Wevo Energy Privacy Policy

(Last modified: 25 September 2024)

INTRODUCTION & SCOPE

This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage of Personal Data (as defined below) made by 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”).

Wevo 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 Privacy Policy constitutes an integral part of the Website Terms of Use and the Wevo App End User License Agreement (collectively the “Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms. This Privacy Policy governs our collection and processing of Personal Data practices in connection with:

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”.

If you are an end user of our Business Partner App (“Business Partner App User”):

Please note we process Personal Data only on behalf of the Business Partner, as its service provider and data processor and accordingly, the Business Partner determines and responsible for the processing of your Personal Data and the Business Partner’s own privacy policies and privacy practices will govern the processing of your Personal Data. This Privacy Policy governs solely our data processing practices. However, given the above and to provide transparency to any end users interacting with our Apps, this Privacy Policy further provides information regarding the Personal Data 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 Data.

US residents:

California residents – for additional privacy information as required under the California Consumer Privacy Act (“CCPA”) – please review our CCPA Notice.

For additional privacy information for certain United States residents – please review the “Additional Notice for US Residents” paragraph of this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at: privacy@wevo.energy.

UPDATES AND AMENDMENTS TO THIS PRIVACY POLICY

We reserve the right to update or amend the Privacy Policy, from time to time, as we find needed and applicable and at our sole discretion. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. In the event required under applicable laws, or if we implement any changes that substantially change our privacy practices, we will provide notification of such updates or changes, using reasonable means. Any amendments to our privacy practices described under this Privacy Policy will become effective when we publish the modified Privacy Policy, unless otherwise required under applicable laws. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

Wevo Energy Ltd. is the data controller of the Personal Data collected with regards to Visitors, Prospects and Wevo App Users.

Please note however that the Business Partner that provides you with all services related to your use of the Wevo App is an independent controller or your Personal Data collected both through the Wevo App and the Business Partner use of our Solution. We do not control, monitor or bear responsibility with regard to the Business Partner privacy practices which are governed by its own polices.

EU Data Protection Representative:

EU residents may send their inquiries regarding our privacy practices under the GDPR or request to exercise their rights under the GDPR to our EU Data Protection Representative as follow:

By Email: dpr@wevo.energy

UK Data Protection Representative:

UK residents may send their inquiries regarding our privacy practices under the GDPR or request to exercise their rights under the GDPR to our UK Data Protection Representative as follow:

Wevo Energy UK Ltd.

By Email: privacy@wevo.energy

By Mail: 71-75 Shelton St, London, WC2H 9JQ, United Kingdom

Attn: Wevo Energy UK Data Protection Representative

Contact Information:

Questions, comments, requests, and complaints regarding this Privacy Policy and our privacy practices are welcome and should be addressed to us by using the contact details below. All requests will be dealt with promptly and efficiently.

Wevo Energy Ltd: privacy@wevo.energy

DATA WE COLLECT AND PURPOSE OF COLLECTION AND USE

You will find below information regarding the types of data we collect, the purposes for which we process your Personal Data as well as our lawful basis for processing (where the GDPR applies to your Personal Data).

We may collect aggregated, non-personal, and non-identifiable information which may be made available or gathered via your use of the Website or Apps (“Non-Personal Data“). This may include technical information regarding your device or browser, type of operating system, and aggregated usage information. We are not aware of the identity of the individual from which the Non-Personal Data is collected. Also, we may process and anonymize or aggregate Personal Data in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified individual or device. Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes.

When you interact or use our Website, Wevo App and Services, we collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, names, emails, etc., subject to applicable law.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data. We may use and disclose Non-Personal Data related to our business and the Services for analytics, research, development, and other purposes. Some of this information may be considered “de-identified” under U.S. privacy laws (i.e., data that is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on data that has been “de-identified” as defined by U.S. privacy laws, we will: (i) take reasonable measures to ensure that the de-identified information cannot be associated with an individual, household, or device; (ii) commit to maintain and use the information in de-identified form and not attempt to re-identify the information; and (iii) contractually obligate any further recipient not to re-identify the de-identified data.

You are not obliged by law to provide us with any of your Personal Data. However, if you refrain from doing so, we may not be able to provide any or all of our Services.

We have included in the table below information about the Personal Data we collect, how and for which purposes we process and use your Personal Data and the lawful basis for which we do so (subject to the GDPR, if applicable).

Type of Data

Purpose of Processing

Lawful Basis (where the GDPR applies)

VISITORS AND PROSPECTS

Contact Communications

Contact details:

If you voluntarily contact us in any manner, whether for support, to submit a request, or for other inquiries, whether by sending us an email or through other means of communications, e.g., any online form, or if we otherwise communicate with you (e.g., when we reach out to Prospects) we will process your contact information which may include name, email address, phone number, and additional information that might be applicable such as your country.

As for Prospects in addition to the above, we may further process the Prospect’s organization and position, managed site and building and social media profile URL (e.g. LinkedIn).

Contact communications & Engagement Data:

We will process and store our communications with you, including email correspondence and, where applicable call and meeting recording.

We process such Contact Communications data for the purpose of contacting you, responding your inquiries or establishing a potential business relationship and provide you with the support or information you have requested.

The correspondence with you, or, where applicable, recording of our calls, may be processed and stored by us for record keeping, to improve our service, as well as in the event we reasonably determine it is needed for future assistance or to handle any dispute you might have with.

We may further use your email address to send you marketing material related to our Services in which you have shown your interest, including promotions, such as new features, additional offerings, special opportunities etc. (“Direct Marketing”).

When you voluntarily contact us, we process such Contact Communications data based on your consent.

In other cases, including for Direct Marketing, Contact Communications are processed and stored subject to our legitimate interests.

Any recording of calls or meetings shall be made subject to obtaining your consent.

Newsletter & Events Registration

When you sign up to our mailing list (newsletter or other marketing materials), webinars and events, you will be requested to provide your contact details, such as name, email address, and may be requested to provide additional information such as your organization name (i.e., on behalf of which you contact us) and country.

We process such data to add you to our mailing list and send you the content you have signed up to receive, such as updates, offers, invitations, etc. or, as applicable, to register you as a guest of our events and enable your participation. We may further process your data for Direct Marketing.

We process the data you voluntarily provide upon registration subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly.

Direct Marketing is based on our legitimate interest, you may opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.

If you unsubscribe or opt- out, we will further retain your email address, however solely as part of our internal suppression file to ensure we comply with such preference and choice, based on our legitimate interest.

Online Identifiers & Usage Data

When you access our Website or interact with any of our digital assets, we may collect certain online identifiers, including your IP address, cookie ID, similar unique online identifiers generated, tags, etc. (“Online Identifiers”).

In addition, when you access our Website or interact with any of our digital assets or communications, we may further collect information related to your interaction with such assets and communications such as actions made on the Website, pages viewed, access time and date, approximate geographical location (country), duration, the URL or advertising campaign from which you have reached our Website, etc.

We process Online Identifiers and Usage Data through our or third-party cookies and tracking technologies (see the Cookies and Tracking Technologies Section below).

This data is processed for the following purposes:

For operation, functionality, security and fraud prevention purposes, debugging purposes and to resolve technical problems.

For analytic, marketing and advertising purposes. For example, we process this data to understand how Visitors use our Website, as well as to measure effectiveness of our content and advertising campaigns.

Note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address.

Processing Online Identifiers and Usage Data for operation and security based on our legitimate interest.

Processing Online Identifiers and Usage Data related to our Website for analytic and advertising purposes is based on your consent which we will obtain through our cookie notice and consent management tool available on our Website. You may withdraw consent or change your preferences at any time by using the cookie settings tool available on our Website.

APP USERS

Signing Up for An Account & Use of Services

Registration & Account Information

If you are or wish to become a user of the Services, depending on your interaction with us, upon or prior to installing the App, you will be required to provide certain information which may include:

Identification and contact data: Full name; Email address; phone number; ID number.
Your address and parking space information.
Payment information – please note that we do not store, or have access to your full payment method details, and such will be stored by our third-party payment processor and subject further to their policies.

Charging Information

When you use our App the charge your EV Vehicle, we collect certain information regarding such usage including charger’s location and usage time, date and duration (i.e., plug in and plug out).

Transactions

We process the commercial transaction data related to your usage of the Services, including charges, statements, invoices, billing information and transactions made.

We will use this data to designate your App account and allow you to use the Services and the App providing the Services, supporting its operation, including exercising payments in consideration of your EV charging consumption.

Also, your email address will be used to send you needed operational information related to our App and Services (e.g., password set-up, payment statements and billing information, notify you regarding any updates to our App, or Services etc.).

We collect and analyze your charging information to calculate the payments of charging so we can bill you for the Service.

We may further use your charging information, in an aggregated manner, to analyze usage trends, and to further improve and develop our Services.

In addition, in some territories, we (directly or on behalf of our Business Partners), may participate in certain governmental related environmental plans, and in such cases we may share the charging information only (i.e. we will not share your identification information) with third party operators or agents of such plans – please see the ”Sharing Data With Third Parties” paragraph below.

If you are a Business Partner’s App User or using the Wevo App on behalf of our Business Partner, your data will be shared with the Business Partner – please see the ”Sharing Data With Third Parties” paragraph below.

If you are a Wevo App User, our lawful basis for processing this information is the performance of a contract (i.e., providing you the Services).We will further retain your information, under our legitimate interest for record keeping purposes and to analyze, improve and develop our App and Services.

Also, transactional data (such as invoices and payment records) shall be retained to comply with our legal obligations.

Customer Support & Troubleshooting

If you voluntarily contact us in any manner, whether for support, report errors, to submit a request, or for other inquiries, by any means of communication we make available (email, phone, chat, etc.) you may be asked or voluntarily to provide us with certain information such as:

Contact information: your full name, email address, phone number and location (country or charger location, as needed for support);
The content of your inquiry, which may include additional information, as you choose to provide.

In the event applicable to your support request or inquiry, we will further process certain online identifiers (such as the unique ID we assign to each App User) and certain usage data – as further detailed in this table below.

We will use this data and our contact communications and correspondence to respond to your inquiries and provide you with the support or information you have requested, to analyze the error and for bug management and troubleshooting purposes.

We may further use the data we gather relate to errors and bugs to improve and develop our Services.

If you are a Wevo App User, our lawful basis for processing this information is the performance of a contract (i.e., providing you the customer support as part of our Services).

We will further retain your information as part of our business records or to improve our Services under our legitimate interest.

Online Identifiers, Device Data & Usage Data

Online Identifiers

When you install our App or interact with our Services, we collect certain online identifiers, including your IP address, and certain mobile identifiers (e.g. App installation ID).

Device Data & Usage Data

When you install our App or interact with our Services, we also collect:

Technical data transmitted from your device, such as type of device and operating system, the language used, approximate geographical location (country). Subject to your consent, you may enable certain app permissions, including GPS location.
Usage data related to your use of the App, including actions made, features used, access time and date, use duration, any similar App engagement data.

We use this data for operating, providing, maintaining, and managing, the App, Services and to further protect on secure or App and Services, identify and fix errors and bugs.

We will further use this data for auditing and tracking usage statistics and traffic

flow, to improve and customize our App and Services, enhance your experience and for advertising purposes.

GPS location data is processed solely to enable you certain features of our Services such chargers location next to you or providing directions (based on third party providers such as Google maps, etc.). We do not store such location data.

We process this data based on our legitimate interests.

For any usage of App permission (including GPS location), or use of data for personalized advertising purposes, or where otherwise required under applicable laws, we will obtain your consent. You may withdraw your consent at any time through the App settings or as otherwise detailed in this Privacy Policy.

AUTHORIZED USERS

Business Partner Account:

To access the Business Partners’ account and use our Solution, Business Partners will provide us with their Authorized Users information such name and email address.

Usage Data:
When you access and use the Solution, information regarding such use and access to our platform is automatically generated and collected, which may include the click stream within the platform, access logs, actions made (including time and date), and IP address, crash data and analytics, etc.

We use this data to enable Authorized Users to access the Solution and its platforms and use it on behalf of the Business Partner, to authenticate and validate access, enable log-in, as well as to send needed operational information related to our engagement.

In addition, we may use this information for Direct Marketing purposes (meaning, as our customer, we may send you marketing related communications regarding our Solution).

Usage data and online identifiers are used to help us understand how you are using our Solution, and how to better provide and improve our services and for security, operation and debugging purposes.

We process your information to enable access permissions for the purpose of performing our contract with the Business Partner.

Processing of information for Direct Marketing purposes is made subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” option within the body of the message.

Usage data and online identifiers used for operation, security and analytic purposes, are processed based on our legitimate interest.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ, and we are only responsible for the Personal Data we collect and process as the controller of the Personal Data. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the “Data Transfer” Section below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce our agreements, terms and policies, as well as to protect the security or integrity of our databases, Solution, App and Services, and to take precautions or defend against legal liability and claims. Such processing is based on our legitimate interests.

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the us, we may collect information as follows:

Provided by you voluntarily – we will collect information if you choose to provide us with the information, such as through contact us communications, etc. all as detailed in this Privacy Policy.
Provided by our Business Partner – our Business Partners using our Wevo App as part of the Solution we provide us certain information such as your name, email address and phone number, to create your account and send you the needed link to access and download our Wevo App.
Automatically – we may use cookies and certain tracking technologies such as pixels, tags, SDKs, etc. (as elaborated in the section below) to gather some information automatically such as online identifiers and usage data.

COOKIES AND TRACKING TECHNOLOGIES

Similar to many other online services, we use cookies and similar technologies such as pixels, SDKs, etc., (ours or of our third party service providers and partners) in our Website and Apps for various purposes, including to operate, manage, maintain and secure our Websites, Apps and Services, to improve your experience and to advertise our Services.

The categories and type of cookies we use on our website are as detailed under our Cookies List available at: https://wevo.energy/wevos-cookie-list/ .

We further use the third-party technologies known as SDKs in our Apps:

Coralogix – used for security any analytics.

Sentry.io – used for security and debugging.

Also note, that certain their party cookies used for marketing purposes (e.g., Google) may independently, as a data controller, collect and use certain Personal Data through our use of cookies, and combine it with other information obtained from your online activities on other digital assets, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use data under their own policies and are responsible for their practices.

Managing Cookies and Opting Out:

Other than cookies classified as essential or strictly necessary for functionality purposes, you can always configure your cookies preferences and opt-out from use of certain or all cookies at any time, using the cookies preference management tool on our Website or through your browser’s settings. In some cases, certain services, features and functionality may not be available to you or work properly if you disable cookies.

SHARING DATA WITH THIRD PARTIES

We share your Personal Data with third parties, including our affiliated companies and subsidiaries, Business Partners and service providers that help us provide our Services. The categories of such third-party recipients are as follows:

Sharing of Data with a Business Partner- as explained above, if you are a user of our Business Partners, we will share your Personal Data with the Business Partner providing you services. If you use our Wevo App for the provisions of obtaining the Business Partner’s services, the Business Partner and Wevo each act as an independent controller of your Personal Data collected through the App. If you use our Business Partner App, the Business Partner is the data controller of your Personal Data, and we collect and process such Personal Data only as a data controller and services providers on its behalf. In both cases – the use of your Personal Data by the Business Partner is subject to its practices and policies, which may differ from ours, and we do not monitor nor shall we bear any responsibility for the Business Partner’s practices, all are subject to the direct engagement between you and the Business Partner;
Service Providers- we share your Personal Data with third parties that perform services on our behalf (e.g. storage and computing infrastructure, customer service, tracking, servers, service functionality, marketing, and support, etc.). These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services. Note however that payment processors we use will process Personal Data subject to their practices aligned with applicable financial regulations.
Environmental Incentive Plans Owners and Operators – 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.);
Affiliated Companies & Corporate Transaction – we may share Personal Data within our company group in accordance with the terms of this Privacy Policy for the purpose of providing the Services. We may further share your Personal Data in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation, or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
Legal Requirement, Enforcement and Defense – we will share your Personal Data in situations we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.). We may further share Personal Data, solely to the extent needed to enforce our policies and agreements; investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues; defend from legal claims you may have and establish or exercise our rights; or protect your or third parties’ vital interests, rights and safety.

DATA RETENTION

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

We may retain Personal Data 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 Data.

Please note that where we act as a Processor on behalf of a Business Partner, the retention periods are under the sole discretion of the Business Partner, as the data controller.

SECURITY

We have implemented physical, technical, and administrative security measures for the Apps and Services in accordance with applicable laws, to protect Personal Data from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost

Note that, the transmission of information via the Internet and online data processing cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee, and we make no warranty that, we will always be able to prevent security incidents and will not be held responsible for unauthorized access or use beyond our reasonable control

CROSS BORDER DATA TRANSFER

Due to our global business operation, your Personal Data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country. However, in all cases, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer, in accordance with relevant and applicable law.

Specifically, if and where Personal Data collected within the UK or EU are transferred outside these territories to countries which were not granted with an adequacy, such transfer is subject to and made pursuant with an approved transfer mechanism such as the Standard Contractual Clauses or data privacy framework.

YOUR RIGHTS UNDER PRIVACY PROTECTION LAWS

Under applicable privacy protection laws, individuals have certain rights and controls regarding their Personal Data we process and maintain. Depending on your relationship with us, your jurisdiction and the privacy laws that apply to the processing of your Personal Data, the principal rights might include:

Right to be informed – you have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy. If you have any additional questions, please contact us at: privacy@wevo.energy
Right to access/inspect your Personal Data – you have the right to ask us to confirm whether or not we collect and use your Personal Data, and if so, you have the right to know which Personal Data we specifically hold about you ask for a copy of your Personal Data or access it;
Right to correct/rectify your Personal Data – you have the right to ask us to correct or update any of your Personal Data that is incorrect, after verifying the accuracy of the data first, taking into account the nature of the processing and the purposes (or request deletion for inaccurate Personal Data).
Right to erase your Personal Data (the right “to be forgotten”) – you have the right to request the erasure of certain Personal Data, if specific conditions are satisfied, for example, if you think we no longer need to use it for the purpose we collected it from you, in case the process of your Personal Data was based on your consent, where we have used it unlawfully, or where we are subject to a legal obligation to erase your Personal Data. any request for such erasure will be subject to our rights and obligations under applicable law (e.g., legitimate interests such as record keeping with regards to our engagements, completing transactions, providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest, etc.). You are not required to create an account with us to submit a deletion request;
Right to restrict our processing of your Personal Data – you have the right to ask us to restrict or limit the purpose for which we process your Personal Data in certain circumstances and where certain conditions are satisfied (such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data; where the processing is unlawful and you oppose the erasure of the Personal Data; where we no longer need the Personal Data for the purposes of the processing).;
Right to object to how we use your Personal Data – you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;
Right to withdraw consent/opt-out – when the lawful basis for processing your Personal Data is your consent, you may withdraw such consent at any time. You have the right to opt-out from Direct Marketing, if applicable, by unsubscribing through the email received. We do not profile you in a manner that has a significant effect on you or other individuals, therefore there isn’t an opt-out option.
Data portability right – you have the right to ask us to provide a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another entity without hindrance. We will select the format in which we provide your copy;
Right to appeal or lodge a complaint – If we decline to take action on your request, we will inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the GDPR you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.

Note that, not all those rights apply in every jurisdiction.

For California Residents, please further review our CCPA Notice, and for US residents, please further see the “Additional Notice for US Residents” paragraph below – to learn more about your rights under applicable US law.

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 data.

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.

CHILDREN

Our App, Services and Website are not directed, nor is it intended for use by children or minors and we do not knowingly process Personal Data of such individuals. Please contact us if you have reason to believe that a child has shared any Personal Data with us.

LINKS TO OTHER SITES

Our Website, Apps and Services may include links to third-party websites, plug-ins, and applications. 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-parties’ practices and are not responsible for their privacy statements.

ADDITIONAL NOTICE FOR US RESIDENTS

Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws and be entitled to additional disclosures.

“Personal Data” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)

“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

Categories of Personal Data & Categories of third parties with whom Personal Data is shared:

Under the paragraph “Data We Collect and Purpose of Collection and Use” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used.

Additionally, under the paragraph “Sharing Data with Third Parties” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent.

“Sale” of Personal Data:

Under US privacy laws, in principal, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment however, subject to the definition of the term “Sale” under US privacy laws, we may “sell” the following categories of Personal Data when we use cookies or other third-party advertising services:

Identifiers – online identifiers such as IP and Cookie ID;

Internet and electronic network activity information – such as your engagement with our Website and ads.

Geolocation data – derived from IP (country level).

Consumer Rights:

Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

Access – the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.
Delete – the right to delete their Personal Data provided to or obtained by us.
Correct – the right to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.
Opt-Out – to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for purposes of making decisions that produce legal or similarly significant effects.

The paragraph “Your Rights Under Privacy Protection Laws” provides additional information regarding your principal rights.

Exercising Your Privacy Rights:

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: privacy@wevo.energy.

When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

To exercise your right to opt-out of the “sale”, you may use the cookies preference management tool on our Website to change your preferences and opt-out of cookies.

Authorized agents may initiate a request on behalf of another individual by contacting us at nfo@wevo.energy; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

If we decline to take action on your request, we shall so inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction (including – Colorado AG at https://coag.gov/file-complaint/; Connecticut Attorney General at: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318; Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform).

EFFECTIVE AS OF: September 2024