Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to the AdaptCharge Platform, the software program provided by the Company.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to one of the following as per Your location and/or use of Application.

- United Kingdom (UK) : AdaptCharge Limited ("AdaptCharge"), a company registered in England and Wales with company number 15882568 and registered office at 124 City Road, London, EC1V 2NX.

- India: SASR SAMYSRI Private Limited ("AdaptCharge"), a company incorporated in India with Corporate Identity Number (CIN) U27900AP2025PTC120617 and registered office at 401, Madhavadhara, Visakhapatnam, Andhra Pradesh, 530018,

India.

• Country refers to: UK or India as per Your location and/or use of Application.

• Device means any device that can access the Service such as a computer, a mobile phone or a digital tablet.

• Personal Data is any information that relates to an identified or identifiable individual.

• Service refers to the Application.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used or to assist the Company in operating, securing, supporting, and improving the Service.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• You or Your means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

• Personal Data While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

- First name and Last name

- Email address

- Phone number

- Charging session data: charger ID/location, session start/end time, energy delivered (kWh), price/tariff applied (and taxes if relevant), payment/wallet transaction IDs, receipts/invoices, refunds.

- Vehicle/app usage: vehicle nickname/model (if collected), connector type, favourites, support tickets, error logs.

• Organisation Data If you are using the service as an organisation, we may collect the following information

- Organisation Name

- Organisation Address

- GST or VAT number

• Wallet and payments We collect wallet balance, top-up amounts, transaction timestamps, transaction status, and payment/transaction reference IDs for reconciliation, refunds, dispute handling, and audit/compliance. We do not store full card, UPI PIN, or bank login credentials. Payment processing is handled by regulated payment service providers, who process payment details according to their own policies.

• Location (Foreground & Background) We may collect precise location data while you use the app to show nearby chargers, provide navigation, confirm proximity for starting/stopping a session, improve session reliability, and help prevent fraud or misuse. If you enable background location, we may collect location when the app is not in use to support features such as proximity checks and session reliability. You can disable location permissions at any time in your device settings; if disabled, some features may be limited.

• Usage Data Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

• Information Collected while Using the Application While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

- Information regarding your location

- Photos you choose to upload for charger reviews – When you submit a charger review, you may optionally take a photo or select existing photos from your device to upload. We access your camera and/or photo library only when you choose to upload review photos, and we do not access them in the background.

- Review visibility: Photos you upload with charger reviews may be visible to other users viewing that charger listing. We may remove review content that violates our terms or applicable law.

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server, or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes: To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

• For financial compliance: To process top-ups, provide refunds, generate receipts/invoices, and maintain audit trails for financial compliance

• Account verification: Mobile number and email verification (OTP-based). We do not collect government ID documents for KYC unless explicitly stated in the app at the time of collection.

Where required, we process personal data to perform our contract with you (e.g., providing charging and wallet services), to comply with legal obligations (e.g., accounting/tax), for our legitimate interests (e.g., security and fraud prevention), and based on your consent where you enable optional permissions (e.g., background location). We may share Your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to operate, host, secure, support, and improve the Service (including communications, customer support, fraud prevention, and service diagnostics).

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that

We control or that are under common control with Us.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. We may retain transaction records for longer periods where required for accounting, tax, fraud prevention, and dispute resolution.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. International transfers (UK users): Our systems and service providers may process your personal data outside UK. Where UK law requires for such transfers, we use appropriate safeguards (such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to EU Standard Contractual Clauses) and we assess transfer-related risks.

Delete Your Personal Data

You have the right to delete or request to delete your personal data. We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service. You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us. Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: Comply with a legal obligation

- Protect and defend the rights or property of the Company

- Prevent or investigate possible wrongdoing in connection with the Service

- Protect the personal safety of Users of the Service or the public

- Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us but consider that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Your rights

• Your rights (UK) If you are in the UK, you may have rights to request access to your personal data, correct inaccurate data, request deletion, restrict or object to processing, and request data portability (where applicable). You can exercise these rights; write to support@adaptcharge.io with subject – ‘Privacy Grievance’ and your registered mobile number/email and a description of your request. We aim to respond within a reasonable timeframe and as required by applicable law. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

• Your rights (India) If you are in India, you may have rights to access information about how we process your personal data, request correction or erasure (as applicable), and use our grievance redressal mechanism. To exercise your rights or raise a grievance, write to support@adaptcharge.io with subject – ‘Privacy Grievance’ and your registered mobile number/email and a description of your request. We aim to respond within a reasonable timeframe and as required by applicable law.

Children's Privacy

Our Service does not address anyone under the age of 18.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: By email: support@adaptcharge.io