Wevo CCPA Privacy Notice

(Last modified: 25 September 2024)  

Wevo Energy Ltd, a wholly owned subsidiary of Solaredge Technologies Ltd (Wevo Energy Ltd, including its affiliated companies and subsidiaries shall be collectively referred to herein as “Wevo”, “Company”, “we” or “us”) is the developer, owner and operator of an electric vehicle chargers’ usage and management solution (“Solution”), used, among others, by our third-party customers (“Business Partners”). Our Solution further includes our owned and developed mobile applications to be used by our end users or our Business Partner’s end users, operated by us, or by our Business Partners and under their brand (respectively “Wevo App” and “Business Partner App” and collectively the “Apps”). 

This CCPA Privacy Notice (“CCPA Notice”) is an integral part of Wevo’s Privacy Policy, and subject to the provisions of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 effective January 1, 2023 (collectively “CCPA”). 

This CCPA Notice applies to California residents which are: 

• Individuals who access and use our website available at: https://wevo.energy (respectively “Website” and “Visitors”) or otherwise prospects and potential business partner’s representatives interacting with us through our digital assets (“Prospects”);  
• Users who have installed and are interacting with our Wevo App (“Wevo App Users”) and the services offered therein (“Services”). 
• Our Business Partner’s representatives, using and operating our Solution on their behalf (“Authorized Users”)

Each of the Visitors and Wevo App Users shall also be referred to herein as “you” or “consumer”).  

Any terms defined in the CCPA have the same meaning when used in this CCPA Notice.  Definitions used herein shall have the same meaning as defined in the Privacy Policy.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/consumer-privacy-resources.

If you are a Business Partner’s App User: 

Please note we process Personal Information only on behalf of the Business Partner, as its “service provider” and accordingly, the Business Partner, as the “business” determines and responsible for the processing of your Personal Information and the Business Partner’s own privacy policies and privacy practices will govern the collection and use of your Personal Information. This CCPA Notice governs solely Wevo’s data processing practices as the “business” (i.e., when you are our Website Visitor, Prospect, Business Partner or Wevo App User). However, given the above and to provide transparency to any end users interacting with our Apps, our Privacy Policy further provides information regarding the Personal Information that might be collected with regards to any such end users use of the Apps, however, solely directly related to the App’s functionalities. You should further review the Business Partner’s policies as they independently apply to its data collection and processing practices, as well as further contact the Business Partner, on behalf of which you use or interact with the Services, in connection with a request to exercise your rights related to your Personal Information.

PART II: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

• CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below. Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below. 

Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

The following categories of Personal Information was collected by Wevo within the last twelve (12) months:

• CATEGORIES OF SOURCES OF PERSONAL INFORMATION 

• Directly and indirectly from activity on our Website and with our Wevo App: For example, directly from you when you access our Website or login to the App, or indirectly, we collect your usage data automatically from measurement tools. 
• Directly from you: For example, when you fill out our forms, contact us, account registration, etc.
• From third-parties: For example, from Business Partners that wish to enable you to use the Wevo App, data analytics providers, etc. 

• USE OF PERSONAL INFORMATION

We may use the Personal Information collected as identified above, for the following purposes: 

• To fulfill or meet the reason you provided the Personal Information (create and designate your account; support; respond to a query, etc.); 
• Provide you our Services;
• Monitor and improve our Services; 
• Marketing purposes;
• Analyzing the Use of our Services and Website; 
• Comply with our legal obligations or respond to law enforcement; 
• As otherwise as detailed in our Privacy Policy (see the “Data We Collect and Purpose of Collection and Use” paragraph).

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

• DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

We may disclose your Personal Information to a contractor or service provider for a “business purpose”. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from “selling” or “sharing” your Personal Information.  In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose: 

Sharing information with environmental incentive plans owners and operators – in addition to the above, we may share, directly or on behalf of our Business Partners, charging usage related information with third parties’ governmental entities (such as energy departments and authorities, incentive and environmental plans operators and aggregators, etc.) for the purpose of participating in and complying with certain environmental incentive plans or similar funding projects. Note that this information will NOT include your identifying information such as name or contact details, rather solely information related to the charger you are using, its location and usage information (e.g., charging – plug in and plug out time, date, duration, energy consumption, rates, etc.);  

• SALE OR SHARE OF PERSONAL INFORMATION 

In the preceding twelve (12) months, we did not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.  

For marketing and analytic purposes, when we promote our Services, we use third-party tools that are able to market our Services online, measure these marketing efforts, identify individuals that are interested in our Services, etc. This is done by placing cookies, pixel or other tracking technology on our website and sharing with these vendors the online identifiers and online behavior information. The CCPA defines these actions as “sharing” or “selling”.    

The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration.” In other words, we may share your Personal Information with a third party to help promote our Services and understand your use of our Services.   

In the preceding twelve (12) months, we have “sold” or “shared” the following categories of Personal Information: 

• CHILDREN UNDER THE AGE OF 16

Our Services are not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 16. please contact us at: privacy@wevo.energy if you have reason to believe that a child has shared any information with us. 

• DATA RETENTION

Subject to applicable laws, we retain the Personal Information we  collect for as long as needed for the purpose its was collected, as set forth under this CCPA Notice and our Privacy Policy, where we are permitted or required under applicable laws to retain Personal Information, or, until you exercise your applicable rights (such as for data deletion, as detailed in paragraph H below –  “Your Rights Under the CCPA”). 

We may retain Personal Information ta for additional periods, in the following circumstances: 

• Where we are required in accordance with our legal, regulatory, tax, or accounting requirements; 
• To maintain accurate records of your or the applicable Business Partner’s engagement with us in the event of any complaints; or 
• If we reasonably believe there is a prospect of litigation relating to your Personal Information, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that where we act as a “service provider” on behalf of a Business Partner, the retention periods are under the sole discretion of the Business Partner, as the “business”.  

Except as required by applicable law, we will not be obligated to retain your Personal Information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

PART III: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM

• YOUR RIGHTS UNDER THE CCPA 

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein:

• • The right to know – you have the right to know what Personal Information we collected about you as the “business”, including the categories of Personal Information and sources from which it is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.
  • Deletion rights – you have the right to request us to delete Personal Information that we collected from you, subject to certain exceptions.
  • Correct inaccurate Personal Information – you have the right to request us to correct inaccurate Personal Information that we maintain about you. 
  • Opt-out of “sharing” as part of our cross-context behavioral advertising or “selling” Personal Information – you have the right to opt-out of the “sharing” of your Personal Information for cross-context behavioral advertising or “selling” Personal Information. As explained above, when we use cookies and similar technologies for marketing or analytics purpose, this practice is considered as “sharing” or “selling” Personal Information. 
  • Opt-Out of the use of automated decision making – you have the right, in certain circumstances, to opt-out of the use of automated decision making in relation to your Personal Information. Note that, we do not use your Personal Information for automated decision making. 

• Data portability – you have the right to request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.

• Non-discrimination – you have the right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/consumer-privacy-resources

• HOW CAN YOU EXERCISE THE RIGHTS?

To exercise your rights, please contact us at: privacy@wevo.energy, detail the right you wish to exercise, and provide us with sufficient information to identify you and locate your Personal Information. 

We will respond and fulfill your request within the timeframe required under applicable laws. 

Certain rights can be easily executed independently by you without the need to contact us, and for example: 

• If you are a Wevo App User, you can exercise your right to request account and data deletion through the App menu; 
• You can opt-out from receiving our marketing emails by clicking “unsubscribe” link; 
• You can use the cookies preference management tool on our Website to change your preferences and opt-out of cookies.

• AUTHORIZED AGENTS 

“Authorized Agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

• When a consumer uses an authorized agent to submit a request to know or a request to delete, we may require that the consumer to: provide the authorized agent signed permission to do so or power of attorney; verify their identity directly with us; and directly confirm with us that they provided the authorized agent permission to submit the request.
• We may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

• NOTICE OF FINANCIAL INCENTIVE

We do not offer financial incentives to consumers for providing Personal Information.

PART IV: OTHER CALIFORNIA OBLIGATIONS 

Direct Marketing Requests: California Civil Code Section 1798.83 permits California residents to request certain information regarding the disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an email with your request and applicable details to: privacy@wevo.energy

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn Do Not Track setting on, visit: www.donottrack.us. 

PART V: HOW TO CONTACT US & UPDATES TO THIS CCPA NOTICE:

CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:

Wevo Energy Ltd.
Email: privacy@wevo.energy.

This notice was last updated on the date indicated under the header. As required under the CCPA, we will, if needed, update this CCPA Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this CCPA Notice.

EFFECTIVE AS OF: September 2024