Charge N Go Australia Privacy Policy (EVNet)

Introduction

Charge N Go Australia Pty Limited ACN 656 295 171 (referred to as ChargeN’Go, we, us or our) has implemented this Privacy Policy to provide you with information about how we collect, hold and use Personal Information and Customer Data:

• through ChargeN’Go’s open-platform network of electric vehicle charging stations (Charging Stations), to which owners of electric vehicles (EVs) may connect in order to charge their EV, and all support network infrastructure and services supplied by ChargeN’Go in respect of the Charging Stations (ChargeN’Go Network);

• through the ChargeN’Go apps which provide data in respect of the ChargeN’Go Network (ChargeN’Go Apps); and

• on the ChargeN’Go website (chargengo.net.au) (Website).

This policy will also apply to any information we collect about you by means other than those listed above (for example, by written communications) on the same basis as this policy.

We are committed to the protection of your Personal Information in accordance with the Privacy Act 1988 (Cth) (as amended from time to time) (Privacy Act) and the Australian National Privacy Principles set out in the Privacy Act (Privacy Principles).

We may, from time to time, review and update this Privacy Policy including, to take into account new laws, regulations and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website.

1. What is "Personal Information" and “Customer Data”?

“Personal Information” is information about an individual’s identity and may include (but is not limited to) the following:

(a) name, postal, billing, email and social media (e.g. Facebook) addresses;

(b) contact details including telephone numbers (landline, mobile and fax);

(c) driver’s licence details and car registration information;

(d) payment details; and

(e) certain information about how an individual uses our ChargeN’Go Network.

“Customer Data” is information we collect about customers which is not considered to be Personal Information, because an individual’s identity could not reasonably be ascertained through the information. Customer Data collected may include (but is not limited to) the following:

(a)details about vehicles using our Charging Stations;

(b) the charging capacity of vehicles using our Charging Stations; and

(c) usage frequency and locational trends of vehicles using our Charging Stations.



2. When and why we collect Personal Information

2.1. We collect your Personal Information to manage our relationship with you, to perform functions and activities relating to our business as further described in clause 5 and as required by law.

2.2. We may collect Personal Information when you:

a) register an account for use of our ChargeN’Go Apps, ChargeN’Go Network, or Website;

b) access or use our ChargeN’Go Network, ChargeN’Go Apps or Website;

c) request information about us, our products or services;

d) request technical support or assistance;

e) provide feedback or make new service requests;

f) fill in a form relating to our ChargeN’Go Network, ChargeN’Go Apps or available on our Website; or

g) contact us by telephone, email, through social media such as Facebook, post or in person.

2.3. We usually collect personal information directly from you although sometimes we may use agents or service providers to do this for us. We may also acquire lists from other sources, both from other companies and from other public documents.

2.4. It is your responsibility to ensure your personal information held by ChargeN’Go is accurate, up to date and complete.



3. Use and collection of Information via our ChargeN’Go Network

3.1. When you connect your EV to a Charging Station or otherwise use the ChargeN’Go Network, the Charging Stations may collect and generate information about you. This information will be stored by or on behalf of ChargeN’Go and accessible to us via the software supporting the ChargeN’Go Network service.

3.2. The information collected by Charging Stations will include, for example, the Charging Stations you use, the amount and type of services you obtain from each Charging Station, and other information regarding your use of our services. We may associate this information with your account and other Personal Information we hold about you, for example in order to bill you for your use of the Charging Stations.

3.4. When you connect your EV to a Charging Station or otherwise use the ChargeN’Go Network, ChargeN’Go may also collect, on behalf of itself and/or its business partners, non-personally identifying Customer Data relating to usage of Charging Stations. All such information may be shared by ChargeN’Go with third parties in ChargeN’Go’s sole and absolute discretion.

4. Use and Collection of Information via our ChargeN'Go Website and App

Location-Based Services

4.1. The ChargeN’Go App may offer location-based search services to help you identify Charging Stations within the ChargeN’Go Network. If you use these services, ChargeN’Go may collect and generate information about you. This information may include your geographic location and the other information you specify in connection with your search, as well as the Charging Stations you locate using your search. This information may reveal your exact location to ChargeN’Go (if, for example, you send ChargeN’Go your GPS coordinates or other precise location information).

4.2. ChargeN’Go may share your location with third parties as part of these location-based services. For example, ChargeN’Go may share your location with a third party to create a map or provide directions to nearby Charging Stations within our ChargeN’Go Network.

Click Stream Data

4.3. When you visit and browse our ChargeN’Go App or Website, our ChargeN’Go App/Website host may collect information for statistical, reporting and maintenance purposes.

4.4 Subject to Clause 8.3, the information collected by our ChargeN’Go App/Website host will not be used to identify you. The information may include:

a) the number of users visiting our ChargeN’Go App/Website and the number of pages viewed;

b) the date, time and duration of a visit;

c) the IP address of your computer or other device; or

d) the path taken through our ChargeN’Go Apps/Website.

4.5 Our ChargeN’Go App/Website host uses this information to administer and improve the performance of our ChargeN’Go Apps/Website.

4.6 We may use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated is used to create reports about the use of the Website. Google will store this information. We will not (and will not allow any third party to) use Google Analytics to track or to collect any personally identifiable information of visitors to our Website. We will not associate any data gathered from this Website with any personally identifying information from any source as part of our use of Google Analytics.

4.7 If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

Cookies

4.8 Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns. Cookies may be either “persistent” or “session” cookies. A persistent cookie will be stored on the user’s computer and will remain valid until its set expiry date, unless deleted by the user before then. A session cookie, on the other hand, will expire at the end of the user session, when the internet browser is closed. 

4.9 If you access our Website a cookie is downloaded onto your device when you first log on. Our Website uses session cookies but also persistent cookies for Google Analytics.

4.10 You can adjust your internet browser to disable cookies, or you can delete cookies already stored on your computer, however we may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.

5. Use and Collection of Personal Information

5.1 We use the Personal Information we collect about you for our business functions and activities, which may include, but is not limited to, the following: 

a) to communicate with you and provide you with information, products or services you have requested, via the ChargeN’Go Network, ChargeN’Go Apps, Website or otherwise;

b) to manage and administer your account including in relation to your subscription, use of the ChargeN’Go Network, use of the ChargeN’Go Apps or Website or to answer any enquiries you may have about your account;

c) to promote and market our products and services to you;

d) to arrange for services to be provided by third parties;

e) to personalise and customise your experiences on our ChargeN’Go Network, ChargeN’Go Apps or Website;

f) to help us research the needs of our customers, and to gain a better understanding of your needs and the needs of customers generally;

g) to conduct research for the purposes of improving our services, creating new services or updating the product provided via our ChargeN’Go Network,
        ChargeN’Go Apps or Website;

h) to conduct research, data analytics and other reasonable activities on behalf of our business partners, such as EV original equipment manufacturers and automobile clubs, including in relation to usage and demographic trends of EVs and the ChargeN’Go Network; and

i) for internal operations, such as record keeping and data analytics.

5.2 We may also be required to disclose your Personal Information if we are required to do so by law.

5.3 We may collect and use your Personal Information for purposes other than those listed in Clauses 5.1 and 5.2. If we do so, we will make it known to you at the time we collect or use your Personal Information.

5.4 If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.

6. Use and Collection of Customer Data

6.1 We collect and use non-identifiable Customer Data for our business functions and activities, which may include, but is not limited to, the following:

(a) collecting information and aggregate data on ChargeN’Go Network services, current usage activities or trends and charging capacities at each Charging Station;

(b) carrying out research and analysis of the behaviour of our customers; and

(c) developing processes, products, services and benefits to better meet customers’ needs.

6.2 We may provide Customer Data to our business partners (including EV original equipment manufacturers and automobile clubs), agents, contractors, service providers or related companies for the purposes of, or in connection with, the supply of services to you and for the same purposes above.

6.3 You agree that ChargeN’Go may use and analyse your Customer Data as required, including for the purpose of improving the ChargeN’Go Network and including your Customer Data in aggregated anonymous databases.

7. To whom we disclose your Personal Information

7.1 In order to carry out the above purposes, we may disclose your Personal Information to third parties that provide products and services to or through ChargeN’Go (including third party couriers), our business partners (including EV original equipment manufacturers and automobile clubs), suppliers, distributors, vendors, financial institutions, our professional advisors, and other parties to whom we are authorised or required by law to disclose information.

7.2 We may also disclose your Personal Information to our Website/ChargeN’Go App host or software application providers in certain circumstances, for example when our Website or ChargeN’Go Apps experience a technical problem or to ensure that they operate in an effective and secure manner.

7.3 Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. The nature of the Internet means that some of your Personal Information may be transferred, stored, processed or used overseas by us or by third party service providers. This may happen if we outsource certain activities overseas or if transactions, information, services or products have an overseas connection. You consent to the collection, use, storage, and processing of your Personal Information outside of Australia.

7.4 In connection with any use of Google Analytics by us, Personal Information may be disclosed to an entity or entities overseas where Google’s servers are located, where it will be stored solely for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries.

8. Marketing

8.1 We may use your Personal Information to provide you with marketing material about us, our services, or products that we think may be of interest to you. We do not disclose any personally identifiable information of our users to advertisers. 

8.2 You may opt-out of receiving marketing information from us at any time by:

(a) clicking on the “Unsubscribe” link included in any marketing email you receive from us; or

(b) contacting us as specified in clause 12.

8.3 Unless otherwise specified in this Privacy Policy, we or our Website/ChargeN’Go App host will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Privacy Principles.

9. Finding out what Personal Information we hold about you

9.1 You are entitled to access Personal Information that we hold about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Privacy Principles. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal.9.2 A request for access can be made by contacting us as specified in Clause 12.

10. Maintenance and security of Personal Information

10.1 We strive to ensure the security, integrity and privacy of our customer’s Personal Information. We use a variety of physical and electronic security measures including restricting physical access to our offices and firewalls and procedural methods to keep personal information collected via our ChargeN’Go Network, ChargeN’Go Apps or Website secure from misuse, loss or unauthorised use or disclosure.

10.2 Personal Information that is held by us in hard copy is stored securely on our premises and is only disclosed or used for the purposes described in this Privacy Policy.

10.3 If we find that we have no further need for your Personal Information we may remove it from our systems and destroy all record of it.

10.4 You can update your contact and Personal Information at any time by contacting ChargeN’Go as specified in Clause 12 or alternatively through the “Account Information” functionality in the ChargeN’Go Apps or the Website (if applicable). We welcome notification of changes to your details so we can keep our records up to date.

12. What to do if you have a question, problem or complaint about our use of your Personal Information
or this Privacy Policy.

If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy Policy in respect of your Personal Information, or for any other queries or communication in relation to this Privacy Policy, please contact us via support@chargengo.net.au or by using the contact details listed on our Website. We will respond to all queries as quickly as possible. If you do not consider our response satisfactory, you may contact the Office of the Australian Information Commissioner.

13. Zoho Campaigns Privacy (Zoho)

ChargeN’Go uses Zoho and/or other electronic email service to provide electronic newsletters to subscribers.

In distributing newsletters, Zoho will collect Personal Information from you, including email addresses you have provided to ChargeN’Go for the purpose of receiving electronic updates, and all information relating to those email addresses. Zoho also uses cookies, web beacons and Flash player codes to collect information about: 

• when you access the ChargeN’Go electronic newsletters;

• your browser type and version;

• your operating system and other similar information.

For more information on the information Zoho will collect, please refer to the Zoho Privacy and the Zoho Terms of Service.

Zoho will use the information collected from you for the purpose of hosting the online platform to enable ChargeN’Go to create, send and manage electronic newsletters. Zoho will also use this information to measure the performance of ChargeN’Go’s email campaigns.

Zoho may transfer this information to its contractors or other third parties who process the information on Zoho’s behalf, or where otherwise required to do so by law.

Zoho is based in the United States of America (USA) and is subject to the laws of the USA. Your information (including your IP address) will be transmitted to and stored by Zoho on servers located outside Australia.

By signing up to electronic newsletters about network updates, partnerships and deals, you consent to your personal information being collected, used and disclosed as set out in these terms and conditions, and in Zoho Privacy Policy and Terms of Use;

• consent to your personal information being sent and stored overseas, and acknowledge that Australian Privacy Principle 8.1 contained in Schedule 1 to the Privacy Act 1988 (Cth) will not apply to the use of the information;

• acknowledge that Zoho is not subject to the Privacy Act 1988 (Cth) and you will not be able to seek redress under the Privacy Act 1988 (Cth) for any privacy breaches by Zoho but will need to seek redress under the laws of the USA.

You can unsubscribe from the ChargeN’Go electronic newsletter at any time by selecting the “unsubscribe” option in every email sent to you by Zoho. If you have any questions or concerns relating to the use of your personal data please contact support@chargengo.net.au 

14. Zoho Campaign Privacy

ChargeN’Go uses Zoho Campaign to manage communications with subscribers.

In distributing communications, v will collect personal information from you, including email addresses you have provided to ChargeN’Go for the purpose of receiving electronic updates, and all information relating to those email addresses. Zoho Campaign also uses cookies, web beacons and Flash player codes to collect information about

• when you access the ChargeN’Go electronic newsletters;

• your browser type and version;

• your operating system and other similar information.

For more information on the information Zoho Campaign will collect, please refer to the Zoho Campaign’s Privacy Policy and the Zoho Campaign Terms of Use Policy.

Zoho Campaign will use the information collected from you for the purpose of hosting the online platform to enable ChargeN’Go to create, send and manage electronic communications. Zoho Campaign will also use this information to measure the performance of ChargeN’Go’s email campaigns.

Zoho Campaign may transfer this information to its contractors or other third parties who process the information on Zoho Campaign’s behalf, or where otherwise required to do so by law.

Zoho Campaign contractually agrees to process personal information in compliance with all applicable privacy laws, including the Australian Privacy Act (please see Section 3(b)). 

By signing up to electronic communications about network updates, partnerships and deals, you consent to your personal information being collected, used and disclosed as set out in these terms and conditions, and in Zoho Campaign’s Privacy Policy and the Zoho Campaign Terms of Use Policy.

You can unsubscribe from the ChargeN’Go electronic newsletter at any time by selecting the “unsubscribe” option in every email sent to you by Zoho Campaign.

15. What else you should know about privacy on the Internet

Remember to close your browser when you have finished your online session. This is to ensure that others cannot access your Personal Information if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe. You as an individual are responsible for the security of and access to your own computer.

Whenever you voluntarily disclose Personal Information over the Internet that information can be collected and used by others. In short, if you post Personal Information in publicly accessible online forums, you may receive unsolicited messages from other parties in return. Ultimately, you are solely responsible for maintaining the secrecy of your username and passwords and any account information. Please be careful and responsible whenever you are using the Internet.