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EV Connect, Inc. Privacy Policy

EV Connect, Inc. (“us”, “we”, “our”, the “Company” or “EV Connect”) provides the services available on the EVConnect.com website (and any other Company website), the EV Cloud Subscription Service (to Charging Site Hosts, described below) and the downloadable, mobile, EV Connect Network Application (collectively, the “Services” or “Service”), which allows you to charge your vehicle on any electric vehicle service equipment (an “EVSE” or “Charging Station”) that has been commissioned onto our EV Cloud Network.

This Privacy Policy (“Privacy Policy” or “Policy”) informs you of our privacy practices and policies regarding the collection, use and disclosure of Personal Information, Financial Information, Transaction History, Usage Data and Log Data when you use our Service. We will not use or share your information with anyone except as described in this Privacy Policy. When we collect personal information on EVConnect.com or any other Company website, certain additional disclosures, that are specific to the context of our collection and use of the information being collected (e.g. an event or information request page), may be provided to you. For the avoidance of any doubt, we will adhere to those commitments and any such additional privacy policy statements are hereby incorporated into this Privacy Policy.

By signing up to use our Service, and opting-in to our uses of your information, you agree to the collection and use of information in accordance with this policy (the “Privacy Policy”).

Information Collection

Personal Information

When you sign-up for our Service, and while using our Service, you may provide us with certain personal and personally identifiable information that can be used to contact or identify you. We collect personal information such as the make and model of your vehicle and your geolocation and personally identifiable information such as your name, your email address, your phone number and your postal address (collectively “Personal Information”).

Financial Information

When you sign-up for our Service, and while using our Service, you may also provide us with credit card information, such as your credit card account number, expiration date, CSV and address (“Financial Information”).

Transaction History

In the event our Service is used to process a credit card transaction, we will collect the date and amount of each transaction, which will be associated with the last four digits of the credit card you utilized (collectively “Transaction History”).

Usage Data

When you use our Services to charge a vehicle, we will collect usage data, such as the time and location of the charge, duration of the charge, and amount paid for the charge (“Usage Data”).

Log Data

We may also collect information that your browser sends whenever you visit or use our Service, as well as any other generic user information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the type of mobile phone you are using to access our Service, the operating software and firmware used by your mobile phone, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other data generated from cookies (see the Cookies section below for more information).

Use and Retention of Information

We collect Personal Information for the purpose of providing the Service, identifying and communicating with you, responding to your requests/inquiries, servicing your account, improving our services, and to the extent you have not opted-out, (i) contacting you with information about our Services and offers, and (ii) contacting your via text message with updates about your charging session.

We will only retain your Personal Information and other Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements. For clarity, retention periods may be extended if we are required to preserve your information or data because of litigation, investigations and other similar proceedings, or if a longer retention period is required or permitted by applicable law.

We collect Financial Data to charge you for your electric vehicle charging sessions, but we do not store or retain any of your Financial Information, except for the last four digits of your credit card. Your Financial Information is processed directly by the applicable third party processor through an API integration.

We collect your Transaction History so that we can accurately track the charges we have made to your credit card, so that we can document our revenue and answer questions you may have in connection with any charges made to your credit cards.

We collect Usage Data to analyze electric vehicle use. Usage Data may also be combined with data obtained about the make and model of your vehicle and your geolocation and this combined information may be shared or sold to third parties. We do not sell personally identifiable information.

We collect Log Data for the purpose of providing and improving the Service, and, as described in this Privacy Policy, to advertise and send other communications to you.

We may link or combine the Personal Information we collect and/or receive about you and the Log Data we collect automatically during your visit to our website or use of certain of our Services. This allows us to provide you with a personalized experience and helps us to continually work to improve our Services.

EV Connect has separate agreements with the property owners of each location that uses our EV Cloud Subscription Service to make their EVSE available for your use (“Charging Site Hosts”). Charging Site Hosts have the ability to set the prices for our Services on their EVSE and will have access to your Transaction History and Usage Data when you use the EVSE located on their property. Except to the extent the Charging Site Host has established a user group with special privileges, such as Charging Site Host employees that sign up for the Service with their designated company email (in which case the Charging Site Host will be able to verify your Transaction History and Usage Data in connection with your special user group status), none of the information shared with Charging Site Hosts is Personal Information (as described in this Policy) that, itself, can be used to contact or identify you. If you have any questions about the data practices of a Charging Site Host using our Services to process or obtain access to your information or data, you need to contact the Charging Site Host directly, and ask for their Privacy Policy or Privacy Statement. Certain Service functionalities allow Users to report issues regarding Charging Stations and Charging Site Host locations. You acknowledge and agree that EV Connect may share any such information or material (e.g. photos) you provide, including any Personal Information therein, with the applicable Charging Site Host.

Third Party Data Processors

EV Connect engages certain third parties that may process data submitted to EV Connect to perform certain business-related functions and to increase the functionality of our Services. These companies provide various services to us, such as processing of payments and monitoring and analyzing how our Services are used or performing. When we engage another company to perform such functions, we may provide them with information, including Personal Information, Financial Information, Transaction History, Usage Data and Log Data in connection with their performance of such functions. These third parties may analyze the data we provide, combine that data with publicly available data, and provide us with access to their analysis and reports. These subprocessors are listed below, as may be updated by EV Connect from time to time:

  • PayPal, Inc. (Braintree)
  • Apple Inc. (Apple Pay)
  • Google LLC (Google Pay, Google Analytics, Google AdWords, Crashlytics, Fabric and Firebase)
  • Amazon Web Services, Inc.
  • The Rocket Science Group LLC dba MailChimp
  • Twilio Inc.
  • ZenDesk, Inc.
  • Bugsnag Inc.

To the extent these third parties have access to any of your data, and especially your Personal Information or a combination of data that is deemed to be personally identifiable, please know that they are contractually (i) limited to only use this data to perform specific tasks on our behalf and (ii) obligated not to disclose or use your information for any other purpose.

For your information, Google LLC recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information in order to improve our Services and provide you with the best user experience possible. The third-parties we work with may also use cookies to help us analyze how our users are using the Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

Behavioral Remarketing

EV Connect may use Google AdWords to advertise to you on third-party web sites after you have visited or used our Service. We, and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords remarketing service is provided by Google LLC. You can customize the Google Display Network ads by visiting the Google Ads Settings page: https://adssettings.google.com/authenticated

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials, charging status notifications, and other information that may be of interest to you. If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. For the purpose of clarification, in jurisdictions which require an opt-in for such communications, you will not receive such communications unless you have affirmatively opted-in. You may also opt out of receiving any, or all, of these communications from us by updating your preferences from your account page or following the unsubscribe link or instructions provided in any email we send or by contacting us.

Compliance With Laws

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

Your Rights in Respect to Your Personal Information

Users who wish to correct, update, change, or erase the Personal Information they submit to the Service should be able to go back into the applicable account page to edit the submitted information. For your information, in accordance with certain, possibly applicable, privacy laws, you may have the following rights in respect of your Personal Information that we hold:

  • Right of access and portability. The right to obtain access to your Personal Information along with certain information, and to receive that Personal Information in a commonly used format and to have it ported to another data controller.
  • Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
  • Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
  • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
  • Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your Personal Information for direct marketing purposes, to the extent it is related to such direct marketing.

For additional information, assistance with any problems accessing your information or if you wish to exercise one of these rights, please contact us.

Upon request, we will provide you with information about whether we hold any of your personal information. Again, you may access, correct or request deletion of your personal information by logging into your account, or by contacting us. We will respond to your request within 30 days.

Business Transaction

EV Connect may share your Personal Information or Data with Company affiliates for the purpose of any necessary collaboration. In addition, if EV Connect, Inc. is involved in a merger, acquisition or asset sale, your Personal Information and Data may be transferred as a business asset. In such cases, we will provide notice before your Personal Information is transferred and/or becomes subject to a different Privacy Policy.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain administrative, technical, and physical security measures appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer

To facilitate EV Connect’s global operations, we may store, transfer and access the information and personal data you submit to our Services around the world, including the United States, Canada and other countries in which EV Connect or its third party service providers have operations. This Privacy Policy shall apply even if EV Connect transfers such information or personal data to other countries. By consenting to this Privacy Policy and using our Services (or, for the avoidance of any doubt, providing information or personal data to us on any Company website in any other context), you consent to the transfer of your information and personal data among these facilities, including those located outside your home country.

If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA. In all such cases, we will only transfer your personal data if:

  • The country to which the personal data will be transferred has been granted a EuropeanCommission adequacy decision;
  • The recipient of the personal data is located in the U.S. and has certified to the EU-U.S. Privacy Shield Framework; or
  • We have put in place appropriate safeguards with respect to the transfer, for example the EU Model Clauses.

You may request a copy of the safeguards that we have put in place in respect of any applicable transfers of personal data by contacting us as described in the Contact Us section below.

For the avoidance of any doubt, if you are located outside United States and choose to provide information to us, please note that our current practice is to transfer the information, including Personal Information, to United States, where it is processed. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Your California Privacy Rights

As already stated elsewhere in this Privacy Policy, and in accordance with California Civil Code Section § 1798.83, please know that EV Connect does not disclose personal data collected on the Service to third parties for their direct marketing purposes. (California Civil Code Section § 1798.83 permits users of a website that are California residents to request certain information regarding the disclosure of personal data to third parties for their direct marketing purposes).

Children’s Privacy

Only persons age 16 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

This Privacy Policy is effective as of February 1, 2019 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us.

For our Canadian users, please know that this Policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

Address: 112 Kent Street, Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-free: (800) 282-1376
Facsimile: (613) 947-6850
TTY: (613) 992-9190
Website: www.priv.gc.ca/en/