EU Data Act

1. Purpose of this Notice

This notice is published by Axioma Metering in accordance with Regulation (EU) 2023/2854 (the “EU Data Act”). It explains the categories of data generated by Axioma Metering’s connected products, how data may be accessed, and under what conditions data may be shared with authorised third parties.

This notice does not replace Axioma Metering’s Privacy Policy. Personal data processing is governed separately under applicable data protection legislation, including Regulation (EU) 2016/679 (GDPR).

Important notice about Axioma Metering’s products deployment and usages. Axioma Metering is a manufacturer and technology supplier of smart metering devices and supporting software platforms. In the substantial majority of deployments, Axioma Metering sells smart meters and software to Utilities, municipalities, and other metering service operators (collectively, “Operators”). The Operator connects the meters to its own infrastructure, installs them at end-user premises, and operates them within its own systems. Axioma Metering does not have access to end-user measurement data or personal data in such deployments. End users who wish to access, correct, or port their consumption or metering data should therefore contact their Utility or metering service provider directly.

Axioma Metering’s EU Data Act obligations arise primarily in two capacities:

• As a product manufacturer: ensuring that connected products are designed to make data accessible and portable as required by the EU Data Act.
• As a data holder in limited direct-service scenarios: where Axioma Metering operates platforms that hold or process data generated by connected products, as described in Sections 3 and 4 below.

2. Products and Services Covered

This notice applies to the following categories of Axioma Metering products and services:

• Smart water meters — connected metering devices generating measurement and operational data.
• Smart heat meters — connected metering devices generating measurement and operational data.
• Communication gateways and concentrators — devices facilitating data transmission from meters to operator systems.
• AxiLink mobile application — a professional field tool used by authorised personnel (installers, maintenance technicians) to interact with meters locally via NFC or optical port. See Section 4.1.
• AxiReach remote management platform — a cloud-based platform used for remote monitoring, diagnostics, and firmware/configuration management of deployed devices. See Section 4.2.
• Related firmware, APIs, and software — supporting the above products.

Applicability may vary depending on product model, firmware version, deployment configuration, contractual arrangement, and local regulatory requirements.

3. Categories of Data Generated

Axioma Metering connected products and associated services may generate, record, transmit, or process the following categories of data:

3.1 Measurement and Operational Data

• Water or heat consumption measurements
• Flow, temperature, and pressure measurements
• Timestamps and interval readings
• Event and alarm information

Note on measurement data access. In standard deployments, measurement data is transmitted by the meter directly to the Operator’s own Head-End System (HES), Meter Data Management (MDM), or Advanced Metering Infrastructure (AMI) platform. Axioma Metering does not routinely receive or store this data. Requests relating to consumption data should be directed to the Operator.

3.2 Device and Diagnostic Data

• Battery status
• Communication status and quality indicators
• Firmware and hardware version information
• Device configuration parameters
• Operational diagnostics, error logs, and status indicators

3.3 Connectivity and Service Data

• Communication session metadata
• Network-related operational data
• Remote configuration and firmware update activity logs

The specific data categories available depend on device type, enabled functionality, communication technology, and system configuration.

4. Data Access

4.1 AxiLink Mobile Application

AxiLink is a professional mobile application intended exclusively for authorised field personnel such as installation technicians and maintenance engineers. It is not a consumer-facing application and is not accessible to end users.

AxiLink enables local interaction with smart meters via NFC or optical port. Authorised users may:

• read meter archives (measurement data logs stored in the device);
• review device status and diagnostic information;
• configure device parameters within authorised permissions.

User access to AxiLink is controlled by unique credentials and role-based authorisation. Authentication and all data processing — including payload encryption and decryption — are handled server-side. Cryptographic keys are not stored in or transmitted to the mobile application.

For Operators considering own-branded field applications. Axioma Metering can provide consultancy support to Operators who wish to develop their own mobile tools with secure integration into Axioma Metering’s key management infrastructure. Such arrangements are subject to separate contractual and security requirements.

4.2 AxiReach Remote Management Platform

AxiReach is Axioma Metering’s cloud-based remote device management platform, built on Thingsboard and deployed on Axioma Metering’s dedicated virtual server infrastructure within Microsoft Azure (EU region).

AxiReach is used where an Operator and Axioma Metering have agreed to a dual-IP connectivity arrangement. Under such arrangements:

• Measurement data continues to flow to the Operator’s own systems as normal.
• Technical operational data (device health, configuration status, communication quality, firmware version, diagnostics) is periodically transmitted to AxiReach for remote monitoring and maintenance purposes.
• Measurements may occasionally be transmitted to AxiReach in limited circumstances (e.g., specific diagnostic sessions) as agreed with the Operator.

AxiReach is primarily used for:

• monitoring device health across deployed fleets;
• executing COTA (Configuration Over The Air) commands;
• executing FUOTA (Firmware Update Over The Air) commands;
• piloting and demonstrating remote management capabilities.

Authorised Operator personnel are provided with access to AxiReach under the relevant contractual arrangement. Most Operators manage their deployed meters through their own HES/MDM/AMI platforms; AxiReach access is provided as a supplementary service.

5. Sharing Data with Third Parties

Where Axioma Metering acts as a data holder (as described in Section 4.2), it may, subject to applicable law, contractual obligations, cybersecurity requirements, and technical feasibility, facilitate data sharing with authorised third parties at the request of the Operator or, where directly applicable, the user.

Examples of authorised third parties may include:

• the Operator itself or its designated service providers;
• energy or resource management service providers;
• regulatory, audit, and control authorities;
• maintenance and operational service providers.
  
  

Data sharing requests should be submitted using the contact details set out in Section 10. Axioma Metering may require appropriate authentication, authorisation, and verification before enabling such access. Response timelines will comply with applicable legal requirements.

Note for end users. In the majority of deployments, Axioma Metering does not hold end-user data and cannot fulfil data portability or access requests on behalf of the Operator. End users should contact their Utility or metering service provider to exercise data access or portability rights.

6. Limitations and Restrictions

Access to data may be restricted where necessary to:

• protect cybersecurity and device integrity;
• maintain the security and reliability of critical metering infrastructure;
• protect trade secrets and confidential business information;
• prevent fraud, tampering, or unauthorised system manipulation;
• comply with legal or regulatory obligations;
• protect intellectual property rights.

Accordingly, Axioma Metering does not provide access to:

• source code of firmware or software;
• cryptographic keys, security credentials, or secure authentication mechanisms;
• protected firmware internals;
• proprietary algorithms beyond legally required disclosures.

Access requests may also be limited where disclosure would adversely affect the security, resilience, or lawful operation of products, systems, or communication infrastructure.

7. Personal Data

Some device or operational data may constitute personal data under applicable privacy legislation.

In standard deployments, Axioma Metering does not process personal data of end users. Where personal data is processed — for example, in the context of AxiLink user accounts or AxiReach access credentials — such processing is governed by Axioma Metering’s Privacy Policy, available at:

www.axiomametering.com/en

Where personal data is involved, data access and sharing may be subject to identity verification and additional legal grounds or authorisation.

8. Data Availability and Technical Feasibility

The availability of data depends on:

• device capabilities and firmware functionality;
• communication availability and deployment architecture;
• whether AxiReach connectivity has been agreed with the Operator;
• customer system integration and data retention periods;
• contractual arrangements between Axioma Metering and the Operator.

Certain legacy products or deployments may have limited technical capabilities regarding data access. Where AxiReach is not deployed, Axioma Metering has no technical access to device data in the field.

9. Security Measures

Axioma Metering implements technical and organisational measures to protect the confidentiality, integrity, availability, and authenticity of its systems and data. These include:

• role-based authentication and authorisation controls;
• end-to-end encryption of data in transit;
• server-side key management (keys are not exposed to client applications);
• audit logging and access monitoring;
• rate limiting and secure API design;
• infrastructure security controls within Microsoft Azure.

10. Contact and Requests

Questions or requests regarding this notice, data access rights, or EU Data Act compliance may be submitted to Axioma Metering’s legal and compliance team:

Axioma Metering UAB

Veterinarų g. 52, Biruliškės, Kauno raj., Lithuania

Email: dataact@axioma.eu (or info@axioma.eu)

Website: www.axiomametering.com/en

Supervisory authority. In accordance with the EU Data Act and applicable data protection law, complaints or disputes may be submitted to the competent national supervisory authority. Axioma Metering is established in Lithuania; the relevant authority is the State Data Protection Inspectorate of Lithuania (Valstybinė duomenų apsaugos inspekcija — VDAI), accessible at www.vdai.lrv.lt.

11. Changes to this Notice

Axioma Metering may update this notice from time to time to reflect regulatory developments, product changes, technical implementation updates, or operational and legal requirements. The latest version, including its version number and effective date, will be published on the Axioma Metering website.

This notice was prepared with reference to Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data (EU Data Act).