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Sentinel™ Privacy Policy

How Sentinel EMS Ltd collects, uses and protects your personal data. Version 1.0.

This Privacy Policy explains how Sentinel EMS Ltd ("Sentinel", "we", "us", "our") collects, uses, shares and protects your personal data when you use the Sentinel service or interact with us. It applies to residential and commercial customers of the Sentinel service, visitors to our website, and anyone else whose personal data we hold.


We are the controller of your personal data. Sentinel EMS Ltd is registered in England and Wales (registered number 16914668). Our registered office is at Lynnem House, 1 Victoria Way, Burgess Hill, West Sussex, England, RH15 9NF. If you have any questions about this policy or how we handle your data, please contact us at support@sentinelems.co.uk.

  • When you use the Sentinel service, we collect the following categories of personal data. Not all of these apply to every customer — it depends on how you use the service.

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    • Contact and account information: your name, address, email address, telephone number, and (for business customers) your company name, company number and the name of the person signing up on the company's behalf.

     

    • Authentication information: your Sentinel account username and password, and (where applicable) multi-factor authentication settings.

     

    • Property and asset information: the address of your Property, the make, model and specifications of your Compatible Energy Asset, and your smart meter MPAN.

     

    • Energy data: half-hourly smart meter readings, energy import and export data, solar generation data, battery charge and discharge data, telemetry from your Compatible Energy Asset, and device event and fault logs.

     

    • Tariff and supplier information: your current energy supplier, your tariff name and unit rates.

     

    • Payment information: your Direct Debit bank details and payment history.

     

    • Correspondence: any messages you send us and any support requests you raise, including through the Sentinel app.

     

    • Website and app usage data: information about how you use our website and the Sentinel app, including IP address, device type, browser type and pages viewed.

  • We collect personal data in the following ways:

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    • directly from you, when you sign up for the service, complete the Signup Form, contact our support team or interact with our website or app;
       

    • automatically from your Compatible Energy Asset and smart meter, once you have given us permission to access them;
       

    • from your energy supplier and the Data Communications Company (DCC), where you have authorised us to receive smart meter data on your behalf; and
       

    • from our approved Intelligent Energy Partners and other third parties who help us deliver the service.

  • We use your personal data for the following purposes. Under the UK GDPR we need a legal basis for each purpose, which we set out below.

    Purpose
    Legal basis
    To provide the Sentinel service to you (monitoring, optimisation and grid services participation).
    Performance of our contract with you.
    To operate your Compatible Energy Asset (charge, discharge, register in grid programmes).
    Performance of our contract with you.
    To calculate and pay your share of Grid Services Revenue.
    Performance of our contract with you.
    To send you service and account communications (including onboarding, signup confirmations, service alerts and change notices).
    Performance of our contract with you.
    To take payment of your Subscription Fee by Direct Debit.
    Performance of our contract with you.
    To handle your questions, complaints and support requests.
    Performance of our contract with you, and our legitimate interests in running a properly supported service.
    To improve the Sentinel service through analytics and (where fully anonymised) machine-learning.
    Our legitimate interests in improving our product and service, and — where identifiable data is involved — your consent.
    To comply with our legal, regulatory and tax obligations.
    Compliance with a legal obligation.
    To send you marketing about other Sentinel products and services, where you have opted in.
    Your consent (which you can withdraw at any time).

    Where we rely on your consent, you can withdraw that consent at any time by emailing support@sentinelems.co.uk. Withdrawing consent doesn't affect the lawfulness of any processing we carried out before you withdrew it.

  • The Sentinel service uses automated software to make continuous decisions about when to charge and discharge your Compatible Energy Asset, and about whether and how to enter it into grid flexibility programmes. These automated decisions are how the service delivers your bill savings and your Grid Services Revenue, and are part of the service you have signed up for. They do not have a legal or similarly significant effect on you within the meaning of Article 22 of the UK GDPR. You can override automated control at any time through the Sentinel app or by contacting our support team.

  • We share your personal data with the following categories of third party, only where doing so is necessary to deliver the service or to meet a legal obligation:

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    • Our approved Intelligent Energy Partners, who operate the software platforms Sentinel uses to connect to and control your Compatible Energy Asset. These partners act as our sub-processors.
       

    • Your energy supplier, where we need to share your tariff, MPAN or settlement data to deliver the service.
       

    • Distribution Network Operators (DNOs), the National Energy System Operator (NESO), and grid services programme operators, where we need to register your Compatible Energy Asset to participate in grid services.
       

    • The Data Communications Company (DCC), to access half-hourly smart meter data on your behalf.
       

    • The manufacturers of your Compatible Energy Asset, where we need to share diagnostic or telemetry data to resolve a fault.
       

    • Our cloud hosting provider, who hosts the Sentinel platform in UK data centres.
       

    • Our customer support and CRM providers, who help us manage your account and answer your queries.
       

    • Our email service provider, who sends transactional emails (signup confirmations, service updates, receipts) on our behalf.
       

    • Our payment processor and bank, for the purpose of taking Direct Debit payments and paying your share of Grid Services Revenue.
       

    • Our professional advisors, auditors and insurers, where reasonably needed.
       

    • Law enforcement, regulators or courts, where we're required to do so by law.
       

    • A successor to our business, if we sell or restructure Sentinel.
       

    We do not sell your personal data to anyone.

  • All processing of your personal data takes place in the United Kingdom. If in future we need to transfer your personal data outside the UK, we will only do so where a valid transfer mechanism (such as the UK International Data Transfer Agreement) is in place, and we will update this Privacy Policy to reflect that.

  • We keep your personal data only for as long as we need it for the purposes we collected it for, and to meet our legal obligations. In practice, this means:
     

    • Account and service data: for the duration of your Sentinel account, and for up to 90 days after you close your account so we can settle any outstanding revenue share payments and handle any post-termination queries.
       

    • Energy and telemetry data: for the duration of your Sentinel account. On request, we can provide you with a copy of your data (for example as a CSV file) before we delete it.
       

    • Payment records: for at least 6 years after the end of the financial year in which the payment was made, to comply with our tax obligations.
       

    • Correspondence: for up to 3 years, so we can handle repeat queries and complaints.
       

    • Anonymised and aggregated data: indefinitely, for product improvement and analytics — as this data no longer identifies you, it is no longer personal data.

  • We take the security of your personal data seriously and use appropriate technical and organisational measures to protect it against loss, misuse, unauthorised access, alteration and disclosure. These measures include encryption of data in transit and at rest, access controls with multi-factor authentication for administrative access, network security controls, staff training, secure backups, and regular reviews of our security posture.
     

    If we ever become aware of a breach affecting your personal data, we will notify you and the Information Commissioner's Office (ICO) where the law requires us to do so.

  • Under the UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:
     

    • Access: you can ask us for a copy of the personal data we hold about you.
       

    • Rectification: you can ask us to correct any personal data that is inaccurate or incomplete.
       

    • Erasure: you can ask us to delete your personal data in certain circumstances (for example if you have closed your account and we don't need it for another purpose).
       

    • Restriction: you can ask us to limit how we use your personal data in certain circumstances.
       

    • Portability: for personal data you have given us and that we process by automated means, you can ask us to give you a copy in a commonly used, machine-readable format (such as CSV) or to send it to another provider.
       

    • Objection: you can object to us processing your personal data where we rely on legitimate interests (including for marketing).
       

    • Withdraw consent: where we rely on your consent, you can withdraw it at any time. If you withdraw consent to essential processing (such as accessing your smart meter data), we may no longer be able to provide the Sentinel service to you.
       

    • Complain to the ICO: you can lodge a complaint with the UK's data protection regulator, the Information Commissioner's Office, at ico.org.uk or 0303 123 1113. We'd appreciate the chance to address your concerns first — please contact us at support@sentinelems.co.uk.
       

    To exercise any of your rights, email us at support@sentinelems.co.uk. We will respond within one month. There is no charge unless your request is manifestly unfounded or excessive.

  • Our website uses cookies and similar technologies to help the site work properly and to understand how visitors use it. Some cookies are essential; others are optional and only set with your consent. Please see our Cookie Policy on our website for details of the cookies we use and how you can manage them.

  • The Sentinel service is not intended for children under 18. We do not knowingly collect personal data from children. If you believe we hold personal data about a child, please contact us at support@sentinelems.co.uk and we will delete it.

  • We may update this Privacy Policy from time to time to reflect changes in how we process personal data or in the law. Where we make a material change, we will notify you by email or through the Sentinel app. The version in force at any time is the version published on our website.

  • If you have any questions about this Privacy Policy or how Sentinel uses your personal data, please contact us at:

    Sentinel EMS Ltd

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    Lynnem House, 1 Victoria Way, Burgess Hill, West Sussex, England, RH15 9NF

    Email: support@sentinelems.co.uk

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