July 2024

Transparency Statement:

We are committed to being transparent about how the information you provide to us is used and stored. By using our services or visiting our website, you agree to the guidelines outlined in our terms and conditions regarding the handling of personal data as described in this privacy policy, in accordance with “General Data Protection Regulation” (hereafter called “GDPR”) of European Union and “Personal Information Protection and Electronic Documents Act” (hereafter called “PIPEDA”) guidelines of CANADA.

Privacy and Integrity Disclaimer

We take responsibility for processing your personal data on our website and our platform. This responsibility means ensuring that you, as a visitor of our website or user of our service/app, are informed about what personal information we collect, how we collect it, and why. We also provide you with the ability to request changes to your information, limit its use, access the information we hold about you, or exercise your right to be completely removed from our systems. Rest assured that we do not share your information with third parties without your explicit consent. This Policy does not apply to any website, product or service of any third-party company even if the website links to (or is linked from) our website. CHARGING RIGHT does not operate or control those websites, products or services. We strongly encourage and recommend you to always review the privacy practices of a company before deciding whether to provide any information.

Accountability

We have appointed a Privacy Officer who is responsible for ensuring our compliance with the “General Data Protection Regulation” (GDPR) of European Union; and the “Personal Information Protection and Electronic Documents Act” (PIPEDA) of Canada. You may contact our Privacy Officer at: pivacyofficer@chargingright.com for any inquiries or concerns regarding our privacy practices.

Personal Information

In this Privacy Policy, the term ‘Personal Information’ refers to data that can identify a specific individual, including information related to their vehicle or any anonymous data (such as an IP address) associated with their internet account. Personal information excludes aggregated anonymous data that can no longer reasonably be linked to a specific person. You have the right to access your Personal Information, and we are committed to maintaining its accuracy and completeness based on the details you provide. If you request access, we will inform you about the use, existence, and disclosure of your Personal Information as permitted by law, always seeking your consent for any purposes beyond those outlined in this Privacy Policy.

Purpose of Collecting our Data

CHARGING RIGHT collects and uses the data that (1) you directly provide to us, (2) our website stores on your computer as “cookies” (3) generated and logged by the Electric vehicle supply equipment (or EV chargers) registered on our platform to fulfill, enhance, and tailor our commitments, products, and services to your needs. This includes providing you with services and gathering statistics to improve our website and offerings, ensuring compliance with legal obligations. For instance, if many users visit a specific page, we can deduce its popularity and adjust the content accordingly. Similarly, if users frequently click on a particular topic or download a brochure, it helps us create more relevant content or adapt our services.

Additionally, if we have your explicit consent, we may use your information for marketing purposes, such as informing you about our products and services and providing relevant news and updates that you may find interesting or useful. You have the right to update your details, request your data, or ask for complete removal from our databases at any time. You can unsubscribe by clicking the “Unsubscribe” link in our emails or by contacting us directly via email.

Collected Information Types

The type of personal data we collect varies based on your interactions with CHARGING RIGHT and may include:

• Contact Information: This includes your name, address, email address, and telephone number.

• Additional Details: Any other information you provide during your communications with us.

• User Data: Information about your use of our website and services, such as IP addresses, device types, browsers, and your interactions with our site/app, including pages visited and buttons clicked.

Our Data Collection Practices

The primary way we collect data is when you voluntarily provide it through forms on our website, such as filling out a contact form, enrolling to our services, participating in our surveys, etc. You always have the option to update your information, request a copy of your data, or ask for your details to be completely removed from our databases.

Information You Provide to US Through Cookies

We collect information through “cookies,” which are text files placed on your hard drive to enhance your experience on our website. Cookies help automatically adjust the website to your preferences, recognizing you and retrieving previously entered information. This functionality saves time, improves usability, and creates a smoother user experience. You have the option to accept or block cookies through your browser settings. While most browsers accept cookies by default, you can adjust your browser settings to refuse them. Please be aware that blocking cookies may sometimes reduce the functionality, usability, and overall experience of our site.

Current Clients of CHARGING RIGHT Services

This privacy policy applies specifically to our website, not to the systems and various digital services we provide. If you are a customer of CHARGING RIGHT services, software, or applications, please refer to the respective applications, software, or services for detailed information about our privacy policies and how we comply with “GDPR” and “PIPEDA”.

Service Providers We Use to Perform The Services

• Google Forms and Google Analytics:We use Google Analytics for the purpose of collecting statistics on how our website is used in order to better understand and improve the information site services we provide. Google Analytics primarily stores IP address, web browser type, and cookie information that you have chosen to share with Google. Also we use Google Forms to create online survey which its results can be used to adapt our services to our potential customer requirements.

• Matomo:We use Matomo Analytics for the purpose of collecting anonymous statistics on how our website is used in order to better understand and improve the information site services we provide. You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users. You are not opted out and You should Uncheck a box to opt-out, if You want so.

• HubSpot: We use HubSpot to manage our website, for marketing, CRM and sales purposes. It is one of the leading systems on the market and HubSpot’s support for GDPR & PIPEDA is continuously updated. You can read more about HubSpot’s support for GDPR here: HubSpot GDPR Data Privacy and its support for PIPEDA here: HubSpot Data Privacy for CANADA.

Process The Data for Employment Applications

The personal information collected and processed through our job application processes, such as via cv@chargingright.com, is made available only to relevant employees of CHARGINGRIGHT and is used solely for recruitment purposes. Your personal information is handled strictly for recruitment and is retained only as long as necessary to fulfill this purpose. Data may be stored for up to twenty-four months to potentially match you with future job openings. In certain cases, where required by law, we may need to store the data for a longer period. If you wish to have your employment data deleted, corrected, updated, or restricted, please contact us at contact@chargingright.com.

Data Retention Period

When you initiate contact with us, we securely retain your contact information until either you or CHARGING RIGHT decide to terminate the interaction. If we initiate contact, your data will be stored as long as there is a mutual interest and/or need, or until either you or CHARGING RIGHT chooses to terminate the contact.

Ensuring Information Security

Ensuring the security of information is a top priority for us. We employ rigorous measures to securely store your personal information. By adhering to current and well-established security standards, procedures, and guidelines outlined in GDPR and PIPEDA, we safeguard your data from unauthorized access, alteration, dissemination, and destruction.

Individual Access

You have the right to request access to your personal information and to request corrections if the information is inaccurate or incomplete. Please contact our Privacy Officer to make such requests at: pivacyofficer@chargingright.com.

Children’s Privacy

Our website and services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If we become aware that we have inadvertently received personal information from a child under the age of 13, we will delete such information from our records.

Data Breach Notification

In the unlikely event of a data breach, we will notify affected users within 72 hours of becoming aware of the breach, in accordance with applicable laws and regulations. We will also take immediate steps to mitigate any potential harm.

Sharing and Disclosure of Information

Charging Right does not sell or rent your Personal Information to marketers or third parties. We may share your Personal Information with trusted third parties who are integral to the operation of our Website and App, including but not limited to financial institutions, payment processors, verification services and credit bureaus, as well as any third parties that you have directly authorized to receive your Personal Information. We may store your Personal Information in locations outside the direct control of Charging Right, for instance, on servers or databases co-located with Providers. If we offer links to third party service through Charging Right and you choose to access these services, you authorize the third party service to access your Charging Right account, you acknowledge that we may share payment transaction data and related information with the third party that provides the authorized application. The use of your information by such third parties will be subject to their applicable privacy policy, which you should carefully review before accessing the service.

If Charging Right undertakes or is involved in any merger, acquisition, reorganization, going-public event, sale of assets or bankruptcy, insolvency or any similar event, then we may transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

Revisions and Updates

This Privacy and Integrity Policy may be revised, particularly in response to legal updates and changes. We encourage you to periodically review this policy to stay informed about any recent revisions.

Questions About This Policy

If you have any questions, recommendations, requests or concerns regarding this policy or how we handle information—including inquiries about accessing, updating, or deleting your information—please contact us at: contact@chargingright.com or pivacyofficer@chargingright.com.