will retain personal information for as long as necessary to:

• Provide our products and services
• Administer programs and associated benefits
• Meet legal, regulatory, accounting, and contractual obligations
• Resolve disputes and enforce agreements

Once these purposes have been fulfilled, personal information is securely deleted or de-identified. As a general rule, program transaction records and related audit logs are retained for up to seven (7) years following the end of program participation, after which they are deleted or de-identified in accordance with Variablegrid's retention schedule.

Minors

The Application is not intended for individuals under the age of 14. Variablegrid does not knowingly collect personal information from children under 14 years old.

If we discover that a child under 14 has provided personal information, that data will be promptly deleted from our servers. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us at support@variablegrid.com so we can take appropriate action.

Security

Variablegrid takes the security of your information very seriously. We use physical, electronic, and procedural safeguards to protect the information we process and store.

Changes

This privacy policy may be updated from time to time. Any significant changes will be communicated through an update to this page or a notification within the Application. We encourage you to review this policy regularly. Where changes materially affect how we collect, use, or disclose your personal information, we will notify you and, where required by law, obtain your renewed consent.

This policy is effective as of July 2, 2026.

Your Consent

By creating an account, enrolling in a program, or using our products and services, you consent to the collection, use, and disclosure of your personal information for the specific purposes described in this policy. You may withdraw your consent at any time as described in the section “Withdrawing Consent and Opting Out” above.

Contact Us

If you have any questions regarding privacy, data access, or your rights, please contact us at: support@variablegrid.com