Privacy Policy

Last updated: 11 February 2025

PowerWise (“Company”, “we”, “us”, or “our”), powered by Scratch Power, operates the PowerWise platform (“Service”). This Privacy Policy explains how we collect, use, store, and protect your personal information when you use the Service.

By using PowerWise, you consent to the collection and use of your information as described in this policy. If you do not agree, please do not use the Service.

1. Information We Collect

1.1 Information You Provide

When you register and use PowerWise, you provide us with:

Account information: First name, last name, email address, phone number, password, and optionally your gender and age.
Meter information: BPC meter number, meter owner name, physical address (city, suburb, country).
Household profile: Household size, dwelling type, appliances, energy-saving features, water features, security features, and lifestyle preferences.
Meter readings: Manually submitted meter reading values and dates.
Outage reports: Descriptions of power outages in your area, including location details.
Feedback: Messages, bug reports, feature requests, and other feedback you submit through the app.

1.2 Information Collected Automatically

When you use the Service, we automatically collect:

Device and browser information: User agent string, browser type, and device type.
Location data: Approximate location (city and country) derived from your IP address using the MaxMind GeoLite2 database. We do not use GPS or precise geolocation.
Usage data: Pages visited, session identifiers, and referral sources for anonymous analytics.
Login information: Login timestamps, IP addresses, and approximate location at the time of login.

1.3 Information from Third Parties

BPC (Botswana Power Corporation): When you add a meter, we retrieve meter owner details, tariff information, and purchase/consumption history from BPC’s systems. This includes historical electricity purchases, token details, and meter configuration data.
CyclePay: Our payment provider sends us transaction status updates (success or failure). We do not receive or store your payment card details.

2. How We Use Your Information

We use your information to:

Provide the Service: Process electricity purchases, generate tokens, track consumption, and calculate remaining balances.
AI-powered insights: Analyse your purchase history and consumption patterns to provide personalised recommendations, usage alerts, and cost optimisation suggestions.
Outage notifications: Match your meter location with reported outages to send relevant notifications about power disruptions in your area.
Community benchmarks: Aggregate anonymised consumption data by dwelling type and household size to provide community comparison insights.
Cashback and referrals: Calculate and credit cashback rewards, and track referral completions.
Communications: Send transactional emails (purchase confirmations, token delivery, low balance alerts) and push notifications you have opted into.
Service improvement: Analyse anonymous usage patterns to improve the platform’s features and performance.
Security: Detect and prevent fraud, abuse, and unauthorised access.

3. AI and Automated Processing

PowerWise uses artificial intelligence to analyse your electricity data and generate insights. This includes:

Consumption analysis: Your purchase history is processed to calculate daily usage rates, detect anomalies, and predict future consumption.
Personalised recommendations: AI models generate suggestions for optimal purchase amounts and timing based on your usage patterns.
Outage extraction: AI is used to extract structured outage information from BPC announcements to provide accurate notifications.

AI processing uses third-party services (see Section 5). Your data is sent to these services only as needed to generate insights and is not used to train their AI models.

4. Data Sharing

We do not sell your personal information. We share your data only in the following circumstances:

4.1 Service Providers

We share data with trusted third-party service providers who assist in operating the Service:

Provider	Purpose	Data Shared
BPC	Electricity vending and meter verification	Meter number, purchase amounts
CyclePay	Payment processing	Transaction amount, reference number
AWS (Amazon Web Services)	Cloud hosting and AI processing	Encrypted application data
Resend	Email delivery	Email address, name, email content
MaxMind	IP-based geolocation (processed locally)	IP address (not sent to MaxMind; database is local)

4.2 AI Service Providers

To generate insights, anonymised or pseudonymised consumption data may be processed by AI services including AWS Bedrock (Anthropic Claude), Google Gemini, and OpenAI. These providers process data according to their respective privacy policies and data processing agreements. No personally identifiable information (such as your name, email, or meter number) is included in AI prompts.

4.3 Legal Requirements

We may disclose your information if required by law, legal process, or government request, or to protect the rights, property, or safety of PowerWise, our users, or the public.

5. Data Storage and Security

5.1 Storage Location

Your data is stored on servers hosted by Amazon Web Services (AWS) in the EU West (Ireland) region. Our database is encrypted at rest and in transit.

5.2 Security Measures

We implement appropriate technical and organisational measures to protect your data, including:

Encryption of data in transit (TLS/SSL) and at rest
Secure password hashing
Access controls and authentication for all systems
Regular security reviews
Secrets management through AWS Secrets Manager

While we take reasonable precautions, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

5.3 Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Service. Purchase history and consumption data are retained to enable historical analysis and AI insights. If you request account deletion, we will delete your personal data within 30 days, except where retention is required by law or for legitimate business purposes (such as fraud prevention).

6. Push Notifications

With your explicit consent, PowerWise sends push notifications for:

Low electricity balance and critical balance alerts
Purchase confirmations and token delivery
Power outage notifications for your area
AI-generated consumption insights and tips
Vend failure and refund notifications

Push notification subscriptions (endpoint URL and encryption keys) are stored securely. You can disable push notifications at any time through your browser settings or device settings.

7. Cookies and Local Storage

PowerWise uses essential cookies and local storage for:

Authentication: Session cookies to keep you logged in.
Preferences: Your display preferences and settings.
Service Worker: PWA functionality for offline access and push notifications.

We do not use third-party tracking cookies or advertising cookies.

8. Your Rights

You have the right to:

Access: Request a copy of the personal data we hold about you.
Correction: Request correction of inaccurate or incomplete personal data.
Deletion: Request deletion of your account and associated personal data.
Objection: Object to certain processing of your personal data.
Data portability: Request your data in a structured, commonly used format.
Withdraw consent: Withdraw consent for push notifications or other optional data processing at any time.

To exercise any of these rights, please contact us at support@scratchpower.com. We will respond to your request within 30 days.

9. Children’s Privacy

The Service is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child under 18 has provided us with personal data, we will take steps to delete such information.

10. International Data Transfers

Your data may be processed outside of Botswana, including in the European Union (AWS Ireland) and the United States (AI service providers). Where data is transferred internationally, we ensure appropriate safeguards are in place, including data processing agreements with our service providers.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or via email. The “Last updated” date at the top of this page indicates when the policy was last revised. Your continued use of the Service after changes are posted constitutes your acceptance of the revised policy.

12. Data Protection

PowerWise operates in compliance with the Botswana Data Protection Act, 2018 (DPA). If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant data protection authority in Botswana.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: support@scratchpower.com
Website: powerwise.scratchpower.com