Privacy Policy

Assist EV Network (“Assist EV” / “we” / “our” / “us”) has created this privacy policy (“Policy”) to inform you on how we process your personal data, whether you are a visitor to our website, a purchaser of our electric vehicle charging stations, or a user of electric vehicle charging stations on the Assist EV Network. The “Assist EV Network” is defined as the open-platform network of electric vehicle charging stations and the vehicle charging applications the network delivers, that is operated and maintained by Assist EV.

This Policy applies to your use of the Assist EV website (the “Website”), the mobile application (the “App”) and to any service offered by Assist EV, including your Assist EV account (if you have registered or are registering your account) as well as the Assist EV radio-frequency identification cards (the “RFID cards”) (each of these services and applications are collectively defined as the “Service”). For purposes of this Policy, “Driver” shall mean an individual who signs up for an Assist EV account to access the Assist EV Network.

The controller of the processing described in this privacy policy is Assist EV, located at 1 Runway Farm, Honiley Road, Meer End, Kenilworth, CV8 1NQ. Assist EV’s designated person responsible for Assist EV’s handling of your personal data is our Data Protection Officer. You can contact our Data Protection Officer at [email protected]

Please read this Policy carefully to understand our practices regarding your personal data and how we collect, process and transfer it. If you have any questions about this Policy or how we handle your personal data, please email us at [email protected]

This Policy was last changed on January 29, 2022. We reserve the right to change this Policy at any time. If we do, we will provide notice when we are legally required to do so.

1. Information we collect and use

   1. Information Assist EV processes about you

      Assist EV may collect the following information from you:

      1. When you register an account with us and access the Assist EV Network, we collect your: full name, username, password, title, email address, telephone number, postal code, country, location, Assist EV card number, user identification, user differentiator, and the last four digits of your credit card number or information about other means of payment (collectively, “Account Data”);
      2. When you register an account with us, we may process additional information that you provide to us at your sole discretion, like your full address or information about your vehicle (e.g., make, model, colour, etc.), to provide you with Service notifications and your membership account information, (collectively, “Optional Account Data”);
      3. When you use Assist EV’s social media features to communicate with other users of the Service or upload a photo of the station, we collect your username and other information like charging station name and charging station location, (collectively, “Social Media Data”). Assist EV may use Social Media Data for marketing and promotional purposes, as described below;
      4. When you use the Assist EV Network, but you are not a customer of Assist EV, (e.g., you are Customer of a third-party network provider that has a roaming agreement with Assist EV either directly or through a “Clearinghouse”, a hub for technical integration with multiple roaming partners), we will collect the following information about you (“Roaming Data”). Roaming Data includes: the charging session’s date, start time, end time, duration, identification number, energy dispensed, charging port identification number, total fees associated with each charging session, pricing policy applied, and either an Access Card Identification Number or an EV Contract ID. You will have access to the Assist EV Network and the data will be formatted and delivered according to the specifications described in the OCPI, OCPH or other protocols agreed to between Assist EV and the other network or Clearinghouse;
      5. If you sign up for the Service, use the Service, or send an email or other communication to Assist EV (e.g., phone call, text, push notification, etc.), we may retain your contact information and those communications (“Communication Data”). Communication Data is the communication between the Driver and Assist EV for purposes of customer support, marketing and billing;
      6. If you own or operate an Assist EV station (a “Site Host”) we retain data about the station owner’s contact details, and if relevant, your affiliation or association to a company account;
      7. If you own an Assist EV Home product, we may collect session and scheduling data for the Assist EV Home product, Driver inputted data (e.g., Driver Tips), station images and photos uploaded by a Driver, your vehicle make, model, year and colour (collectively, “Home Station Data”);
      8. When you visit our Website, we collect the following data: IP address, date and day of access request, pages viewed, time zone difference to Greenwich Mean Time (GMT), the standard HTTP-header information, the time spent on each page of our Website, links you have clicked on our Website, the page you visit before and after you come to our Website, browser type, operating system, language and version of browser software (“Website Data”);
      9. When you use our application, we collect the following data: IP address, date and day of access request, pages viewed, time zone difference to Greenwich Mean Time (GMT), mobile device location, the standard HTTP-header information, the time spent on each App page, the geolocation of your mobile phone, links you have clicked on our Website, browser type, operating system, language and version of browser software (“App Data”);
      10. When you use our Service, we process information about how you use the Service, including: your Assist EV charging station location, MAC address of your connected device (e.g., mobile device, PC or laptop), charging station name, charging duration, energy consumed, power cycle patterns, current, voltage (“Session Data”);
      11. We may process information you provide through online surveys and polls (“Survey Data”), provided that participation in these surveys or polls is entirely voluntary and you may easily decline to participate;
      12. Drivers provide their full name, login credentials (e.g., username/password, a secret question and answer), contact information (e.g., email address, phone number, mailing address), vehicle information (optional), and optional information through the “Connections” feature as may be required by a Site Host. The Connections feature allows Site Hosts to control which Drivers receive benefits (e.g., access, preferential pricing) to their stations. If a Site Host chooses to elect the Connections feature, the Site Host may ask the drivers for additional information to verify their identity to access the benefits. Assist EV does not monitor or control the additional personal information that the Site Host can request from a Driver.
   2. How Assist EV uses your personal data and for what purposes

      Assist EV may use the personal data which we collect about you for the following purposes:

      1. Assist EV uses your Account Data, Optional Account Data and Home Station Data to:
         
         1. process your application to create an account with Assist EV;
         2. provide our Service to you including information, products, and services you request from us that enable you to access our charging stations network;
         3. process payment of fees;
         4. notify you of changes to our Website or Service;
      2. Assist EV uses your Session Data and Home Station Data to:

         manage and administer your account, including to distinguish between multiple vehicles or users under a single account, and for information regarding charging sessions (e.g., duration, energy consumption, station owner and station data);

      3. Assist EV uses your Account Data, Optional Account Data, Home Station Data and Session Data to:
         
         1. manage and respond to any inquiries, correspondence, concerns or complaints you have sent to us;
         2. otherwise communicate with you as a customer or user regarding the use of our Website or Service; and
      4. Assist EV uses your Social Media Data to:
         
         1. enable you to communicate with other users, like providing other users and Site Hosts information through Driver Tips;
         2. promote and market Assist EV products and services.

            The legal basis for this processing of your personal data is Art. 6 (1) (b) GDPR: we do this to perform our agreement with you under the terms of the Driver Agreement and, if applicable, the Master Services and Subscription Agreement—an agreement between Assist EV and a Site Host that governs the terms of the Assist EV Network services.

      5. Assist EV uses your Communication Data (1) to provide the Assist EV Service and (2) to the extent we are obligated to retain communication with you under the applicable laws (including tax, financial, or other governmental regulations). Regarding the former, the legal basis for this processing of your personal data is Art. 6 (1) (b) GDPR. Regarding the latter, we are justified to the retain the data under Art. 6 (1) (c) GDPR.
      6. Assist EV processes the following personal data because Assist EV has a legitimate interest under the GDPR to do so.

         Assist EV processes Website Data and App Data to:

         • analyse the Website’s or the App’s use to improve them;
         • assist with customer service requests and accessibility; and,
         • keep our Website or App secure and operational.

           Assist EV processes your Account Data, Optional Account Data, Home Station Data, Session Data and Roaming Data to:

         • ·provide you our Service;
         • safeguard the security of our systems and the Service;
         • analyse and compile information on Service use patterns;
         • perform billing and customer support purposes;
         • provide value added services, promotions and pricing.

         The purposes described in this Section reflect corresponding legitimate interests of Assist EV, and the processing set forth herein is necessary for these purposes. The legal basis for the processing of this data is Art. 6 (1) (f) GDPR.

      7. Personal data we only process on the basis of your consent:

         Assist EV may use your Account Data, Optional Account Data, Home Station Data, and Session Data to provide you with information about our products, services, sweepstakes, or promotions or information from our third-party partners that may interest you, but we will only do so if you gave us permission. Please see the “Marketing” section below for further information.

         We process Survey Data to carry out online surveys and polls, but only if you gave us permission.

         We may also use pseudonymized information and data from the Survey Data to (1) improve the Service and (2) for Assist EV’s marketing purposes where you have provided express consent.

   3. Children

      The Website and Service are intended for persons licensed to drive. In the EU, this typically means individuals over the age of 18. Assist EV does not knowingly collect any information from anyone under 18 years of age. If you are less than 18 we request that you do not submit information to us.

   4. Cookies

      Like most websites, Assist EV uses cookies and similar technologies including web beacons, embedded scripts and e-tags (together referred to as “cookies”, unless otherwise stated) to provide users an efficient user experience in using the Website.

      1. What is a Cookie? A cookie is a small data file that is placed on your computer or mobile device by your web browser. It is a tool that stores information about website visits, recognises you and your preferences each time you visit the Website, and ensures website functionality and enables us to provide the Service which our customer’s request. A cookie file can contain information (e.g., a user ID) that the site uses to track the pages you have visited, but the only personal data a cookie can contain is information you supply yourself. A cookie cannot read data off of your hard disk or read cookie files other sites created. Some parts of the Website use cookies to track user traffic patterns. Assist EV uses cookies to determine (1) the Website information’s usefulness to our users and (2) the Website navigational structure’s effectiveness in helping users reach that information. Assist EV does not correlate this information with data about individual users, nor does it share this information or sell it to any third-party.
      2. Can I stop a Cookie from being placed on my Web Browser? When you first visit our Website, we ask you to consent to our use of these cookies. If you do

         not give your consent, we will not use cookies and tracking technologies. This also applies if your browser settings are set up as ‘Do Not Track’.

      3. Some additional things you should know about our use of cookies:

         You may encounter cookies from our third-party service providers (e.g., Google Analytics, Google AdWords, Marketo, Facebook, LinkedIn and Fullstory) that we have allowed on our Website to assist us with various aspects of our Website operations and services. For a full list of the cookies we use, their duration and the type of cookies please see below. You also may encounter cookies from third parties on certain pages of the websites that we do not control and have not authorized. For example, if you view a web page posted as a link from our Website, there may be a cookie placed by that web page.

         We may use cookies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our Website, for when you later return to the Website.

         We use various types of cookies, including session cookies, persistent cookies, local shared objects, pixels, gifs and other tracking technologies, such as third- party tags, session and persistent technologies, first and third-party cookies. Cookies can be persistent by remaining on your computer until you delete them, or cookies can be based on your browsing session where they delete once you close your browser. First-party cookies are used and controlled by us to provide services on the Website.

      4. The cookies Assist EV uses. Assist EV uses cookies for a variety of reasons, including to: provide you the Service you have requested, enhance our Website’s performance, or analyse how users use our Website. Our use of cookies falls into four categories:

         Strictly necessary cookies: these are essential to enable you to move around the Website and use its features. Without these cookies, the Services you have requested cannot be provided. Performance cookies: these cookies are used to improve how our Website works. They collect information about how users use our Website (e.g., which pages users visit most often, and if users get error messages from web pages). All information these cookies collect is aggregated and therefore anonymous.

         Functionality cookies: these cookies allow us to remember what choices you make (e.g., your user name, language or the region you are in) to provide enhanced, more personal features. The information these cookies collect may be anonymised. These cookies cannot track your browsing activity on other websites.

         Advertising and marketing cookies: these cookies are used to: send you advertising, and marketing-related material tailored to you and your interests, limit the number of times you see an advertisement, and help measure

         advertising campaigns’ effectiveness. These cookies are usually placed by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations like advertisers.

         Our use of cookies may change over time but will generally fall into the above categories. Please visit this page regularly so that you are aware of any changes.

      5. Third-party cookies Google Analytics

         This Website uses Google Analytics to collect information about how users use the Website. The information the cookie generated about your use of the Website will be transmitted to and stored by Google on servers in the United States. Your IP address will be partially used within the European Union or just in the European Economic Area if it is used by other parties. Only in exceptional cases will the full IP address be transferred to a Google server in the United States, and then shortened so it is only partially used there. The IP- anonymization is active on this Website.

         Google will use this information on behalf of the Website operator for the purpose of analysing your Website use, compiling reports on Website activity for Website operators and providing them other services relating to Website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, that if you do this you may not be able to use the full Website. You can also opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser.

         Assist EV also uses a variety of functional, marketing and analytical cookies to enhance your Website experience:

         Functional cookies

         Functional cookies ensure that our Website functions correctly. These cookies facilitate the operation and improve the functions of the web pages. For example, we store your language settings in functional cookies.

         Analytical cookies

         With analytical cookies we collect statistics about how our Website is used with the help of third parties. For example, we collect and store when and for how long you visited or used the Website.

         Marketing cookies

         Similar to analytical cookies, we work with third parties to place marketing cookies on our Website. We do this so that we can make you the most relevant offers based on your online surfing and searching behaviour. With these marketing cookies we also track of which ads you have seen.

      6. How to manage the cookies we use. You may control and block the cookies used by the Website by modifying the settings in your browser or on your device that allow you to refuse the setting of all or some cookies. You can also adjust your settings so that your browser blocks all cookies or only cookies from third parties. You can also delete cookies that have already been placed. However, please note that if you use your browser or device settings to block all cookies you may not be able to access all or parts of our Website. For more information about how cookies can be managed and deleted please visit http://www.allaboutcookies.org/or http://www.networkadvertising.org/choices/.
      7. Processing personal data in the context of cookies. Because cookies contain personal data, the purposes described in this Section reflect the legitimate interests of Assist EV, and the processing set forth herein is necessary for these purposes. The legal basis for the processing of this data is Art. 6 (1) (f) GDPR.

         With the use of some cookies, personal data like email address, IP address, etc. may be processed. If and inasmuch as personal data is processed, the legal basis for processing that data is your consent, expressed through choosing the opt-in option when you first visit(ed) our Website, and, consequently, Art. 6 (1) (a) GDPR.

2. Recipients, or categories of recipients, of personal data

   1. We generally do not share your personal data with any third-party. However, we do share some of your personal data as follows:
      
      1. To our service providers and other contractors (e.g., hosting and financial providers, marketing, customer support platforms, and data storage providers);
      2. To our distributors, resellers, channel partners, Assist EV charging station owners, or authorized third parties including third-party network providers, utilities or their respective employees, freelancers, and consultants to help us provide our Service to you;
      3. When you connect with a station owner through the Assist EV Connections feature as defined in Section 1(a).
      4. When you use our social media features to provide information to Assist EV users about our Services, we share your Social Media Data with these other Assist EV users;
      5. When we resolve customer disputes or inquiries, we use a company to provide us with support on this. This company is based in the Netherlands and has access to customer service data and calls associated with Driver.

         In addition, Assist EV may share some or all of the personal data mentioned under Section 1(a) with third parties in the following circumstances:

      6. To a transition partner as part of a merger, acquisition or any form of sale of some or all of Assist EV assets or business;
      7. In the unlikely event of insolvency, bankruptcy or receivership in which your personal data would be transferred as one of Assist EV’s business assets; and,
      8. Where we are legally obligated to disclose information to the government or third parties for the purposes of criminal or fraud investigations, national security, law enforcement or other issues of public importance.

         Lastly, Assist EV is part of a group of companies, including A Bright Solution UK Ltd. We transfer some of your personal data to this entity as well. We explain this further in Section 4.

         Except as stated above, we will not disclose your personal data to any third parties for any other purposes unless (1) we have your consent or (2) we otherwise have the legal basis or obligation to do so in an individual case.

3. Security Measures

   1. How we protect your personal data

      Assist EV has security measures in place to protect your personal data under our control. To help protect the personal data we collect through the Website or Service, Assist EV uses industry-standard and secure server software that encrypts the information you input before it is sent to us. In addition, Assist EV uses standard industry practice to protect personal data against unauthorized access.

      While Assist EV takes reasonable precautions against possible security breaches of its Website, no website or Internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We are unable to guarantee the security of your personal data while it is being transmitted to our Website or stored in our systems and any transmission is at your own risk.

   2. How you can keep your personal data secure

      You should take steps to keep your personal data 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 Assist EV’s Website, or an Assist EV RFID Card to access charge stations, you are responsible for keeping your

      password and Assist EV RFID Card confidential. You must not share these 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]. Assist EV cannot be held responsible for your failure to keep your password or Assist EV RFID Card secure.

      You should update your password periodically to help reduce the risk of unauthorized access to your account with us. When you do, you should strengthen your password with the combination of uppercase and lowercase letters, numbers, punctuation and other symbols.

4. Transfer of personal data to third countries

   1. Assist EV is a global company which operates its Website and Service through servers located in several countries. If you select a country in Europe as your country of residence, your personal data is hosted on servers within the European Union only.

      We may have to grant access to your personal data, (including your name, full address, email address, telephone number, security question and information about your vehicle including your license number and the make, model, colour of your vehicle), however, to A Bright Solution UK Ltd (our parent company) for Assist EV to provide you with our support services or to troubleshoot any issues to improve our support services.

      In addition, we will transfer certain data (customer service data, pseudonymized session data) to A Bright Solution Ltd, to develop and improve further our products and services for users, which may include pseudonymized information coupled with session data (e.g., length of charge, location of charge, amount of energy received and fee).

      Further, Assist EV Inc. may also need to access pseudonymized information for financial accounting and analytical purposes, and we will grant such access accordingly. Such analytical purposes shall include, but is not limited to, usage patterns of the Assist EV charging station network, to inform product development, safety features, sales strategy, customer service, support and maintenance.

      If any such access is granted or data is transferred to A Bright Solution Ltd., it will be done through a secure network.

5. Links to Third Party Websites

   This Website may contain links to third-party sites. Access to any other websites linked to the Assist EV Website is at the user’s own risk, and Assist EV is not responsible for the accuracy or reliability of any information, data, opinions, advice or statements made on these websites. Assist EV provides these links merely as a convenience and the inclusion of such links does not imply any kind of endorsement. If you provide any third-party with your personal data, we recommend that you review their privacy policies as Assist EV does not control how they collect, process and transfer your data.

6. Marketing

   1. We may also use your Account Data to send you advertising and marketing-related information (e.g., newsletters and events) from Assist EV. Such direct marketing has its legal basis under Art. 6 (1) (f) GDPR, and our legitimate interest is an interest in directly marketing our products to you as an Assist EV customer. If you have an account with us, we may email you such marketing and promotion offers based on your account activity and information collected from Cookies.

      In addition, we may ask you for your express consent in certain marketing activities.

      In any case, you may at any time unsubscribe by clicking on the “unsubscribe” link at the bottom of each marketing communication.

   2. You may be also invited to receive advertisements from Assist EV’s partners and, provided you have given your consent, you may receive marketing communications from our partners. These offers from other businesses may require you to provide information to them if you choose to accept their offers. You should remember that these offers from other businesses are made by the relevant businesses themselves and not by Assist EV. You should always be sure to read the specific terms of service and privacy policies of these third-party businesses before providing any information to them so that you can understand their intended uses for your information. If you have consented, Assist EV may receive information from these businesses regarding your response to their offers so that Assist EV may better tailor your user experience.

      Please note that where you opt out of, and unsubscribe from, receiving marketing communications, we may still send you certain communications relating to your use of the Service (e.g., service announcements, notices about new features or information on the Service, administrative messages and communications regarding your account).

7. Account Termination

   1. Under the law, Assist EV may keep data related to you for seven (7) years, the legal basis for processing this data being Art. 6 (1) (c) GDPR.
   2. Users can request to correct and delete their account by contacting Customer Service. Such requests are typically dealt with within two (2) business days. If you want to stop using your account, it will initially be deactivated. We save your information in case you later decide to restore your account. You will be able to restore your account within 30 days. After the expiration of 30 days, your account and information will be removed and deleted. The legal basis for our retaining your data in this event is Art. 6 (1) (f) GDPR.

8. Period for which the personal data will be stored

   1. In principle, we will store your personal data only as long as necessary for purposes for which the data were collected or otherwise processed. In particular, this means:
      
      1. General use of our Website and the Service

         We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.”

      2. For contractual purposes

         For contractual purposes, we retain all Account Data for as long as our contractual agreement is not terminated. After this period, we will retain your information for additional time in order to be able to make claims resulting from our contractual relationship or defend ourselves against such claims. In addition, Section 7 applies to data which we obliged to retain under statute.

      3. Data processed on the basis of your consent

         We process the corresponding data until you withdraw your consent.

9. Your Rights

   1. If the respective requirements in the GDPR are met, the GDPR grants you certain rights as a data subject.
      
      1. Art. 15 GDPR – Right of access: You have the right to request from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain information.
      2. Art. 16 GDPR – Right to rectification: You have the right to request from us the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
      3. Art. 17 GDPR – Right to erasure: You have the right to request from us the erasure of personal data concerning you without undue delay.
      4. Art. 18 GDPR – Right to restriction of processing: You have the right to request from us the restriction of processing.
      5. Art. 20 GDPR – Right to data portability: You have the right to request to receive certain personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to request to transmit that data to another controller without hindrance from us. You also have the right to request the personal data transmitted directly from us to another controller, where technically feasible.
      6. Art. 77 GDPR – Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State

         of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

   2. Right to object and to withdraw your consent.

      In addition to the rights mentioned above, you have also the right to object to certain processing and the right to withdraw your consent, where processing is based on such.

      1. Art. 21 GDPR – Right to object

         You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, which is based on legitimate interests or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

         In such case, we shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of legal claims.

         Where personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

   3. Right to withdraw consent, Art. 7 par. 3 GDPR.

      Where the processing is based on your informed consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Therefore, you may send us a message to in writing to Assist EV at the address detailed above, or email at [email protected].

10. Your obligation to provide us with personal data.

    You have no statutory or contractual obligation to provide us with any personal data. However, depending upon the activity, some of the information we may ask you to provide is identified as mandatory (because we need it in order to provide the requested Service). If you do not provide the mandatory data with respect to a particular Service, you will not be able to use that Service.

11. Existence of automated decision-making, including profiling.

    We do not use automated decision-making, including profiling, which produces legal effects concerning you or similarly affects you significantly.

12. Contact Us

You can contact us by email at [email protected] or write to us at: Assist EV, Attn: Customer Service Assist EV, 1 Runway Farm, Honiley Road, Meer End, Nr. Kenilworth, Warwickshire CV8 1NQ

Last Updated: 29th January 2022