GEM Energy Privacy Policy

Last Updated: June 2026

1. Introduction
GEM Energy Australia Pty Ltd (referred to as “GEM Energy”, “RACQ Solar”, “we”, “our”, or “us”) is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy (Policy) outlines how we collect, use, disclose, store and protect your personal information when you interact with our products, services, websites, and related platforms.

This Policy applies to all employees, contractors, and third parties acting on behalf of GEM Energy. By accessing this page, you acknowledge that the terms herein serve as the formal notice to you under APP 3, APP 4, and APP 5. GEM Energy collects personal information for the purposes of providing and delivering our products and services, preparing quotes and proposals, communicating with clients and complying with legal obligations.
This notice is provided in accordance with APP 3, APP 4 and APP 5 to ensure transparency and trust in how we handle your personal information. This clause 1 is tied to clause 14 (Consent) of this Policy where your continued use of our services constitutes your consent to this collection and use of personal information as described
here in.

2. What Personal Information We Collect:

We collect personal information that is reasonably necessary to carry out our business functions.

This may include:

• Name
• Email address
• Phone number
• Mailing or installation address
• RACQ membership number (if applicable)
• Energy usage data (e.g. electricity bills)
• Property details (e.g. roof type, number of storeys)
• Images/videos (e.g. meter box, switchboard or site photos)
• Any other information you provide to us 

You may choose not to provide personal information, however this may limit our ability to provide our services.

3. How We Collect Personal Information

We may collect your information through:

● Website forms (gemenergy.com.au and racq.com.au)
● Phone, email, or in-person interactions
● Quote requests and site assessments
● Newsletter subscriptions
● Customer service interactions
● Third-party partners (where relevant)

4. How We Use Your Personal Information

We use personal information to:

● Provide and deliver our products and services
● Prepare quotes, system designs and proposals
● Communicate with you
● Send service updates and installation information
● Improve customer experience and services
● Conduct marketing (where permitted)
● Comply with legal obligations

5. Marketing Communications

We may send marketing communications where you have opted in or where it is reasonably expected. You may opt out at any time. All communications comply with the Spam Act 2003 (Cth) and include an unsubscribe option.

6. Disclosure of Personal Information

We do not sell or rent personal information.

We may share information with trusted third parties, including:

● Contractors and installation partners
● Equipment manufacturers
● Energy utilities (e.g. grid connection providers)
● Finance providers
● IT and cloud service providers
● RACQ and affiliated entities where relevant

Some third parties may be located overseas. Where this occurs, we take reasonable steps to ensure your data is handled in accordance with Australian privacy laws.

7. International Data Transfers

Where personal information is transferred outside Australia, GEM Energy ensures appropriate safeguards are in place to protect your data in line with Australian Privacy Principles. Before disclosing personal information overseas, GEM Energy ensures recipients are subject to substantially similar protections or obtains informed consent.

8. Data Retention and Security

We retain personal information only for as long as necessary to fulfil its purpose or meet legal obligations, including warranty periods. We implement appropriate technical, administrative, and physical safeguards to protect personal information from misuse, loss, unauthorised access, or disclosure. When information is no longer required, it is securely destroyed or de-identified.

9. Data Breach Notifications and Complaints Handling

In the event of a data breach likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme.

If you believe GEM Energy has breached the APPs or mishandled your personal information, you may lodge a complaint in writing to us by sending an email to: info@gemenergy.com.au.  We will acknowledge receipt of your complaint within a reasonable period, investigate the matter and provide a written response. If you are not satisfied with our resolution, you may escalate the complaint to OAIC.

10. Access and Correction of Personal Information

You may request access to or correction of your personal information by contacting us. Requests will be responded to within a reasonable period. We may refuse access where permitted by law.

11. Cookies and Website Analytics

Our website may use cookies and similar technologies to enhance user experience and analyse website traffic. You may adjust your browser settings to refuse cookies, however this may affect functionality.

12. Non-Personal Information

We may collect non-identifiable data such as browser type, device, and usage patterns to improve our services and website performance.

13. Use of Artificial Intelligence (AI)

GEM Energy utilises artificial intelligence (AI) technologies to support internal operations and service delivery. The Company has designated two approved AI platforms for general business use:

Gemini (Google Workspace Enterprise Plus)

Gemini is integrated within GEM Energy’s existing Google Workspace environment and inherits the same enterprise-grade security, access controls, and data handling practices applied across all Workspace services. Interactions with Gemini stay within the organisation. Content entered is not shared with other customers and is not used for AI model training outside of GEM Energy’s domain.

Claude AI (Anthropic)

Claude AI has been selected for its strong security posture, data protection commitments, and suitability for advanced operational and development tasks. Under GEM Energy’s subscription, content entered is not used to train AI models. Data is processed on Anthropic SOC 2 Type II certified infrastructure in the United States and is subject to Anthropic’s privacy policy. Content flagged by automated safety systems may be reviewed by Anthropic in accordance with their usage and privacy policies.

Gemini and Claude have been selected due to their enterprise-grade security, data protection commitments, and integration with existing security protocols. This policy applies to all employees, contractors, and third parties.

Responsible Use

● All AI-generated content must be reviewed, edited, and fact-checked
● AI is a support tool and does not replace professional judgement
● Personal Identifiable Information (PII), Sensitive Personal Information (SPI), or confidential data must not be entered into AI tools without approval
● Copyrighted material must not be used without appropriate rights External Use
● AI-generated content must be rewritten and verified before external use
● Publishing unedited AI-generated content is prohibited Prohibited Use
● Generating harmful, misleading, or unlawful content
● Breaching company policies or legal obligations
● Misuse of confidential or proprietary information

Approved Platforms

Only Gemini within Google Workspace and Claude AI are approved. Any external AI tools require written approval from the Manager, IT & Automations. Compliance Failure to comply may result in disciplinary action, including termination and potential legal consequences.

14. Consent

By providing personal information, you consent to its collection and use as outlined in this policy.

15. Changes to This Policy

This Privacy Policy may be updated from time to time. The latest version will always be available on our website.

16. Contact Us

For questions, concerns regarding this Privacy Policy, or if you believe your privacy has been breached, please contact:

GEM Energy Australia Pty Ltd (RACQ Solar)
Email: info@gemenergy.com.au
Head Office:
Unit 3A, 17 Sugarmill Road
Pinkenba QLD 4008