Privacy Policy — Luso Asset Management

Luso Asset Management is a service of Luso Energy (12 Rivers LLC).

Effective date: September 1, 2026 Provider: 12 Rivers LLC d/b/a Luso Energy ("Luso Energy," "Luso," "we," "us," or "our"), operator of the Luso Asset Management service (the "Service"). Contact: privacy@lusoinc.com · 455 Market St, Ste 1940 PMB 600753, San Francisco, CA 94105-2448


1. Who we are and what this covers

Luso Asset Management provides monitoring, fault diagnosis, performance reporting, and advisory services for solar energy systems. This Privacy Policy explains what information we access and collect, how we may use and protect it, and the choices you have.

It applies to system owners, operators, and other users whose solar systems or accounts we monitor on their authorization ("you"), and to visitors of our website.

2. Information we access and collect

a. Solar system data from connected platforms. With your authorization, we access data from third-party solar monitoring platforms you use (such as SMA, SolarEdge, and Chint). Depending on the platform, this includes plant/site location and identifying details; account and user data associated with access to the plant; measurement and sensor data from the plant and its connected devices; and log data such as error messages, alerts, and events.

We access this data only after you grant permission through each platform's own consent process, and only to provide the Service.

b. Information you provide. Contact details, account information, service preferences, and communications you send us.

c. Information collected automatically on our website. Standard technical data such as IP address, browser type, and usage information, collected through cookies and similar technologies where applicable.

3. How we may use information

We may use the information to:

  • Provide, operate, maintain, and improve the Service;
  • Monitor and analyze system and service performance;
  • Communicate with you and provide customer support;
  • Develop new features, products, and services;
  • Analyze and secure the Service, including using aggregated, de-identified data that does not identify you;
  • Comply with legal obligations and enforce our terms.

4. Authorization and third-party platforms

Access to your solar data depends on authorizations you grant through third-party platforms (for example, SMA's consent screen). Those platforms control the initial collection of your system data and have their own privacy terms. You may revoke Luso's access, and rotate or revoke credentials, at any time through the relevant platform or by contacting us, and we will stop accessing new data from that source.

5. How we may share information

We do not sell your personal information. We may share information only as needed to provide the Service:

  • Service providers and subprocessors who host, process, or support the Service, under confidentiality obligations;
  • Other third parties as needed to deliver services you request or authorize, under appropriate confidentiality obligations;
  • Legal and safety — when required by law, to enforce our terms, or to protect rights, property, or safety.

We may also use and share aggregated, de-identified performance data for internal analysis and service improvement, provided it does not identify you.

6. Data storage, security, and international transfers

We use commercially reasonable administrative, technical, and physical safeguards to protect credentials, account information, and system data; we limit access to personnel who need it to perform the Service; we store credentials using reasonable security measures; and we comply with applicable data-privacy and energy-usage-data laws. If we confirm any unauthorized access to your credentials or data, we will notify you without undue delay.

Because some connected platforms and providers operate internationally (for example, SMA is based in Germany), your information may be processed or stored in countries other than your own.

7. Data retention

We retain information for as long as needed to provide the Service, generate historical reports, meet legal or contractual obligations, and resolve disputes, after which we delete or anonymize it. Upon termination, at your request we will return or destroy your credentials and non-aggregated data.

8. Your rights and choices

Depending on your location, you may have the right to access, correct, delete, or restrict use of your information, to object to certain processing, and to withdraw authorization. To exercise these rights, contact us at privacy@lusoinc.com. You may also revoke platform access or credentials directly, as described in Section 4.

9. Children's privacy

Our services are not directed to children, and we do not knowingly collect information from children.

10. Changes to this policy

We may update this policy from time to time. We will post the updated version with a new effective date and, where appropriate, notify you.

11. Relationship to your services agreement

If you have entered into a separate written services agreement with us (such as an Energy System Monitoring Services Agreement), the data-security and confidentiality terms of that agreement also apply and control over this policy in the event of any conflict.

12. Contact us

Questions about this policy or your information: privacy@lusoinc.com · 12 Rivers LLC d/b/a Luso Energy · 455 Market St, Ste 1940 PMB 600753, San Francisco, CA 94105-2448.