This privacy policy describes the principles ofprocessing the personal data of the users of Gridio’s mobile application.

The controller of personal data is Gridio 2.0 OÜ,registry code 14494626, address Tallinn, Peetri 11, 10414 (“Gridio”).

What personal information we collect

During the sign-up, we collect the following personalinformation:

• e-mail     address, 
• phone     number,
• address, 
• country     of residence, 
• area     code,
• technical     data used to improve our services,
• connected     Device account data required to provide our service,
• EV     model,
• EV     consumption,
• EV     name,
• EV     VIN code.

The legal basis for processing this data is theperformance of a contract in order to provide you with our services.

You will also have the option to sign up using other third-partyplatforms. If you choose to do so, we will ask permission to access basicinformation from that account. You can stop sharing that information with us atany time by removing Gridio’s access to that account.

For what purpose do we collect personal information

Gridio processes personal data for the followingpurposes:

• to     provide and maintain our services;
• to     keep you updated on our services;
• to     provide you with a better experience with Gridio’s mobile application;
• to     be able to communicate with you;
• to     ensure and fulfil the terms of service;
• to     promote safety and security;
• to     develop and improve our services

Use of personaldata

Battery and tariffdata is used to schedule charging to coincide with the cheapest energy windows.

Location data is usedsolely to verify that the EV is at the designated charging location and tooptimise the charging schedule. EV location data is never stored permanently,never shared with third parties, and is only accessed when necessary to provideour charging services.

Access and transfer of personal data

Gridio employees have access to personal data to theextent necessary for the performance of their duties.

Your personal data may be transferred to third parties(for example, technical support) if this is strictly necessary for theprovision of our services.

If personal data is shared with third parties(including App Store, Google Play), then Gridio is not responsible for suchthird-party data protection practices. We recommend that you review therelevant third-party privacy notices.

External processors

Besides payment processing, we also use externalprocessors to analyze the usage of our services, carry out A/B testing of newand improved features and services, and provide technical support to our users.

The following list contains the names of suchprocessors along with the brief descriptions of the processing they do for us,and links to their privacy policies.

AppsFlyer (https://www.appsflyer.com/privacy-policy/)- enables acquisition attribution on native applications

AWS (https://aws.amazon.com/privacy/)- storing of all End User related data and processing of user OEM account,credentials and user vehicle coordinates

Google Analytics for Firebase (https://firebase.google.com/terms) - used for application errormonitoring and product usage data

Google Workspace (https://cloud.google.com/terms/cloud-privacy-notice)– used for customer support emails

Sentry (https://sentry.io/privacy/)- Application quality monitoring and automatic error reporting

Slack (https://slack.com/trust/privacy/privacy-policy)- used for customer support purposes

RevenueCat (https://www.revenuecat.com/privacy/)- manages subscription details, including renewal status and payment methods.

Third-Party Service Providers (e.g. carmanufacturers)

As part of our collaboration with certain carmanufacturers, you may have the option to use our services when purchasing avehicle from one of our partnered manufacturers (“Partner”). In suchcases, the service will be provided through a separate application under adifferent name. While you will be using such a service, please note that theprivacy practices and terms of use for the mobile application may differ fromthe mobile application we provide directly to end-users.

In cases where you access our services through thethird-party app provided by a Partner, they will be the data controller for anypersonal data collected through their application. As the data controller, the Partneris responsible for determining the purposes and means of processing yourpersonal data in relation to their app and services. We, as the serviceprovider, will act as a data processor under their instructions andfunctionalities provided by our mobile application when processing your data aspart of our service offering.

When you purchase a vehicle, the Partner will sharelimited personal data with us, such as your email address, for the sole purposeof sending you an invitation to join our service. We do not use thisinformation for any other purpose unless and until you register and start usingthe mobile application.

If you receive our service through a Partner, thisPrivacy Policy still applies to your personal data. We treat your personalinformation with the same level of care and in accordance with the termsoutlined in this policy, regardless of whether you receive access to ourservice.

Unless explicitly stated, the Partner does not haveaccess to the personal data you provide directly to us as part of using ourservices. We do not share, sell, or transfer your personal information to the Partner,except as necessary for the performance of the contract or as otherwisepermitted by this Privacy Policy.

Regardless of how you access our services, you retainyour rights under applicable privacy laws, including the right to access,correct, or request deletion of your personal data held by us.

Your personal datawill be retained for as long as you have access to the mobile application. Oncethe Partner withdraws from their agreement with us, your data will be deletedor may be stored in an anonymized form for statistical and analytical purposes.

You may agree on data continuity in the event that youstop receiving the service from a Partner, but you wish to continue usingGridio’s services.

In case of a request, mobile application or complaintconcerning the service, please contact us at support@gridio.io. We willreview your inquiry and, where appropriate, forward relevant information to thePartner to ensure your concern is addressed in coordination with them.

Security

Personal data is stored on servers located in theEuropean Union. Personal data may be transferred to third parties in the UnitedStates, but only to companies that provide a sufficient level of security.

To provide our Service to you, Gridio usesselected third parties to provide you with the service, and shall share someinformation with them, under strict confidentiality obligations, to provide youwith the services. Our service providers include Amazon Web Services, amongothers, which enable us to run our cloud-based platform.

Gridio has implemented appropriate technical andorganizational measures to ensure the security of personal data, includingunauthorized or unlawful processing, and accidental loss, destruction or damageof personal data. For example, the GPS location of your EV is never stored byGridio, except when you first set up the service, and this information is nevershared with any other parties. This information is only used to verify whetheror not the vehicle is at your designated smart charge location.

If a personal data breach occurs and such a violationmay pose a high risk to your privacy, Gridio informs you and the relevantauthorities of such a breach.

Rights

You have the right to request rectification, accessand, if necessary, objection to the processing of personal data.

You may request the deletion of personal data, afterwhich we will inform you about the terms and time limit for deleting thepersonal data. The personal data will not be deleted if there is a legal basisfor its retention.

You have the right to receive personal data inmachine-readable form and to transfer such data to another data processor.

You have the right to withdraw your consent to the processingof personal data at any time. 

In order to exercise your rights on personal data,please contact Gridio at support@gridio.io. 

You also have the right to appeal to your local DataProtection Inspectorate.

Retention

Your personal data shall be retained until you ask todelete your personal data. After some time, we may renew your consent in orderto keep it active and valid.  Personal data may be stored anonymized forstatistical and analytical purposes.

In the event of a dispute, the personal data will beretained until an agreement is reached or until the due date for the claimexpires.

Direct marketing

If you are using our services, we may send directmarketing messages to your email address. You can opt out of these messages atany time by contacting us or clicking the “Unsubscribe” button at the bottom ofthe message. Please note that you cannot unsubscribe from service-relatednotifications.

Miscellaneous

In case of a request, application or complaint concerningthe processing of personal data, please contact support@gridio.io.

Gridio has the right to change this privacy policy atany time. Gridio will notify you of any changes to this privacy policy on itswebpage.