Legal

Data Practices Statement

Effective date: [DATE] · Virtual Power Company, Inc. (“ZEOS-AI”), in collaboration with ReWire Group LLC

PLACEHOLDER DRAFT — FOR REVIEW BY LEGAL COUNSEL BEFORE PUBLICATION. NOT YET IN EFFECT.

Scope

This statement describes how building, utility, and operational data is handled within ZEOS-AI Pilot Circle engagements. It supplements — and is subordinate to — the data terms in each participant’s Pilot Participation Agreement.

What data is used

Pilot engagements may involve utility usage data (connected via authorized data connectors or provided manually), building characteristics, system and DER information, compliance records, and related operational documents identified in the agreed pilot scope.

Purpose limitation

Participant data is used to operate the pilot, configure and evaluate platform capabilities, generate participant-specific insights and reports, and improve ZEOS-AI. It is not sold to third parties.

Access and authorization

Data connections are established only with participant authorization. Access within ZEOS-AI is limited to authorized users designated by the participant and the ReWire team members supporting the engagement.

Aggregated and anonymized data

ReWire may use aggregated, anonymized data — which does not identify a participant, building, or individual — for benchmarking, product development, and industry reporting.

Confidentiality

Identifiable property-level and participation data is treated as confidential and is not disclosed to third parties without prior written consent, except as required by law or as expressly permitted in the Pilot Participation Agreement.

Retention and deletion

Data-retention and deletion terms, including treatment of data after a pilot concludes, are defined in the Pilot Participation Agreement. Participants may direct questions or requests to their ReWire lead.

Security

ReWire maintains administrative, technical, and organizational safeguards appropriate to the sensitivity of pilot data, including access controls and secure information-exchange procedures established at onboarding.

Questions about this document may be directed to [email protected].