Thank you for trusting GoPlugable (we, us or GoPlugable) to be responsible for your personal data. We respect your privacy and are committed to protecting your personal data.

This privacy policy (policy) applies to all processing of personal data undertaken by GoPlugable (other than processing of personal information in the context of recruitment and employment, which is dealt with under separate internal policies) including when you interact with us as one of our suppliers, hosts or chargees (or as an employee or representative of same), visit our premises, or visit or use our website (regardless of where you visit it from https://www.goplugable.com/ (our website) and the software services available through it, including downloadable software applications such as our GoPlugable community-powered EV charger-sharing network (the App), which you may download, access and use on your mobile device. We describe the Software Services or functionality offered by the App and website collectively in this policy as the software services.

Any data that we collect through our website or generally when providing you with our other services shall be known as the “Customer Data”, and any data collected specifically through the App (or any browser-based interface for accessing the App) is known as the “GoPlugable Data”.

For the purpose of this privacy policy, a user (a user) means any individual using our website or App (including to find out more about the cleaner, greener future that we stand by, learn about EV charging solutions, register as an owner of an EV charger who wishes to monetise their charger (a host); or to find a spot to charge their own electric car (a chargee).

This policy also informs you about your privacy rights and how the law protects you. It does not cover any third-party website you have used to access our websites or App, any third party websites that you access from them, or any interactions between users which have not been conducted via our website or App.

It is important that you read this policy so that you are fully aware of how and why we are using your data.

1. WHO WE ARE

1.1 Contact Details

Our full details are:

Full name of legal entity: Power Rangers EV Technologies Ltd T/A GoPlugable, a company incorporated in Northern Ireland under a registered company number: NI697254.

Email address: info@goplugable.com

Postal addressSU Co-Work, One Elmwood, 77-79 University Road, Belfast, BT7 1NF

ICO Registration Number: [ ]

1.2 Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, including the UK Data Protection Act 2018 and the Irish Data Protection Acts 1988 to 2018, we act as both a controller (i.e., where we make decisions) in relation to your personal data that we collect, as well as a processor (i.e. process data broadly in accordance with your instructions).

When we act as a Processor: When as a user you use the Software Services to process other peoples’ personal data, or make decisions regarding your own personal data (for example, where users interact with each other and share personal data via the Software Services), we act as a processor. Under these circumstances, you may act as a controller or processor yourself, and we will act as either a processor or a sub-processor.

When we act as a Controller: By contrast, when we collect personal data and determine the purposes and means of processing that personal data – for example, when we store account information for account registration, administration, services access, or contact information as explained below – we act as a controller. This policy is intended to tell you more about the ways in which we process your personal data as a controller.

1.3 Third-Party Links

Our websites and Services may include links to third-party websites, widgets, plug-ins and applications (including various social media platforms). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. WHAT KIND OF PERSONAL DATA DO GOPLUGABLE PROCESS?

INFORMATION YOU SUPPLY TO US

2.1 General Personal Data: This is personal information about you that you share with us by online forms on our website, through email, through the post, on the telephone, when you register to use the Software Services, when you complete customer surveys, engage with our customer services team, or by any other means.

GoPlugable Data

Typically, when you sign up to use the Software Services as a user, or when using the Software Services, you may be asked to provide information about yourself, including your full name and email address, address, telephone and/or mobile phone number, username and password, alongside other non-personal details. The App prioritises your security through the use of two-factor authentication during login. You have the flexibility to log in using either your social media accounts (like Facebook) or your email address. To verify your identity, you might also be required to provide a valid photographic ID document, for example, a passport or driver’s licence. For clarity, as noted in our terms, while we take certain measures to verify the identities of our users, we do not conduct exhaustive background checks and we cannot assume liability for such verification. The App functions as an online marketplace, relying on mutual trust between chargees and hosts.

Additionally, you may be required to upload photos of the charging location and electricity meter photos before and after charging, which enables Users to verify EV charger usage more effectively (these photos may contain personal data to the extent your meter point reference number is captured in them or other personal details).

When you sign up as a host, we will also ask you to share details of any relevant address at which you own an EV charger with us.

When you sign up as a chargee, we may ask you to share your home address with us, which we will keep confidential and will not make visible for other users or hosts. For the avoidance of doubt, GoPlugable reserve the right to disclose this information to authorities, courts or involved parties in case of a dispute. When you sign up as a chargee, you must also share your driver registration number (indicated on your driver’s licence) and vehicle registration number.

You may also provide personal data when you report any technical or service issues in relation to our Software Services, including relevant notes about any issues and how we responded to resolve these, as well as details of any payments you have made via our Software Services.

2.2 Financial Details: Where you pay for the Software Services, these payments will be made by credit card through a third-party payment processor (currently Stripe Inc.) whose terms and conditions and privacy policy you will be required to accept in order to use our website.

Your financial details will be collected and held by the third-party payment processor. We will not collect or hold your financial details but we will obtain details of your third party payment processor username and other details such as your name, email address and/or telephone number and address.

2.3 Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.

2.4 Marketing Information: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).

2.5 Third Party Data: Where you are sharing such personal data that does not directly relate to you (e.g. your representatives that legally act on your behalf), you must ensure you have the consent to do so and have shared this policy with that person/those people. For the avoidance of doubt, however, you must own the EV charger and have permission to permit any third party chargees to charge their vehicles using your EV charger where you sign up as a host, and must also have valid rights to use any vehicle you charge through hosts with whom you have connected via the software services where you sign up as a chargee.

IF YOU FAIL TO PROVIDE PERSONAL DATA

2.6 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Software Services). In this case, we may not be able to provide those services.

PERSONAL DATA WE COLLECT

2.7 Telephone Recordings - Telephone conversations may be recorded for training or monitoring purposes.

2.8 Technical Data from our Websites: We use certain technical services to gather technical data online whenever you use our website (as a visitor) including information about your device and your visits to our website such as your IP address, geographical location, browser type, referral source, internet service provider (ISP), clickstream data, browser type and language, time zone, length of visit and pages viewed, date or time stamps weblogs and other communication data. Please see our cookies policy for further detail, which can be found in Schedule 1 to this policy.

Where logged in, you will be personally identifiable from the technical data we collect using the website, as it will be tied to your specific user account.

2.9 Technical Data from the App: We also use certain technical services to gather certain technical and usage data whenever you use the App, including device, content and usage data, as well as a unique device ID. When using the App on an Apple device / IoS, we may also collect information on other applications you are using on your mobile device at the same time as using the App, unless you’ve disabled that feature.

Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time.

If you do consent to this use of your data, we will use location data sent from your Apple or Android device while you are using the App. For instance, if you are using the App as a chargee, your GPS location will be used to track your exact location in order to recommend charge points near you. Under no circumstances, except as detailed in Section 5.1.5 below, will the host’s exact address be visible through the Software Services. You may opt out of this tracking using the settings on your Apple or Android device.

By turning on location services, you consent to our and our affiliates’ and licensees’ transmission, collection, retention, maintenance, processing and use of your location data and queries in order to provide and improve location-based services.

Where logged in, you will be personally identifiable from the technical data we collect using the App, as it will be tied to your specific user account.

PERSONAL DATA WE RECEIVE FROM THIRD-PARTIES

2.10 Device Data: analytics providers and advertising networks such as Google; and search information providers such as Google.

2.11 Contact, Financial and Transaction Data: from providers of technical, payment and delivery services such as Stripe.

2.12 Social Media: publicly available information through social media sites, such as Facebook, Instagram, LinkedIn, Twitter, and Google, including where you have responded to a promotional item or offer from us through social media facilities.

2.13 Publicly Available Information: we may collect personal information about you from other publicly available sources. This can include your name, address and other publicly available information. As far as possible, we ensure that where any third-parties are involved in supplying such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the UK Companies House registry, the Irish Companies Registration Office or the relevant electoral registers.

IMPORTANT – PLEASE NOTE: Our Host Terms of Use and Chargee Terms of Use require our users to refrain from uploading or processing any sensitive data (as defined in the terms) using the Software Services.

We require all of our users to agree to adhere to these terms at all times, but do not actively monitor content uploaded or processed using the Software Services and are not responsible for enforcing those terms.

If you are reviewing this policy because you believe your or your organisation’s data has been used in violation of those terms, please contact us.

KEEPING YOUR PERSONAL DATA UP TO DATE

2.14 It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. WHAT INFORMATION IS NOT COLLECTED?

3.1 We do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers).

3.2 Nor do we collect any information about criminal convictions and offences. As noted above, the relevant terms of use applicable to both chargees and hosts include restrictions on any of our users using the Software Services to collect such data (or financial information) but as noted we do not proactively monitor this and cannot be held responsible where our users breach these restrictions.

3.3 If you’re a child under the age of 18 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not have an account on GoPlugable. GoPlugable does not knowingly collect information from or direct any of our content specifically to children under relevant ages. If we learn or have reason to suspect that you are a user who meets these criteria, we will unfortunately have to close your account. Please see our Terms of Use for information about account termination.

4. HOW IS INFORMATION USED?

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you, to

keep internal records for administration purposes related to such contracts, for the purposes

contemplated in any separate Terms of Use for our websites that you have entered into, including for

the purposes set out in the “Our Standard Business Operations” section below. This is the ground we

rely upon to process Third-Party Data our hosts and chargees may upload when using the Software

Services.

4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and

fundamental rights do not override those interests.

4.1.3 Where we need to comply with a legal or regulatory obligation.

4.2 Generally, we do not rely on consent as a legal basis for processing your personal data other than as set out below in relation to marketing and testimonials. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

4.3 Our Standard Business Operations:

4.3.1 To provide the Software Services that we contract to provide to you or others;

4.3.2 To provide you with information that you request from us;

4.3.3 To confirm your identity as a natural living person; and

4.3.4 As part of our billing, payments and recovery processes.

For example, we may use contact information to notify you of any issues which might impact the provision of the Software Services to you, confirm your bookings placed via the Software Services, respond to requests that you make, or notify you of changes to your account or the Software Services.

4.4 Marketing

We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in our Software Services.

We may use your identity, contact, technical, usage, and profile data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

If you have subscribed for these features, we may contact you for marketing purposes, both to inform you of any updates or news in relation to us or the Software Services or to otherwise inform you of information related to our business or your account with us (direct marketing relating to GoPlugable), or, if you have opted into this feature, we may also send third-party direct marketing communications to you via email, text message or other mediums.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions.

We will never sell your personal data to any third party (as noted below). 

4.5 Testimonials

We may post host and charge testimonials and comments on our websites or other platforms, which may contain personal data. We obtain each user’s consent via email prior to posting their name and testimonial.

4.6 Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.7 Legal Requirements

We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.

By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist-related activities or other illegal behaviours.

4.8 Enhancing the Software Services

We may use personal data (other than that comprised in private Customer Data) for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, and other Services and products.

4.9 Website Administration and Customisation

We may use the information we collect about you for a variety of website administration and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our websites, deliver our websites content to you, measure Website traffic, measure user interests and traffic patterns, and improve our websites and the Software Services and features offered via our websites.

4.10 Aggregated or Non-Identifying Information

Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information. GoPlugable treats IP addresses, log file information, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. GoPlugable may use non-identifying information for any purpose.

We may also combine your non-identifying information with third party data sources (including data obtained from offline sources and data obtained from our users using the Software Services) in our effort to improve the Software Services. We may share such non-identifying information with our users and service providers, affiliates, and other third parties for any purpose.

Certain jurisdictions, including the European Union and UK, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.

5. WHAT INFORMATION IS SHARED?

5.1 We do not disclose personal data outside GoPlugable, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of processors or controllers set out below for the purposes set out above or otherwise below:

5.1.1 any member of our group, which means our subsidiaries, our ultimate holding company and its

subsidiaries, as defined in section 1159 of the Companies Act 2006, or with companies under

common ownership (i.e. having common shareholders);

5.1.2 with HM Revenue & Customs, the Irish Revenue Commissioners, regulators and other authorities

acting as processors or joint controllers based in the United Kingdom and Ireland who require

reporting of processing activities in certain circumstances (excluding private Customer Data – unless

we are subject to a Compelled Disclosure);

5.1.3 with third party purchasers, if we buy, sell or merge any business or assets of our business and are

required to share data as part of the buying, selling or merger agreement or if our assets are

acquired by a third-party, and data is transferred as part of the purchased assets. If any such change

happens, we will ensure that it is under terms that preserve the confidentiality of your personal data,

and we will notify you on our website or by email before any transfer of your personal data. Any

purchaser would be bound by the terms of this policy and our Terms of Use;

5.1.4 where you are a chargee, with the relevant host (with whom you have placed a booking or of whom

you have made any enquiry) as strictly necessary to provide the Software Services, including sharing

your name, photographs you have taken in connection with your charging session (as noted above),

real-time location;

5.1.5 where you are a host as strictly necessary to provide the Software Services, including any

information forming part of any description of your EV charger and its general location on your

property (if applicable), or other information you have submitted to us as part of your public profile will

be published after you have approved it, and will be viewable via the Software Services by all users.

Your address will also be visible to chargees with whom you confirm a booking for your charger,

otherwise, the users will just see a distance radius (e.g. that an available charge point is 2 miles

away) along with an approximate pinpoint on a map;

5.1.6 with other users, generally, we reserve the right to share further information that we have collected,

including home addresses or your official name as recorded on any ID documentation, where

requested by another user with whom you have a confirmed booking in case of a dispute;

5.1.7 with professional advisers acting as processors or joint controllers including lawyers, bankers,

auditors and insurers who provide consultancy, banking, legal, insurance and accounting services,

where they have a need to know same for any of the purposes set out above;

5.1.8 with reputable and trusted third-parties where we have asked them to contact you on our behalf,

where you have given us consent, it is part of our contractual agreement, is a legal requirement or

there is clear legitimate interest between us (these services may include sending you email, calling

you by telephone, sending you information through the post etc.);

5.1.9 with specific selected third parties, determined by us, if you breach any agreement with us, so as to

enforce our rights against you, including credit-reference agencies, debt-collection firms or service

providers, solicitors or barristers and law enforcement agencies (if applicable);

5.1.10 with our third party sub-contractor providing website and App design and development services,

acting as a processor, based in India. When we transfer data to them, we will remain responsible for

it, and will ensure we have a lawful mechanism under UK GDPR and EU GDPR to permit such

transfers (namely standard contractual clauses under EU GDPR or the UK international data transfer

agreement under UK GDPR); and

5.1.11 with other service providers acting as processors based in the European Union or United Kingdom

who provide IT and system administration services, including for the performance of our contract with

you, as set out below: When we transfer your data to our service providers, we remain responsible

for it:

• with email marketing services to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails;

• with analytical service providers, such as Squarespace Analytics, Google Analytics or MixPanel, in order to analyse our website traffic or App usage to improve products and services;

• with processors offering software tools, or EU or UK based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf (our current servers are maintained by Amazon Web Services,whose privacy policies are available at https://aws.amazon.com/privacy/. By default, and unless we have agreed otherwise in writing with the location of these servers will be within the EU;

• with providers offering programmable communication tools for making and receiving phone calls, sending and receiving text messages, or sending transactional and marketing emails, and performing other communication functions (such as Twilio or SendGrid);

• with third-party identity verification service providers; and

• with providers of cloud-based customer relationship management tools, who may also facilitate customer support ticketing and communications, or interactive surveys, and host such data, such as FreshWorks.

5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy.

5.3 We do not share, sell, rent, or trade personal data with third parties for their commercial purposes.

5.4 We may also share personal data with your permission, so we can perform services you have requested.

5.5 As noted above, the Software Services may also allow you (as a data controller) to share your personal data with other users who may access that content and use it in compliance with the relevant terms of use applicable to the relevant category of user, where, for example, hosts and chargees may be able to exchange messages after the booking has been confirmed.

5.6 Whilst GoPlugable accepts no responsibility for how users may use information you choose to share, we do require users to agree that where you need to use this data, you may only use it as strictly necessary for the purposes authorised by the relevant host or charge and only in accordance with the relevant terms of use applicable to them.

6. HOW IS MY INFORMATION SECURED?

6.1 GoPlugable takes all measures reasonably necessary to protect personal data from unauthorised access, alteration, or destruction, maintain data accuracy and help ensure the appropriate use of personal data. We follow reasonable industry standards to protect the personal data we hold, both during transmission and once we receive it.

6.2 In addition, we limit access to any personal data to those employees, agents, contractors, service providers and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to duties of confidentiality.

6.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.4 No method of transmission, or method of electronic storage, is 100% secure. Although we will do our best to protect your personal data, we cannot guarantee its absolute security. Any transmission is at your own risk.

7. HOW IS INFORMATION COLLECTED AND STORED GLOBALLY?

7.1 Information that we collect will be stored and processed in the United Kingdom and European Union in accordance with this policy, save for information shared with our external website and App design and development sub-contractor, who is based in India. Where required by law to facilitate such processing, we will ensure that they sign data transfer agreements such as EU standard contractual clause agreements or the UK international data transfer agreement.

7.2 In particular:

7.2.1 we provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing, we will ensure that it has an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest);

7.2.2 we collect only the minimum amount of personal data necessary, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing;

7.2.3 we offer you simple methods of accessing, correcting, or deleting the data we have collected; and

7.2.4 we provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.

8. WHAT HAPPENS IF I HAVE A COMPLAINT?

8.1 If you have concerns about the way GoPlugable is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at info@goplugable.com with the subject line “Data Privacy”. We will do our best to respond as soon as we can, unless required to respond earlier under relevant law.

8.2 If you are a data subject based in the UK or European Union, you may have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), the Irish Data Protection Commission, the ROI supervisory authority for data protection issues (https://www.dataprotection.ie/) or other competent supervisory authority of an EU member state if the Software Services are accessed outside the UK or Ireland.

We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.

9. HOW DO YOU RESPOND TO COMPELLED DISCLOSURE REQUIREMENTS?

9.1 Plugable may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

9.2 In complying with court orders and similar legal processes, GoPlugable strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

10. HOW CAN I ACCESS MY OWN PERSONAL INFORMATION?

If you’re already a user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting us.

Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a (transferable) copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

• Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

• In relation to profiling you have the right not to be subject to solely automated decisions and where we make such automated decisions, you have a right to have a person review the decision.

• Withdraw consent at any time (or object to processing) where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. DATA RETENTION AND DELETION

Personal Data Generally

11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and

sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Personal data which GoPlugable considers to be of less relevance to the performance of a contract, such as miscellaneous correspondence or telephone records, may be deleted earlier.

11.3 We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.

11.4 By law we have to keep basic information about any of our users and service providers (including contact, identity, financial and transaction data) for six years after you cease being a user or service provider for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any products or services you or your employer or other person by whom you have been authorised to use the Software Services have purchased from us.

11.5 If you have otherwise closed your account on our App or through the Software Services, save for the anonymised data mentioned below, or the basic information mentioned above, we will endeavour to delete all personal data we no longer have grounds to process within 12 months of the date of such deletion.

11.6 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11.7 If you would like to cancel your account and initiate deletion of your personal data, you may do so by contacting us at info@goplugable.com. As above, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain security, and enforce our agreements, but barring legal requirements, the timeframe above will be observed for deletion.

12. HOW DO YOU COMMUNICATE WITH USERS?

12.1 We will use your email address to communicate with you, if you’ve given us the OK, and only for the reasons you’ve permitted. Emails by default are not disclosed with other users, even if you belong to the same organization. This will not change how we contact you, as we always utilise your primary email address.

12.2 Depending on your email settings, GoPlugable may occasionally send notification emails about new features, requests for feedback, important policy changes, or offer customer support. We also send marketing emails, including ones featuring new services and products offered by our commercial partners (as noted above), but only with your consent. There’s an unsubscribe link located at the bottom of each of the emails we send you.

12.3 Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.

13. WILL YOUR PRIVACY POLICY CHANGE?

Unless legally necessary (in which case you will be notified by email), any changes we may make to this privacy notice in the future will be posted on this page without further recourse or notice to you. If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.

We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.

Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page and, where appropriate, may be notified to you when you next log on to use the Software Services.

Otherwise, any changes shall be applicable without further notice.

This version one of this policy was last updated on [ ] 2023 and historic versions can be obtained by contacting us.

14. HOW CAN I CONTACT GOPLUGABLE?

Questions regarding our Privacy Policy or information practices should be directed to us via one of the contact methods that we have provided in this policy.

15. LEGAL

This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have non-exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy. This shall be without prejudice to your rights under relevant legislation, including where you are based in the Republic of Ireland.

SCHEDULE – GENERAL COOKIES AND OTHER TECHNOLOGIES POLICY FOR THE GOPLUGABLE WEBSITE

(EXCEPTING GOPLUGABLE APP)

1. WHAT SPECIFIC TECHNICAL DATA DO GOPLUGABLE COLLECT?

1.1. GoPlugable collects and analyses traffic by keeping track of the IP addresses of our visitors and by collecting log file information. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet service provider (ISP) or by another organisation. An IP address, by itself, cannot identify you personally (unless you are logged in whilst using our sites). However, when combined with other information, your IP address can be used to identify the computer you are using. In addition, GoPlugable may use your IP address to estimate your geographic location.

1.2. Our websites uses “cookies” and similar technologies, including HTML5 local storage on our websites and when providing the Software Services. A cookie is a file stored on your device that may be used to identify an individual as a unique user by storing certain personal preferences and user data. GoPlugable uses cookies and other technologies to identify your device, identify authorised users of the GoPlugable service, track affiliate referrals, complete online purchases through GoPlugable’s billing system, and similar Website monitoring activities.

1.3. GoPlugable may also use web beacons, small graphic images or other web programming code (also known as “1x1 GIFs” or “clear GIFs”), which may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our websites, to monitor how users navigate our websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

1.4. GoPlugable may also use embedded scripts on our websites and in connection with the provision of its Services. “Embedded scripts” are programming code designed to collect information about your interactions with a website, such as the links you click on, and may assist our customers in providing us with information used to provide the Software Services. The code is temporarily downloaded onto your device from our web server, our customer’s web server, or a third party service provider, is active only while you are connected to our websites containing the embedded script, and is deactivated or deleted thereafter.

1.5. Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on our websites, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.

1.6. Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications such as the operating system and browser you used. Similar to an IP address, a user agent string, by itself, does not identify you personally. However, when combined with other information, a user agent string might be used to identify the computer originating a message.

1.7. GoPlugable may also request access to or otherwise receive information about your device location when you access our websites. Your location data may be based on your IP address. We use location data in connection with providing the Software Services and to help improve the Software Services.

1.8. GoPlugable may assign your computer or mobile device a unique identification number (Unique ID) based on log file information when you access our websites GoPlugable may set a cookie on your device containing, amongst other things, the device’s Unique ID. GoPlugable uses information generated from the Unique ID for purposes of improving the Software Services, primarily our ability to detect fraud. GoPlugable does not share the Unique ID or any associated data with unaffiliated third parties.

2. WHAT COOKIES / TRACKING CODE ARE USED BY GOPLUGABLE?

2.1. Cookies

2.1.1. GoPlugable uses cookies to make interactions with our service easy and meaningful. We use cookies (and similar technologies, like HTML5 local storage) to keep you logged in, remember your preferences, and provide information for future development of GoPlugable.

2.1.2. A cookie is a small piece of text that our web server stores on your computer or mobile device, which your browser sends to us when you return to our site. Cookies do not necessarily identify you if you are merely visiting GoPlugable; however, a cookie may store a unique identifier for each logged in user. The cookies GoPlugable sets are essential for the operation of our websites, or are used for performance or functionality. By using our website, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept cookies, you will not be able to log in or use GoPlugable’s services.

2.2. Google Analytics

2.2.1. We use Google Analytics as a third party tracking service, but we don’t use it to track you individually or collect your personal data. We use Google Analytics to collect information about how our website performs and how our users, in general, navigate through and use GoPlugable. This helps us evaluate our user’s use of GoPlugable; compile statistical reports on activity; and improve our content and website performance.

2.2.2. Google Analytics gathers certain simple, non-personally identifying information over time, such as your IP address, browser type, internet service provider, referring and exit pages, time stamp, and similar data about your use of GoPlugable. We do not link this information to any of your personal information such as your user name.

2.2.3. GoPlugable will not, nor will we allow any third party to, use the Google Analytics tool to track our users individually; collect any personal data other than IP address; or correlate your IP address with your identity. Google provides further information about its own privacy practices and offers a browser add-on to opt out of Google Analytics tracking.

2.2.4. Certain pages on our site may set other third party cookies. For example, we may embed content, such as videos, from another site that sets a cookie. While we try to minimise these third party cookies, we can’t always control what cookies this third party content sets.

2.3. Tracking

2.3.1. “Do Not Track” is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from third party tracking services. We do not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site beyond our basic Google Analytics tracking, which you may opt out of. Because we do not share this kind of data with third party services or permit this kind of third party data collection on GoPlugable for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser’s Do Not Track setting.

2.3.2. If you are interested in turning on your browser’s privacy and Do Not Track settings, the Do Not Track website has browser-specific instructions.

2.3.3. Please see our section on email communication to learn about our use of pixel tags in marketing emails.