Deftpower B.V.

Westervoortsedijk 73 KB | 6827 AV | Arnhem | The Netherlands

Chamber Of Commerce 78087627 | VAT NL861260016B01 | NL90 INGB 0009 6661 96

www.deftpower.com | operations@deftpower.com

Privacy Policy Deftpower

In our privacy notice you can read more about how we treat your personal data. This, together with any other

documents referred to within, sets out the basis on which we will process any personal data that we collect from

you, or that you provide to us. Please read the following carefully to understand our views and practices

regarding your personal data and how we will treat it.

Privacy Notice content

• The data controller

• How does Deftpower process your personal data?

o What kind of data does Deftpower collect?

o What sources are the personal data obtained from?

o What are the purposes for processing personal data?

o On what legal basis do we process your personal data?

o Automated decision-making

o How long do we store personal data?

o Who processes your personal data?

o Does Deftpower transfer personal data to third countries?

o How does Deftpower protect personal data?

• How do we handle personal data from IP addresses, cookies, and similar technologies

o Cookies used on websites

o Third party access to data collected on Deftpower’s websites

o Location data

• What rights do you have in respect of your personal data?

o The rights of the user

o Blocking of direct marketing

o Automated decision-making?

• Changes to our privacy notice

• Contact

The data controller

How does Deftpower process your personal data?

What kind of data does Deftpower collect?

Deftpower collects data that is necessary for the relationship you have with us and the purposes for which the

data are used. Deftpower collects the following personal data categories.

• Preference data - such as contract type, contact language; payment method; pricing type;

• Security data - such as passwords, security incident information;

• Technical data - such as technical data of customer consumption point;

• Transactional detail data - such as invoicing details;

• Financial data - such as credit card number, bank account information;

• Identifying data - such as name; RFID key number

• Behavioral data - such as customer profiling and other information derived from your use of our

services; login details;

• Communications - such as your answers to surveys and other feedback and communications you send

us;

• Data on your use of our service - such as energy/ electricity consumption data;

• Computer device data - such as IP address, cookie data;

• Contact data - such as email address; telephone number; billing address; delivery address for RFID

keys e.g.

• Contract data - such as payment terms

What sources are the personal data obtained from?

The processed personal data include data that are received from you at the time of the order, at the time of

joining our service, or during the customer relationship. We also receive observed data from your use of our

devices and services. Deftpower may also process derived data which have been derived from or concluded

based on the received data.

In addition, we use Google Analytics to analyze user online behavior.

What are the purposes for processing personal data?

We process personal data only for predefined purposes. The purposes for which we process personal data are:

• Customer relationship management (e.g sending of contract related notifications, product or service

related notifications or updates, customer guidance).

• Contract and product management.

• Providing, managing and maintaining the service (e.g. end-user license management, investigating and

fixing technical issues).

• Identification of data subjects.

• Suspension of provided services.

• Receipt and transaction information storing.

• Contract and invoice archiving.

• Delivering goods and services, including returns’ management.

• Complaint and Dispute management, including compensation demands.

• Transferring personal data (to include transfers and disclosures).

• Billing and debt collection.

• Refunds of payments to customers.

• Internal reporting.

• Establishment, exercise or defense of legal claims.

• Partner reporting.

• Product and Service development, including feedback and surveys.

• Customer satisfaction surveys.

• Vendor communications.

• Fraud protection.

On what legal basis do we process your personal data?

In order for us to be able to process your personal data, we rely on different legal bases, including:

• Your consent. If we rely on your consent as a legal basis for the processing of your data, you may

withdraw your consent at any time;

• The necessity to establish a contractual relationship with you and to perform our contractual obligations;

• The necessity for us to comply with a legal obligation (for instance, we are required by law to store

certain data for a specific period of time) and to establish, exercise, or defend Deftpower against legal

claims;

• The necessity to pursue our legitimate interests, including:

o Internal reporting

o Partner reporting

o Product and service development including feedback and surveys

o Transferring personal data (to include transfers and disclosures)

o Compensation demands

o Debt collection

• The necessity to protect the vital interests of any person;

Automated decision-making

We may make decisions about you through automated decision making. Such as automated tracking of your

potential debt to Deftpower from previous unpaid use of our services.

Our automated decision-making procedures may affect your ability to use our services. We may need to do this

either to perform our legal obligations or because it is necessary to enter into, or the performance of, a contract

between you and us. This means, that if we have outstanding invoices, we may deactivate your account until the

bill is paid.

If we have made a decision about you solely on the basis of an automated process (e.g. through automatic

profiling) and that affects your ability to use the services or has another significant effect on you, you can ask to

not to be subject to such a decision unless we can demonstrate to you that such a decision is necessary for

entering into, or the performance of, a contract between you and us.

How long do we store personal data?

Deftpower seeks to limit the period for which the personal data are stored to a minimum. Thus, Deftpower

processes your personal data only to the extent and as long as is necessary to meet the purposes of the data

processing.

The specific retention periods may be different depending on the categories of data. As a general rule, your

personal data are stored for the duration of the customer relationship as well as for a period of three (3) years

from the end of the customer relationship. Whereas e.g. information about transactions will be kept for at least

ten (10) years on a legal basis. Deftpower sets out and regularly re-evaluates data type specific retention periods

for the personal data it holds. Once personal data is no longer necessary, Deftpower will delete it or anonymize it

as soon as possible.

Who processes your personal data?

Principally, we do not sell, trade or license any personal data to third parties. Personal data may be disclosed to

our authorized employees or affiliates to the extent necessary for the purpose of processing. The data will never

be available to all employees but to a limited number of authorized persons. We also use third parties as our data

processors to help us develop, deliver and maintain our product and services, and fulfil our other purposes as

defined in this privacy notice. When a third party processes personal data on our behalf, we always ensure via

contractual arrangements that the processing of personal data is always conducted safely and in accordance

with privacy laws and data processing best practices.

List of categories of the third parties processing data (=data processors):

• Service providers, such as printing services, installation partners, customer service providers

• Payment Service Providers

• Cloud Service Providers

• Charger Manufacturers

• Roaming platform providers

• IT service providers and Consultancies (e.g. developers, designers, and testers)

• Service and maintenance partners (e.g. HW repair and maintenance)

• Charger Cloud systems providers

• Invoicing and debt collection service and system providers

• Data hosting system providers (Microsoft Azure)

• Software and tool providers (e.g. for software development, business analytics, sales, marketing, work

order management, customer relationship management, online conferencing and communication)

• Operational companies such as the post office or delivery couriers

• Research companies (for e.g. conducting customer satisfaction or product and service development

surveys)

• Telecommunications system providers

In addition, personal data may be disclosed to authorities when we are required to do so by law, based on

demands made by competent authorities in accordance with existing privacy laws.

Does Deftpower transfer personal data to third countries?

Principally, Deftpower does not transfer personal data outside the European Union or the European Economic

Area (EEA). However, if personal data is transferred outside the EU or the EEA, Deftpower uses appropriate

safeguards in accordance with existing privacy legislation, such as the standard contractual clauses provided by

the European Commission.

How does Deftpower protect personal data?

Deftpower fulfils the necessary technical and organizational measures, which ensure and demonstrate that

privacy laws are being followed in the processing of personal data.

These measures include the use of Identity and Access Management systems to ensure that only authorized

persons have access to personal data, the use of firewalls, IP filtering, multi-factor authentication,

pseudonymisation and encryption of data, detailed instructions and training for personnel on protection of

personal data and careful consideration when selecting our service providers that are involved in the processing

of personal data on our behalf.

How do we handle personal data from IP addresses, cookies, and similar technologies

Cookies used on websites

When you use our services or visit our websites, Deftpower can collect data about your devices through cookies

and other tracking techniques.

Cookies are a small text file that we use to Identify and count the browsers and devices that visit our websites.

This information may then be used by us or third parties for marketing purposes.

Our use of cookies differs depending on which of our websites you visit. You can get more information about

which cookies we use on a particular website by reading the specific information about cookies on the current

site.

Location data

The location data of the user’s device may be used to provide services based on the location of the device if the

user has given clear consent to the processing of location data.

The user has the right to withdraw the consent at any time by changing appropriate settings on their device.

What are your rights when it comes to your personal data?

Right of access - You have the right to access your personal data, which means that you have the right to

obtain confirmation as to whether or not your personal data are processed and, if so, also receive a copy of the

personal data that is processed by Deftpower and further information about the processing carried out by

Deftpower.

Data Portability Right - You are entitled to data transfer, which means that you may, under certain

circumstances, have the right to have the personal data transmitted to another controller.

Right to rectification - You are entitled to receive incorrect information about you corrected or supplemented.

Right to erasure - You have the right to have your data erased, if:

• The data are no longer necessary for the purposes for which they are processed

• You withdraw your consent for some treatment and thereafter there is no legal basis for Deftpower to

process the data

• Your data has been processed illegally

• The processing of your data is not necessary to comply with applicable legal requirements in order to

determine, enforce or defend legal claims and/or for archival, research or statistical purposes

Right to withdraw consent - If you have given special consent to a certain treatment, you are always entitled to

withdraw your consent.

Right to object to the processing of personal data - When processing is carried out on the basis of the

legitimate interests pursued by Deftpower or by a third party, you have the right to object at any time to

processing of personal data concerning you. Unless Deftpower can demonstrate compelling legitimate grounds

for the processing, Deftpower shall no longer process the personal data. Right to object to direct marketing - You

are entitled to object to the processing of personal data pertaining to you for direct marketing at any time. Then

we will no longer process personal data for such purposes.

Right to restriction - You are entitled to limit your data during the time we investigate and check your request.

Right not to be subject to an automated decision - If we have made a decision about you based entirely on

an automated process and the decision has legal consequences or otherwise significantly affects you, you may

request that the decision be reviewed by us through renewed and individual assessment. This applies if we

cannot prove that an automated decision is necessary to conclude or implement an agreement between you and

us.

Right to complain to the supervisory authority - You are entitled to complain to the Data Inspection Authority

or other competent regulatory authority if you believe that we treat your personal data in violation of applicable

data protection legislation.

In order to exercise these rights, please do this by email to the following email address: operations@deftpower.com

Further Information

If you wish to opt out to services like Google Analytics, you can use a special command to disable this service for

your browser. Click one of the following links and follow the instructions:

Google Analytics: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Changes to our Privacy Notice

We reserve the right to amend this Privacy Notice. Amendments may be necessary due to the development of

our services or, for example, changes in the relevant laws. Any changes to our Privacy Notice will be

communicated on our website or through our mobile application Deftpower. In some cases, we may choose to

inform about these changes also by email.

Contact

Questions, comments, and requests regarding this privacy notice are welcomed and should be addressed by

email to operations@deftpower.com or by post to:

Deftpower B.V.

Privacy Coordinator

Westervoortsedijk 73 KB

6827 AV Arnhem

The Netherlands