Maine Transactive Energy Pilot (MTEP) Privacy Policy

Maine Transactive Energy Pilot (MTEP) Privacy Policy

Last Updated: October 15, 2025

1. Introduction

This Privacy Policy explains how Post Road Foundation (“we,” “us,” or “our”) collects, uses, shares, and protects information when you participate in the Maine Transactive Energy Pilot (“MTEP”) or use the MTEP App (the “MTEP App”), the MTEP website at mtep.postroadfoundation.org, or other applications (collectively our “Services”).

MTEP is a research project of the Post Road Foundation that has received Institutional Review Board (IRB) approval to study electric load flexibility. By participating in MTEP and using the MTEP App and MTEP website, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Contact

For questions about this Privacy Policy or our data practices, or if you would like to make a complaint, please contact:

Post Road Foundation
1999 Harrison St. STE 1800
Oakland, CA 94612
Email: privacy@postroadfoundation.org
Phone: 207-200-1362

3. Information We Collect

We collect information in several ways to operate MTEP and provide our Services to you. This includes information you provide directly, information collected automatically through our equipment and systems, and information from third parties.

3.1 Personal information that you provide directly via our website, by e-mail, text, phone, or in person:

  • Enrollment Information: Information you provide when applying to participate in MTEP through our website enrollment form.
  • Contact Information: Name, email address, mailing address, and phone number.
  • Utility Account Information: Utility name, account numbers, meter numbers, tariff rate structure, utility bills, and interconnection agreement for batteries (if applicable).
  • Secondary User Information: Names, email addresses, and phone numbers of additional household members you authorize to access your MTEP account. By adding secondary users, you are granting them access to view energy data and modify participation settings. You are responsible for informing secondary users that their information will be collected and used as described in this Privacy Policy.
  • Content You Choose to Share: Text, images, audio, video, digital signatures, and metadata associated with the files you share via e-mail, text, or upload.
  • Energy Device Information: Information about your participating energy devices (heat-pump HVAC systems, home storage batteries, heat-pump water heaters, and electric vehicles), such as make, model, serial number, and location.
  • Energy Device Vendor Account Information: Authorization to access energy device data through their manufacturer’s systems, including any tokens and identifiers needed to retrieve your data from manufacturer cloud systems.
  • Building Information: Information about your home or business, such as location (service address), square footage, year built, number of floors, number of rooms, weatherization state, occupancy, whether it has solar power, and electrical panel details.
  • Phone or Tablet Information: The make and model of your smartphone or tablet.
  • Correspondence: Any communication with us via phone, text, or email.
  • Contact or Other Form Submission: Information you provide when contacting us through our website.
  • Surveys: Any response to survey questions that we may send from time-to-time via e-mail or text. Surveys may include demographic questions.

3.2 Information collected automatically by our systems

From enabling equipment that we install:

  • Electricity Usage Data: Real-time and historical usage data from submetering, gateway, and other enabling communication equipment in your building.
  • Enabling Equipment Diagnostics: Performance and status data from the enabling equipment, including communication status and signal strength.
  • Energy Device Data: Data from energy devices other than electricity usage, such as operational status, state-of-charge, and building temperature and humidity.

Note that the MTEP App retrieves the above data from our cloud servers and displays it in the MTEP App but does not store this data on your mobile device.

From the MTEP App on your mobile device:

  • Account Information: Email address, mailing address, and phone number for you and any secondary users you designate to use the MTEP App.
  • Participation Preferences: Your preferences with regard to how you would like your energy devices to respond to grid conditions (“responsiveness choices”), whether you would like to pause participation temporarily, and goals for each device.
  • Energy Device Operating Parameters: Certain energy device settings, such as thermostat set points and preferred state of charge.
  • Energy Device Identifiers: Photos of QR codes, serial numbers, and other hardware identifiers that are used to pair your energy devices with your MTEP account.
  • App Usage Analytics: Information about how you interact with app features.
  • App Performance Data: App crashes, errors, and response times.
  • Survey questions: Answers to survey questions that we may present to you from the MTEP App regarding your participation in MTEP and use of the MTEP App.
  • Technical and App Performance Monitoring Data: Technical and app performance monitoring data is automatically collected through the MTEP App and third-party analytics SDKs. This data includes, but is not limited to:
    • Mobile device(s): Make, model, unique resettable device ID (the MTEP App does not collect persistent device identifiers, e.g., IMEI, IMSI, or SIM Serial number), IP address, Wi-Fi network information, operating system version, and network carrier information.
    • Error & Crash Data: Stack traces, error messages, and app version and build information.
    • Performance Metrics: App launch times, network requests, memory usage, battery impact, and screen load times.
    • User Context: User IDs and session duration and frequency.
  • Location Data (to enable location-based features):
    • Collecting location data requires your explicit permission on your mobile device and is not required to participate in MTEP.
    • You can choose between precise or approximate location.
    • Background location enables some automated features.
    • We will not share your current location with third parties.
    • If you do not want us to use your location, you can turn off the location services for the MTEP App (located in your mobile device settings). Disabling location services may reduce the MTEP App’s functionality.

From our website:

  • Website Analytics: We use Google Analytics to understand how visitors use our website. This includes information such as pages visited, time spent, referral sources, and general geographic location (city/state level).
  • Technical Information: We also collect technical data, including browser type, device type, and IP address (which Google Analytics may use to determine approximate location).
  • Google Analytics uses cookies to collect this information. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

3.3 Information we receive from third parties

From energy device manufacturers (through authorized API connections):

When you authorize API connections to your participating energy devices, data flows from each energy device to the energy device manufacturer's systems, and then to our system. Each energy device manufacturer's privacy policy also applies to your device data. We use manufacturer APIs to collect the following from your participating energy devices:

  • Energy Device Usage/Production Data: Electricity usage and production data.
  • Energy Device Operational Data: Battery charge levels, temperature settings, charging status, and other operational parameters.
  • Energy Device Status: System health, error codes, and operational state.

From Efficiency Maine Trust, utilities, and grid operators:

  • Building Energy Usage Data: Real-time and historical electricity consumption data for your entire building collected from Efficiency Maine Trust or your utility.

From our service providers:

  • Installation and Maintenance Records: Information from contracted electricians about enabling equipment installation, configuration, and maintenance.
  • Payment Processing: Transaction confirmations for incentive payments
  • Third-Party Survey Responses: Responses to survey questions through external survey platforms that we may send from time-to-time via e-mail or text. Survey questions may include demographics.
  • Support Interactions: Records from customer support tools.

From social media:

Information provided when you interact with us on social platforms (governed by each platform's privacy policy).

4. How We Use Your Information

We use the information we collect for the purposes described below. We do not share information with or sell information to third-party advertisers.

4.1 Primary Functions

  • Operate MTEP: Manage your participation in MTEP, coordinate enabling equipment installation, maintain your account, pair your energy devices with your MTEP account, connect to energy device manufacturer APIs, and send dispatch signals to your energy devices via enabling equipment or manufacturer APIs.
  • Security: Send security codes via email or text, remember mobile devices you've logged in from, and detect and prevent fraud and abuse.
  • Improve Services: Monitor and improve MTEP operations, app performance, and user experience; fix bugs and develop new features.
  • Communication: Send notifications to the primary account holder about MTEP operations, energy device operation, program updates, participant surveys, energy consumption reports, demand response or other load flexibility events, announcements, policy changes, security alerts, and support messages.
  • Participant Support: Provide support for your participation, respond to questions and feedback, and coordinate qualified installers to troubleshoot enabling equipment or energy device connections.
  • Display Your Data: Display, via the MTEP App, your electrical usage and production data, energy device parameters, participation preferences, and program performance.
  • Calculate and Pay Incentives: Determine enrollment, participation, and performance-based incentive payments using data from enabling equipment and energy devices. Pay such incentives to you.
  • Comply With the Law: Use your personal information as necessary to comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities, or to investigate or defend legal claims.

4.2 Research and Program Evaluation

  • Research Analysis: Analyze load flexibility effectiveness, grid impact, and energy device performance to advance understanding of transactive energy systems.
  • Program Evaluation: Assess grid and participant benefits.
  • Research Publications: Publish research findings in scientific journals, conferences, and reports
  • Prepare Anonymous, Aggregated, or De-Identified Data for Research Purposes: We create anonymous, aggregated, or de-identified data from your information and from other individuals whose information we collect by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated, or de-identified data to analyze and improve load flexibility services and share such data and any analyses with our research partners.
  • Research Collaboration: Use your anonymous, aggregated, or de-identified data to analyze the performance of MTEP in cooperation with research partners.

5. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We share data only as described below, as required by law, or with your explicit consent.

5.1 MTEP Operations and Analysis

As part of MTEP operations and analysis, we share your data with the following entities:

Program Partners

  • Efficiency Maine Trust: We may share energy usage data with Efficiency Maine Trust, in compliance with their privacy policies, to calculate incentive payments.

Research Partners

  • Institutional Review Board: We may share aggregated or de-identified data with our Institutional Review Board so that they can monitor the safety and conduct of our research.
  • Academic and Other Partners: We may share aggregated or de-identified data with research partners. We only share data that has been stripped of personal identifiers.

Publication Channels

Analysis of anonymized data may be published in scientific journals, research reports, and other academic channels.

Service Providers

We may share your information with trusted service providers who work on our behalf, including, but not limited to:

  • Installation Contractors: Contact and site information for equipment installation, maintenance, and support.
  • Cloud Infrastructure: Secure computing, data storage, and backup services.
  • Analytics Providers: Performance monitoring and usage analysis.
  • Incentive Payment Processors: Secure payment transactions for incentives.
  • Customer Support Tools: Technical support and customer service platforms.
  • Communication Servicers: E-mail, phone, and text services for program notifications.

5.2 Legal Requirements

We may disclose your personal information to law enforcement, government authorities, and private parties, as necessary, to:

  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
  • Enforce the terms and conditions that govern our Services.
  • Protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
  • As required by law, such as to comply with a subpoena, or similar legal process.

5.3 Business Transfer

In the event that Post Road Foundation is involved in a merger, acquisition, or sale of all or a portion of its assets or transfer of its grant funding to another entity, your information may be transferred to the new entity, subject to this same Privacy Policy. You will be notified via email and/or a prominent notice on the MTEP website of any choices you may have regarding this information.

5.4 With your consent

We may share your information for other purposes with your explicit consent, such as featuring your success story or sharing testimonials.

6. Data Security

Post Road Foundation implements best-practice technical, administrative, physical, and cybersecurity safeguards to protect your personal information from loss, unauthorized access, destruction, misuse, modification, and improper disclosure. While no system can guarantee absolute security, Post Road Foundation is committed to minimizing security risk. Users are warned, however, that no system can ever be fully protected against every possible hazard. Comprehensive security measures include:

  • Encryption: Data at rest is encrypted. Data in transit is secured using TLS 1.2 or higher.
  • Access Control: Strict access control is implemented based on the principle of least privilege. Access to your information is limited to employees, affiliates, and contractors who need the information to operate or improve our Services. These individuals must comply with this Privacy Policy. Access is audited on a regular basis.
  • Network Security: MTEP databases reside in a private subnet within a virtual private cloud, protected by security groups and network access control lists.
  • Monitoring and Logging: Continuous monitoring is conducted to detect and respond to suspicious activity in real time.
  • Backups: Regular backups are performed with tested disaster recovery procedures.
  • Security Updates: Systems are regularly updated and patched to address security vulnerabilities.
  • Third-Party Validation: Regular penetration testing and third-party security audits are conducted.

7. Data Retention

We retain your information for as long as necessary to fulfill the purposes we collected it for, including legal, accounting, and research purposes.

  • Account Information: Your name, contact information, and account details are retained while you participate in MTEP and for up to 3 years after your participation ends.
  • Energy Device Specifications and Identifiers: Your energy device specification (make and model) and identifiers (serial number and other identifiers, and photos of QR codes and bar codes) are retained while you participate in MTEP and for up to 3 years after your participation in MTEP ends.
  • Energy Device Data: Data from energy devices, whether conveyed via enabling equipment or energy device APIs, is retained for up to 5 years after MTEP ends, to complete research analysis and meet regulatory requirements.
  • Building Information: Your building information is retained while you participate in MTEP and for up to 3 years after your participation in MTEP ends.
  • Anonymized data: We retain anonymized, aggregated, and de-identified data indefinitely for ongoing research purposes. This data cannot be linked back to you.
  • App Performance Data: Log files and app analytics are retained while you participate in MTEP and for up to 2 years after your participation ends.
  • Incentive payments: Incentive payment records are retained while you participate in MTEP and for up to 7 years after your participation ends.

8. Your Privacy Rights and Controls

8.1 Rights for all participants

You have the following rights under this Privacy Policy and applicable data protection laws:

  • Right to Be Informed: You have the right to know how your personal information is collected, used, and shared. This information is provided in this Privacy Policy.
  • Right of Access: You can request confirmation of whether we are processing your personal information and access a copy of that information.
  • Right to Rectification/Correction: You can request that we correct inaccurate or incomplete personal information.
  • Right to Data Portability: You can request a copy of your information in a structured electronic format.
  • Right to Erasure/Delete, Restrict Processing or Object: You can request that we delete your information, limit processing or analysis of your information, or object to the processing or analysis of your information. Note that some data may be retained as required, e.g., financial records and de-identified data already used in research. Data deletion requires ending your participation in MTEP.
  • Right to Withdraw: You can withdraw from MTEP at any time without penalty by emailing mtep@postroadfoundation.org. You will receive confirmation within 30 days. Upon withdrawal:
    • Future incentive payments will stop.
    • New data collection will stop immediately.
    • Previously collected de-identified data may be retained for research.
  • Right to Manage Energy Device Connections: You have the right to revoke access to any or all of your energy devices at any time, whether those devices are connected via MTEP-provided enabling equipment or manufacturer API. Please contact us to revoke connection. Revoking connections will affect incentive calculations and program features.
  • Right to Opt Out of Optional Communications: You can opt out of program communications, except essential operational messages.

8.2 Additional Privacy Rights

If you are a resident of certain U.S. states, you may have additional privacy rights.

  • California Residents: You may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion of your personal information, the right to opt-out (we do not sell personal information, but you can opt-out if our practices change), and the right to non-discrimination.
  • Maine Residents: Your privacy rights are protected under Maine law. Maine utility regulations provide additional protection for your energy usage data. We comply with all Maine Public Utilities Commission requirements regarding the collection, storage, and sharing of electricity consumption information.
  • Other States: Residents of Colorado, Connecticut, Utah, Virginia, and other states with privacy laws may have similar rights. Contact us to learn about your state-specific rights.

To exercise these rights, contact us as described in Section 2. We will respond to your request within 30 days, or the timeframe required by applicable law, whichever is shorter.

9. Children's Privacy

  • MTEP is not intended for children under 13.
  • MTEP participants must be 18 or older
  • We do not knowingly collect personal or other information from anyone under the age of 13. If we discover a child under 13 has provided information, we will delete the information promptly.
  • If you become aware that any child that you are responsible for has provided us with information without your consent, you should contact us. We will delete such information from our files as soon as reasonably practicable.

10. Data Storage and Transfers

Primary Storage: Your personal information and energy consumption data is stored on secure servers located within the United States.

Third-Party Services: Some third-party services we use (such as software development, analytics, customer support, or payment processing) operate globally and may process data outside of the U.S. These services are bound by strict data protection agreements and use appropriate safeguards to protect your information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. Most changes are effective when posted.

We will notify you of changes by:

  • Posting the updated policy in the MTEP App and on the MTEP website.
  • Sending an email notification to the primary account holder's email address (for material changes).
  • Updating the “Last Updated" date at the top of this policy.

Your continued participation in MTEP after such modifications constitutes acceptance of the updated Privacy Policy.