Privacy Policy

Welcome to the website and application of LLC "EV POWER" (ID No. 405736690) (hereinafter referred to as "EV POWER" or "We"). First and foremost, thank you for using our services; we are confident they will be beneficial to you.

We attach particular importance to the issues of protecting the confidentiality and security of your personal data.

We promise to:

• Take care of the security and protection of your personal data.
• Not use your data unlawfully.
• Provide you with full and comprehensive information regarding the processing of your personal data at any time.

In accordance with the current personal data protection legislation, including the Law of Georgia "On Personal Data Protection" and the General Data Protection Regulation (EU Regulation 2016/679) (hereinafter referred to as GDPR), we are obligated to provide you with information on who we are, how and on what legal basis we process your personal data, which personal data we process, for what purposes, and for how long we store it. Furthermore, we are obliged to provide you with information on who we transfer your personal data to, as well as information about your rights concerning your personal data.

Our goal is to ensure the protection of your personal data. Accordingly, this Privacy Policy (hereinafter referred to as the "Policy") describes how EV POWER collects, processes, uses, stores, shares, and protects your personal data.

It is necessary to indicate your consent to the processing of your personal data before registering on the website and before installing the application.

We emphasize that the website and application are not intended for children, and we knowingly do not collect or process the personal data of children.

Key Aspects of the Policy

This section presents the main, important aspects of the Policy, so that you can receive the most essential and basic part of the information presented in the Policy in the shortest time. The purpose of this is to enable you to make an informed decision regarding the processing of your personal data by us. You will find details on each specific issue in the following sections of the Policy.

The following table summarizes the key data processing details:

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Definition of Terms

The terms used in the Policy have the meaning defined in our Terms and Conditions. In addition, several terms are presented in the Policy with the following meanings:

• "CPO" – Charge Point Operator. A CPO is authorized to purchase, install, own, and manage a charging station/stations, or manage them based on obtaining possession from a third party.
• "Services" – All services provided by EV POWER through all means, including the website and application, regardless of how they are accessed. The services available to you may vary depending on your location, form of access, and other factors, although the Policy applies to all services.
• "Websites" – All websites owned and managed by EV POWER, their sub-domains and sub-pages, both existing and created in the future. The Policy applies to any use/visit of the website or application by you.

In addition to the above, the Policy contains supplementary terms; however, they are easily recognizable, as they will be highlighted in bold font and enclosed in quotation marks when defined as a term.

Privacy Policy and Its Purpose

The purpose of the Policy is to provide you with important information in simple and understandable language, specifically what principles EV POWER's process of collecting, processing, using, storing, and sharing personal data is based on, as well as information on the legal protection mechanisms for your personal data.

The Policy applies to any personal data that EV POWER processes when you visit the website/application or use our services.

Importantly, the Policy does not cover the processing of data by third parties, specifically data processing that EV POWER cannot control, including in cases of redirection to third-party websites or services. Although we try to ensure that redirection from our website is possible only to websites that respect the confidentiality and security of your personal information, we do not take responsibility for their content and privacy policy. We recommend that you carefully review the privacy policy of any third-party website you visit.

Please note that EV POWER usually does not process your personal information, for example, when you only visit our website. Your personal data is processed by EV POWER only if you are asked to provide such information yourself (e.g., when opening an account or receiving a service). Your personal data is collected only on the basis of your informed consent and is used only for the stated purposes, as will be explained in detail in the following sections of the Policy.

Personal Data Processor, Data Processing, and Purpose

The personal data processor is the person who determines the purposes and means of processing your personal data and carries out the data processing directly or through an authorized person.

Your personal data is processed by: LLC "EV POWER," Identification Number: 405736690, Actual Address: Georgia, Tbilisi, Zovreti Street, 37, Tel.: +995 3220 888 09.

We collect and process personal data without the provision of which you cannot use EV POWER's services, and therefore, their provision is mandatory. Specifically, this refers to the personal data you share with us, with your consent, by clicking the consent button when receiving any service, using the application, or opening an account.

Confirmation of the consent button is equivalent to your written consent and confirms that you give informed consent for EV POWER to process your personal data for the purpose of providing the service to you.

You consent and confirm informed awareness that the processing of your personal data also includes EV POWER sharing this data with third parties involved in the service process for you (e.g., installers, electricians, etc.). If you do not consent to the processing of your personal data or do not agree to this Policy, you will not be able to use the website and application.

We collect your following personal data for the following purposes:

• "Contact Information" – For using the service, you will be asked for the following data: name, surname, mailing address, and phone number. We use this information only to provide the service and to communicate with you if necessary. Furthermore, if you consent to receive information about news from us, we will use the data to send notifications about services and special offers/promotions. In addition, if creating an EV POWER account on the website or application is necessary to receive the service, we will use your email to create the account and provide account-related information.
• "Account-Related Information" – Your email address is required when opening an account. This information is used only for your authorization to enable you to use the services that require an account, as well as for account-related communication if necessary.
• "Payment-Related Information" – When adding funds to the account or making an online payment, you will be asked for the following data: card number, card expiration date, name on the card, and security code (CVV). This data is used only to process the payment transaction and to simplify recurring payments.
• "Location-Related Information" – We may process information about your location for various purposes, for example, to show nearby charging stations.
• "Application/Account Usage Data (Usage Data)" – Includes details about your use of the application/account, including information on charging sessions, reservations, and purchases, for your convenience in reflecting information on the application/account, as well as for accounting and reporting purposes.
• "Information related to the vehicle charging session" – Includes details regarding your use of the charger: date, location, charging station, session duration, cost, and amount of energy consumed. The authorization method (e.g., RFID card or mobile) is also stored. This data is used for your convenience in reflecting information on the application/account, as well as for accounting and reporting purposes.
• "Information about charger installation" – Your contact information, car brand, and model. The information is used to be sent to the installers/electricians you selected to receive a price offer (if you use this function), to enable you to use the service.

Additionally, EV POWER uses your personal information in the following cases:

• In general, to provide the service to you and to provide you with a quality service.
• To perform any other function that is directly described to you at the time you provide the information.

Furthermore, we will delete/destroy your personal data if the purposes defined by this Policy no longer exist.

Data Storage, Protection, and Security

We implement all available reasonable technical and organizational security measures and take all necessary actions to ensure that your personal data obtained by us through the website and application is protected from unauthorized/unlawful access, processing, use, loss, alteration, disclosure, or destruction.

These requirements also apply to all third parties to whom the data is transferred for processing. The latter are obliged to notify us, as the personal data processor, about the measures taken.

Importantly, all information you provide to us is stored on our secured servers. Once we receive your information, we use strict procedures and security mechanisms (such as encryption, anonymization/pseudonymization) to prevent accidental loss, use, or unauthorized access to your data.

We acknowledge that we are obliged to ensure the fully implemented internal systems for personal data protection and mandatory regulations that will be in full compliance with current legislation. We take all reasonable and available measures to fulfill this obligation.

Sharing of Personal Data

Information containing personal data collected by EV POWER is confidential. Accordingly, except for the cases described below, EV POWER will not transfer the collected personal data to other third parties.

EV POWER does not sell, rent, or license personal data.

Only EV POWER's representatives and subcontractors, as well as persons responsible for the management and development of the services, have access to the collected personal data. They are obliged to comply with this Policy. These latter persons are contractually obliged to protect the confidentiality of personal data.

We may share your personal data in the following cases:

• To protect our legal rights or for the purpose of defense against legal claims.
• For the purpose of investigation and prevention of illegal actions, fraud, or situations that pose a threat to security.
• For the purpose of preventing the misuse of the service infrastructure (for example, spam attacks, DOS attacks, hacking attempts).
• For our affiliated, partner, or related companies (if any) (such persons are required to comply with the terms provided for by the Policy).
• To third-party services and certain persons, for example, email service providers, payment service providers/banking institutions.

Furthermore, EV POWER uses the services of certain third parties to expand functionality. When you send personal information to use these functions, you automatically consent to its transfer to the specific service providers. For example, EV POWER uses Google Maps for the charging station map – in this case, information about your location may be shared. Also, if you use the function that allows you to search for electricians/installers, your contact information will be transferred to them. Photos or other data containing personal information may also be transferred. These third parties are obliged to use the data only for the specified purpose.

Note: The cases of sharing your personal data by us are also presented in the table in section 1 of the Policy.

Importantly, the transfer of your data to third parties is carried out only for a defined purpose and only to the necessary extent resulting from that purpose.

Your personal data is accessible to our employees who, in accordance with their service competence and functions, have strictly defined limits for access and processing, and are also subject to a confidentiality obligation.

Secured Payments

When paying, your card data is securely transmitted using the TLS protocol directly to the payment service providers/banking institutions.

EV POWER never stores card data on its own servers. Payment service providers/banking institutions store information related to transactions only to ensure secure payment, to store proof of purchase, and for the purpose of fraud prevention.

EV POWER does not have access to information about your payments. We only receive confirmation or rejection directly regarding the transaction carried out by you.

Application Access to Your Device ("Permissions") and Uninstallation

The Application may require:

• Access to the camera – for taking photos of charging stations.
• Access to location – for showing nearby stations.
• Access to network services – Wi-Fi/mobile internet.
• Sending notifications – for example, about the reservation status.
• Access to device memory – for storing authorization and payment documents.

You can delete the application at any time. The method of deletion depends on the type of device and the system version from which you want to delete it. EV POWER is not responsible for this process or the possible transfer of data to third parties during this process.

Limited Data Collection for Statistical, Analytical, and Security Purposes

EV POWER uses Google Analytics for analyzing user behavior on the website. Importantly, the collected data (IP address, browser, device type, access time, viewed pages, and others) does not allow for your identification. This data is processed only to better determine the needs of website visitors and to improve the website/services.

EV POWER also uses Google App Analytics, which collects data about application usage (e.g., device screen size, type, browser information, geolocation) but in an anonymized form. This data is stored in a pseudonymous profile and is not used for the identification of a specific person.

Furthermore, your IP address and other data may be used for the investigation of fraudulent or criminal activity, or in case of violation of the terms of use of the services.

Cookies and Their Use

Cookies are small text files stored on your computer, tablet, or mobile phone. Specifically, when you access a website or use an application, cookies allow the website to "remember" you and how you used it during each login. In other words, cookies are used to collect information about you and your behavior. This serves to and ensures that you have the ability to better manipulate the internet.

EV POWER uses "cookies" and similar technologies, such as tags, pixels, and web beacons. By visiting the website or using the application, you consent to their use.

In the case of the Services, "session cookies" are used, which improve your experience by storing information about the current visit on your computer or device, for example, when using the service or using certain functions.

We use cookies for the following functions:

• Simplifying authorization.
• Simplifying the shopping experience.
• Simplifying the payment process when paying for the service cost or adding funds to the account.
• Storing your information when using the services (e.g., storing card information for future use).
• For internal analytics and research, for the purpose of improving the services.
• Simplifying online advertising.
• Helping to identify possible fraudulent actions.

Your browser or device can be set to refuse cookies or delete them. However, deleting them may negatively affect the user experience or certain functions. EV POWER and its representatives are not responsible for the functions that may not work after deleting cookies.

Risks Associated with the Internet and Wireless Data Transmission

Importantly, complete security is not guaranteed when using the internet and wireless technologies. In this case, data theft, loss, or alteration may occur. You agree that EV POWER and its representatives are not responsible for damage caused by such risks.

Your Rights Regarding Personal Data Processing

You have the right:

• To request and receive information free of charge:
• • I. Whether data about you is processed, and whether the data processing is justified.
  • II. About the data that is processed, as well as the basis and purpose of this data processing.
  • III. About the source of data collection/acquisition.
  • IV. About the data storage period (time), and if a specific period cannot be determined, about the criteria for determining the period.
  • V. About the identity of the data recipient or categories of data recipients, including information about the basis and purpose of the data transfer, if the data is transferred to a third party.
  • Furthermore, you have the right to receive this information in a form acceptable to you.
• To review the personal data about you in EV POWER and receive copies of this data free of charge.
• To request the correction, update, addition, blocking, deletion, or destruction of the data about you if they are incomplete, inaccurate, not updated, or if their collection and processing were carried out contrary to law.
• To withdraw your given consent without explanation at any time and request the termination of data processing and/or the destruction of processed data (if there is no other basis for data processing).
• • Furthermore, if you withdraw your consent to personal data processing, the provision of services by EV POWER to you will be terminated.
• To appeal to the State Inspector's Service (Tel.: (+995 32) 242 10 00; Email address: office@pdps.ge; Address: N. Vachnadze #7, Tbilisi, 0105 - Personal Data Protection Direction) or the court if you believe that EV POWER's data processing does not comply with the rules established by the Law of Georgia "On Personal Data Protection".

By registering on the website and opening a personal account, receiving any service, purchasing a product, or opening an account, and by reviewing the Policy and clicking the consent button, you confirm your informed awareness of your aforementioned rights.

How to Contact Us

If you have any questions, requests, or claims regarding this Policy or the collection, processing, use, disclosure, sharing, and/or protection of your personal data, you can contact us using the following means:

• Actual Address: Georgia, Tbilisi, Zovreti Street, 37 
• Email Address: info@evpower.ge 
• Phone Number: +995 3220 888 09 

Changes to the Policy

We reserve the right to change or replace this Policy at any time and without prior notice.

Any change to the Policy will be published at the following address: Georgia, Tbilisi, Zovreti Street, 37. Please note that it is your responsibility to periodically check the Policy. Furthermore, using the services after the publication of Policy changes means that you agree to these changes.

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