Privacy Policy

Introduction

Spack EV (“SPACK EV”, "we", "us" or "our") respects your (expression includes “Company” "you" or "your") privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our digital platforms (expression includes our website or mobile application). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OUR DIGITAL PLATFORMS.

While this Privacy Policy applies to all our services, we’ll also provide additional information about privacy related to particular services where necessary. We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including those which may also collect and use data about you. We are not responsible for any of the data collected by any such third party

Information We Collect

We collect different types of information depending on how you interact with Spack EV.

2.1 Personal Information

We may collect personal information that you provide directly to us, including but not limited to:

• Name, email address, and phone number
• Account credentials and authentication information
• Company name and business contact information
• Billing and payment information (e.g., invoicing details, partial payment identifiers from payment gateways)
• Support requests, feedback, and other communication content
• Information you provide when requesting quotes, demos, or proposals

2.2 EV Charging & Platform Usage Data

When you use our Platform and EV charging services, we may process:

• Charging session details: start/stop times, energy delivered, session duration, tariffs, cost, transaction IDs
• Charging station details: unique station ID, connector ID, station model, firmware version, location of the charging station
• Charge card or authentication identifiers: (e.g., RFID card ID, app token, vehicle ID, or other authentication numbers)
• Roaming / third-party card data: identifiers from third-party eMobility Service Providers (eMSPs), where applicable
• Log files and service data: error logs, diagnostic information, communication logs (e.g., OCPP transaction logs)
• App and dashboard usage patterns: features used, clicks, navigation flows

2.3 Device and Technical Data

We automatically collect certain technical information when you access or use the Platform:

• Device type, operating system, browser type and version
• IP address and general location (based on IP)
• Mobile device identifiers (where applicable)
• Application performance data and analytics events
• Cookies and similar technologies (see Cookies and Tracking Technologies below)

2.4 Location Data

If you allow location access in our mobile application or browser:

• We may collect your GPS location to help you discover nearby charging stations and improve route planning.
• Processing of precise GPS location is based on your consent, which you can withdraw at any time via your device or app settings.

3. Legal Basis for Processing (Where Applicable)

Depending on your location and applicable law, we process your personal information based on one or more of the following legal bases:

Performance of a contract:

To create and manage your account, provide EV charging services, process payments, and deliver related services.

Consent:

For GPS location sharing, certain marketing communications, and cookies (where required).

Legitimate interests:

To improve service quality, ensure network security, prevent fraud and misuse, perform analytics, and enhance user experience.

Legal obligations:

To comply with applicable laws, tax and accounting rules, and regulatory requirements.

4. How We Use Your Information

We use the collected information for the following purposes:

4.1 EV Charging and Platform Operation

• To provide and maintain our EV charging services and management Platform
• To authenticate users, charge cards, and vehicles
• To process charging sessions, calculate tariffs, and generate invoices or usage reports
• To manage public, private, and fleet charging scenarios
• To provide warranty, maintenance, and support services for connected charging stations

4.2 Account, Billing & Administration

• To create and manage your user or company account
• To process transactions, generate invoices, and send billing information
• To manage subscriptions, service plans, and payment status
• To meet tax, accounting, and regulatory requirements

4.3 Support, Communication & Relationship Management

• To respond to your inquiries, support requests, and feedback
• To send administrative information such as service updates, policy changes, or security alerts
• To communicate about product changes, feature updates, and service notifications

4.4 Security, Fraud Prevention & Compliance

• To monitor and analyze usage patterns to detect and prevent fraud, misuse, and unauthorized access
• To maintain the security and stability of our Platform and charging network
• To conduct due diligence and comply with legal obligations, law enforcement requests, or court orders

4.5 Analytics, Quality Improvement & Product Development

• To monitor application performance and improve reliability
• To analyze charging behavior, platform usage, and feature effectiveness
• To use log files and service data to improve the quality of our services and diagnose issues
• To develop new features, tools, and integrations based on aggregated insights

4.6 Marketing, Surveys & Promotions

• To send you marketing communications (where permitted) about Spack EV products, services, and events
• To invite you to participate in surveys, feedback programs, or beta testing
• To run campaigns and promotions, based on your consent or our legitimate interests as applicable

4.7 Recruitment & Onboarding

• If you apply for a role at Spack EV, we process your application details for hiring and onboarding purposes.

5. Data Sharing and Disclosure

We may share your information in the following circumstances:

Service providers:

With trusted third-party vendors who support our operations (e.g., cloud hosting, payment gateways, analytics, customer support tools).

Charging partners & business customers:

With charging station owners, fleet operators, or business clients to whom you are linked (e.g., employer, leasing company, fleet manager) for billing, reporting, and service delivery.

Roaming and eMSP partners:

When you charge through roaming networks or third-party eMobility Service Providers.

Affiliates and group companies:

Within our group for internal administration and unified service delivery.

Legal and compliance:

When required by law, regulation, or legal process, or to protect the rights, property, or safety of Spack EV, our users, or others.

Business transfers:

In connection with a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of that transaction.We do not sell your personal information.

6. International Data Transfers

Your personal information may be stored and processed in countries other than your own, where our servers, group companies, or service providers are located.

Where required by law, we implement appropriate safeguards for international data transfers, such as:

• Standard contractual clauses or equivalent legal mechanisms
• Contractual obligations on recipients to protect your information
• Your explicit consent, where applicable

7. Data Retention

We retain personal information only for as long as necessary to:

• Provide the services you requested
• Fulfil contractual and legal obligations
• Resolve disputes and enforce our agreements
• Maintain accurate business and financial records

Typical examples:

Account and profile data

retained while your account is active and for a reasonable period thereafter.

Charging session and billing records

retained for the duration required by tax, accounting, and regulatory laws.

Support tickets and communication logs

retained for a reasonable period to improve service and handle follow-up queries.

When data is no longer needed, we will delete or anonymize it in accordance with our data retention policies and applicable laws.

8.Your Rights and Choices

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal information:

Access

Request a copy of the personal information we hold about you.

Rectification

Request corrections to inaccurate or incomplete data.

Erasure

Request deletion of your personal information, subject to legal and contractual limitations.

Restriction

Request restriction of certain processing activities.

Objection

Object to processing based on legitimate interests or direct marketing.

Data portability

Request your data in a structured, commonly used, and machine-readable format where technically feasible.

Withdraw consent

Where processing is based on your consent (e.g. GPS, marketing), you can withdraw consent at any time without affecting prior lawful processing.

Marketing opt-out

You can opt out of marketing emails by using the unsubscribe link or contacting us directly.

We may need to verify your identity before fulfilling certain requests.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and login sessions
• Analyze Platform usage and performance
• Improve the user experience

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of our service may not function properly without cookies.

If a separate Cookie Policy is available on our website, it provides more detailed information on specific cookies used.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include, where appropriate:

• Encryption in transit and at rest
• Access controls and authentication mechanisms
• Secure server infrastructure and firewalls
• Regular security monitoring and assessments

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

11. Children’s Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children.

If you become aware that a child has provided us with personal information, please contact us immediately. We will take steps to delete such information as required by law.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do:

• We will post the updated version on this page and update the “Last updated” date.
• Where required by law, we will also notify you through the Platform or via email.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.