Power Up Your Property

Privacy Policy

This Privacy Policy (“Policy”) describes how EVLUV collects, accesses, uses, discloses, and otherwise processes your information.

Effective Date: 2024

EVLUV Inc. (“EVLUV,” “we,” “us,” or “our”), provides software solutions and services for electric vehicle (EV) drivers, charging infrastructure hosts and other stakeholders to support EV adoption and minimize charge and range anxiety.

This Privacy Policy (“Policy”) describes how EVLUV collects, accesses, uses, discloses, and otherwise processes your information. This Privacy Policy applies to data processing related to all of our products, services, and websites, including our EVLUV mobile and web applications and cloud based software solutions, your EVLUV account (if you have registered or are registering your account), and EVLUV identifiable QR codes. To make this Privacy Policy easier to read, our products, services, websites, mobile and web applications, and our other online or offline offerings are collectively called the “Services.”

An Important Note: This Privacy Policy does not apply to any of the personal information that we process on behalf of our customers through their use of our Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

Personal Information That We Collect

By using our Services you acknowledge that you are familiar with this Privacy Policy and that you permit us to process your personal information in accordance with this Privacy Policy.

1. Information You Provide Directly to Us

The categories of personal information we collect will depend on how you interact with us, our Services, and the requirements of applicable law. Personal information we may collect includes:

Account Registration Information: If you register for an account with EVLUV, we may collect your first and last name, address, e-mail address, title, telephone number, address, postal code, country, as well as information about your vehicle such as vehicle ID number (“VIN”), make, model, color, and/or information about your EV charger.

Charging Network Data: When you use EVLUV Service, we may collect information that will be associated with you such as, charging session date, start time, end time, duration, identification number, charging port identification number, fees associated with each charging session, pricing policies, and energy load information such as current and voltage.

EVLUV Operated Station Data: If you operate a charge station using EVLUV for commercial or public use (a “Site Host”), we collect certain information from you as a Site Host, such as contact details and the Site Host’s affiliation or association to a company account, as well as personal information of authorized users who may access the Services on behalf of the site host. If you own or operate a charge station using EVLUV for home use, we may collect session and scheduling data, information relating to the WiFi network you connect to the station, geolocation of the station, and other data you input into the home station.

Fleet Operator. If you operate a fleet of vehicles, we may collect the personal information about your authorized drivers and operators that you provide in connection with the Services, as well as the information relating to their use of the Services, such a geolocation, charging sessions, and other vehicle activity or telematics.

User Content: The Services may allow you to upload content, such as images and photos, and communications with other users. Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.

Payment Information: EVLUV collects your payment information necessary for accessing charging stations that are not free-for-use. EVLUV does not store any of your payment card information, such as credit card numbers, Google Pay or Apple Pay information, within the EVLUV platforms, but rather uses a secure third-party platform that passes very stringent data protection and security standards. EVLUV is PCI compliant via Apple Pay, Google Pay, and Stripe. While we do not directly collect or store any payment card information entered through our Services, we may receive information associated with your payment card information (e.g., your billing details).

Your Communications with Us: We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Surveys: We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

Conferences, Trade Shows, and Other Events: We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

Sweepstakes or Contests: We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Business Development and Strategic Partnerships: We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. Job Applications and Employment: We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

2. Information We Collect From Third Parties

EVLUV may collect information about you or others through our affiliates or non-affiliated third parties, services, and organization. For example, Site Hosts may provide us with additional details about users who will be charging at the stations hosted by the Site Host, including contact information of others; or if you access our Services through a third-party application, such as an app store or a third-party login service, we may receive your personal information from them.

We may also collect information about you from non-affiliated third parties for fraud or safety protection purposes. We likewise may combine information that we collect from you through the Service with information that we obtain from such third parties and information derived from any other products or services we provide.

3. Information We Collect Automatically

We may collect personal information automatically when you use our Services.

Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, information related to your charging sessions, and other information about how you use our Services such as time or locations.

o   Location Information. We may collect precise location information, such as where you complete a charging session, or otherwise in connection with your use of our Services.

Biometric Information is Not Collected by EVLUV: Our Services may be used with a device (for example, an iPhone or an Android phone) that uses the device’s native applications to authenticate user identity through biometrics that are stored on the device itself (such as facial recognition or fingerprints). While we leverage the authentication provided by the device biometrics, we do not have access to this biometric information, and it is not possible for us to collect this biometric information. Please refer to your device’s manufacturer or operating system developer for their privacy policies concerning the use and sharing of your biometric information.

Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:

  • Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

How We Use Your Personal Information and the Purposes of Data Processing

We may use your personal information for our business and administrative purposes, as well as to market our products and Services. For example, we may use your information:

  • To provide access to certain areas, functionalities, and features for your use of our Services and to manage your information and accounts;
  • To disclose personal information with third parties as needed to provide the Services to you, such as financial and payment processing;
  • To processing applications if you apply for a job we post on our Services;
  • To register for events and for general promotion of our services;
  • To personalize and improve your experience and engagement when you use our Services;
  • To send you communications that may be of your interest to you, or otherwise communicate to you about your account, activities on our Services, and policy changes;
  • To evaluate your proposals submitted to our website;
  • To respond to your messages and requests, such as for customer or technical support;
  • To operate, maintain, and improve our Services, as well as develop new products and services;
  • To pursue our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • With your separate consent, to process geolocalization data to provide relevant ads and offers to you;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • To debug, identify, and repair errors with our Services and to ensure internal quality control and safety;
  • To carry out activities to comply with our legal, auditing, or other contractual requirements;
  • To authenticate and verify individual identities, including requests to exercise your rights under this Privacy Policy;
  • To enforce our agreements and policies; and
  • For any other purpose identified at the point of collection that is clearly disclosed to you at the time you provide your information, or with your consent, or for other purposes as requested by you, or as permitted by applicable law.

When you provide permission for data processing through our mobile application, we process information about your location for the purpose of locating the charging station closest to you and enabling you to begin charging once you are within a specified proximity to the charger.

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, [text messages,] custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices, you may contact us at any time as set forth below.

We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.

How We Disclose or Share Personal Information

EVLUV is committed to data privacy and safety and will share the information we collect from you in the following cases, all in accordance with the applicable law:

At your direction or with your consent; or in other conditions outlined below, required for safety, reliability, business, or other needs outlined below:

  • With our Service Providers and vendors that assist us with the provision of our Services, which may include IT support, hosting, payment processing, customer service, and other related services;
  • With our Affiliates;
  • With Business Partners, such as Site Hosts when you connect with a EVLUV operated by a Site Host;
  • With our Advertising Partners who may set tracking technologies on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising”;
  • With other users or third parties you share or interact with;
  • In connection with the negotiation, diligence, or actual merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider related to some or all of EVLUV assets or business, your information may be sold or transferred as part of such a transaction as permitted by law or contract; or
  • We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Third Party Websites and Applications

Links to third party websites or applications may be made available through our Services. Clicking on such links will direct you to the website or application of a third party that we do not control. Any personal data you provide via those sites is subject to the Privacy Policies on those websites and is not covered by this Policy. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. You are encouraged to read the privacy statements of every website you visit or application you use.

Your Privacy Choices and Rights

We reserve the right to contact you for non-promotional purposes, such as to provide receipts or send you messages related to your account with us.

1. Marketing & Interest-Based Advertising Choices

Emails and Communications from EVLUV. Once you register as a user, you will receive information from EVLUV that may be useful to you. You are free to choose how EVLUV contacts you for marketing-related communications as well as to request EVLUV to stop sending you marketing communications, by sending an email to [email protected] or by using the “Unsubscribe” link in any marketing email you receive from us. To keep some of our core services (which may include our mobile application) free or to minimal cost to our users, EVLUV may consider other sources such as advertising in the future. Also, we may send transactional emails to fulfill our obligations to you; these emails are not marketing emails, and you will not be able to opt-out of transactional emails.

Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

2. Your Privacy Rights

In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”) Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information; Request Deletion of your personal information; Request Restriction of or Object to our processing of your personal information; and Withdraw your Consent to our processing of your personal information. If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.

Children’s Privacy

Our Services are available to persons over: (i) the age of 18, or (ii) the legal age of majority in the territory where he/she uses the Services or (iii) the minimum driving age in the territory where he/she uses the Services (the minimum age limit). If you are under the minimum age limit, and particularly if you are under the age of 13 our Services may be available to you only with the consent and approval of a holder of parental responsibility over you in accordance with the applicable law. EVLUV makes reasonable efforts to verify if the consent is given or authorized by the holder of parental responsibility over the person under the minimum age limit. In the event that we learn that you are under the minimum age limit, and particularly under the age of 13, and that you are visiting our online services without verification of parental consent, we will delete information collected from you. In the event EVLUV learns that you are under the minimum age limit, and particularly under the age of 13, and we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act), and that you are visiting our online services without verification of parental consent, we will take reasonable steps to delete information collected from you as soon as possible as required by applicable law. EVLUV requests if you are less than the minimum age limit to not submit information to us.

Changes to this Policy

EVLUV may revise this Policy from time to time at our sole discretion. We will post changes in this notice, or as otherwise required by law. We suggest that you periodically revisit this notice to stay informed of any changes. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements, which may be through email or mobile application notification. By continuing to use the Service, you are confirming that you have read and understood the latest version of this Policy.

Supplemental Notice of Your California Privacy Rights

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information EVLUV has collected about them, and whether EVLUV disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by EVLUV

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

  •       Service providers
  •       Business partners
  •       Affiliates
  •       Other users or third parties you share or interact with
  •       Advertising partners

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

  •       Service providers
  •       Business partners
  •       Affiliates

Commercial information

  •       Service providers
  •       Business partners
  •       Affiliates
  •       Advertising partners

Internet or other electronic network activity

  •       Service providers
  •       Affiliates
  •       Advertising partners

Geolocation data

  •       Service providers
  •       Business partners
  •       Affiliates
  •       Advertising partners
  •       Other users or third parties you share or interact with

Sensory data

  •       Service providers
  •       Business partners
  •       Affiliates
  •       Other users or third parties you share or interact with

Professional or employment-related information

  •       Service providers
  •       Affiliates

Inferences drawn from other personal information to create a profile about a consumer

  •       Service providers
  •       Affiliates
  •       Advertising partners

 The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, EVLUV does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide us with written authorization signed by you and your designated agent by contacting us as set forth below for additional instructions. 

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or to verify an authorized representative to speak on your behalf), or to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in below. We will process such requests in accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

Security of Your Information

We are committed to protecting the security of your information. EVLUV has implemented administrative, physical, and technical security measures that are designed to protect your information under our control. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use or disclosure. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

You should take steps to keep your information safe (including your password) and to log out of your account after use. Where we have provided you, or you have chosen, a password which enables you to access certain parts of any of our Services, you are responsible for keeping your password confidential. You must not share these passwords with anyone or store them in a way that may allow a third party to access them. If that happens, you agree to report it immediately to [email protected]. EVLUV cannot be held responsible for your failure to keep your password secure. You must update your password periodically using best practices (such as strengthening your password with the combination of uppercase and lowercase letters, numbers, punctuation, and other symbols) to help reduce the risk of unauthorized access to your account with us.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

Retention of Personal Information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Other Provisions

Supplemental Notice for Nevada Residents. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

Account Deletion

Account Deletion. If You are using the App on an iOS or Android device, You have the option to delete your account. However, if You have an active or upcoming booking or have an outstanding balance on your account, then You cannot delete your account until there is no active or upcoming booking and there is no outstanding balance on your account. Although your account will be deleted from the App, your booking and transaction history will be retained in our database in case a dispute may arise in the future. 

You can delete our App from your mobile device at any time. Deleting the App does not delete your account or the associated Personal Information. To delete your account entirely, please email us at [email protected].