Evunity ApS 

Arkan Plaza, Plot 31 El Sheikh Zayed Building 4, Giza Governorate 12588, Egypt Email: info@evunity.co 

Company registration number: 11070-4000-33399 

Overview 

1. Introduction 

At Evunity ApS, Arkan Plaza, Plot 31 El Sheikh Zayed Building 4, Giza Governorate 12588, Egypt,  registration-no. 11070-4000-33399 ("Evunity", "we", "us", "our"), we understand the importance of  treating the personal data of our customers, vendors, business partners, visitors to our website  and other persons we interact with in a confidential and private manner. Transparency is a  fundamental value at Evunity, and Evunity is committed to following the requirements and  obligations in relation to data privacy in accordance with applicable law, including the Egyptian  Personal Data Protection Law No. 151 of 2020" (PDPL) and alongside GDPR and the EU General  Data Protection Regulation ("GDPR"). Therefore, we have secure and adequate data processing  procedures in place. 

Evunity is the data controller for the processing of your personal data. This privacy policy will  explain how Evunity uses the personal data we collect from you when you use our website, user  portals and mobile applications. 

When we talk about our "Website" we mean www.evunity.co and the other sites and applications  we own and operate. When we refer to "user portals" and "mobile applications", we mean our  product "Evunity". 

If you have any question to this Privacy Policy or you wish to exercise your data subject rights  pursuant to Chapter III of the GDPR and according to section 7 of this Privacy Policy, please  contact Evunity on info@evunity.co. 

2. Categories of personal data, purpose, and legal basis 

2.1 Visitors on our Website, user portals, and/or mobile applications, and newsletter recipients 

When you visit our Website, user portals, and/or mobile applications Evunity will process personal  data about you, for instance, cookies, browser type and version, IP-address, and length of visit. The  purpose of using cookies is, i.a., to improve your user experience on our Website, user portals,  and/or mobile applications to provide functionality, to generate statistics, to target the marketing  of our products to your needs, and to remember your preferences. 

The legitimate interests pursued are to provide you with products and services that work optimally,  a good website experience and marketing activities. The legal basis for the processing of your  personal data is Art. 6(1)(f) of the PDPL and the GDPR. In certain cases, the legal basis for the  processing of your personal data in this regard is your consent, which you will be asked to give  when you visit the Website, user portals, and/or mobile applications, cf. Art. 6(1)(a) of the PDPL and 

the GDPR. You may find more information about our use of cookies in the cookie policy when  entering our Website. 

If you wish to receive a newsletter or book a demo, we also process the following information about  you: name and surname, subject(s) of interest and your email address in order to tailor the content  of and to send our newsletters to you. The legal basis for the processing of your personal data in  this respect is our legitimate interests in branding our products and business and the relevant  marketing material that you have requested, cf. Art. 6(1)(f) of the PDPL and the GDPR. You may at  any time with future effect unsubscribe to receiving our newsletter. To declare that you wish to  unsubscribe, you may use the respective link included in all newsletters or send an email to  info@evunity.co. 

2.2 Customers 

When you register your profile, Evunity will process personal data about you, including your name,  email address, telephone number, your postal address, bank and payment information, and  information on the services purchased. The purpose of the processing of your personal data is to  supply you with our services. 

When you use our services, Evunity will further process information related to date and time,  frequency, location, and pattern of EV charging. Information related to purchases include name,  contact details, address, cost, and transaction details. We use Stripe as a third party credit card  payment processing company to collect payment information. If you submit payment information,  we will share with Stripe information such as your debit/credit card number, billing address, phone  number, and installed application information in order to process payments. In such  circumstances, the third-party provider, and not Evunity, stores your payment information on our  behalf acting as a data processor, and in order to process payments to your Wallet inside of the  application, they process information about your phone number and installed application  information. 

The legal basis for the processing of your personal data in that regard is Art. 6(1)(b) of the GDPR.  This is either because the processing is necessary for the performance of a contract to which you  are a party or because it is necessary in order to take steps at the request of you prior to entering  into a contract. 

2.3 Contact persons at a vendor or another business partner 

As a contact person at a vendor or another business partner, Evunity processes your personal data  when you communicate with Evunity, e.g., via emails in connection with Evunity's existing  contractual relation with the company you are employed with or in connection with the conclusion  or termination of a contract. Evunity processes ordinary personal data about you, including your  name, email address, telephone number, position, etc. 

The legal basis for such processing of your personal data is that the processing is necessary for the  purposes of legitimate interests pursued by Evunity. Evunity's legitimate interests are fulfilment of  our contractual obligations, maintaining and enhancing business relationships, invoicing for the  services your company provides to Evunity and/or vice versa, communicating with you if you have  any questions related to our services or vice versa, and for documentation purposes in the event 

you agree on matters relating to our services in writing via email. The legal basis for the processing  of your personal data is Art. 6(1)(f) of the GDPR and PDPL. 

In some cases, processing of personal data is necessary in order to comply with a legal obligation  to which Evunity is subject, for instance in relation to the obligation on the preservation of  accounting records pursuant to the Egypt Bookkeeping Act. In such case, the legal basis for the  processing is Art. 6(1)(c) of the GDPR and PDPL. 

2.4 Inquiries via chat function in our user portals and mobile applications 

If you submit an inquiry relating to Evunity's services via Evunity's chat function, Evunity will  process personal data about you e.g., your IP-address, geographic location, and the personal data  you include in your inquiry, e.g., name, email address and telephone number. Evunity will not  process special categories of personal data (sensitive personal data) about you, unless you have  provided us with such information, e.g., through the chat function. Evunity kindly encourages you  not to send such sensitive personal data. 

The legitimate interests pursued are to provide customer support by answering the inquiries and  business development. The legal basis for the processing of your personal data is Art. 6(1)(f) of the  GDPR. 

3. Recipients of your personal data 

Where relevant, Evunity may disclose or transfer your personal data to affiliates of Evunity,  business partners or other collaborators for business purposes. Such third parties also include  social media providers, as described in section 6 below. 

In certain specific cases, e.g., in connection with disputes, including when the disclosure of your  personal data is necessary for the establishment, exercise or defence of Evunity's legal claims,  Evunity may disclose your personal data to its advisers or other relevant third parties provided it is  deemed necessary and lawful. 

Evunity uses third-party service providers, such as managed hosting providers, credit card  processors, and technology partners to provide the software, networking, marketing, logistics,  infrastructure, and other services required to operate, develop, deliver, and maintain our product  and services, and fulfil our other purposes as defined in this Privacy Policy. When a third-party  processes personal data on our behalf, the processing is in accordance with documented  instructions given by Evunity and further terms and conditions stated in a data processor  agreement entered with Evunity. These data processors are not permitted to process your personal  data for their own purposes. Evunity ensures that the processing is conducted safely and in  accordance with all applicable privacy laws, with includes but is not limited to the GDPR and PDPL. 

4. Transfer of your personal data to a third country (outside of eu/eea) 

In certain cases, your personal data may be transferred to countries outside of the EU/EEA and  Egypt. Evunity ensures that such transfers are conducted in compliance with applicable data  protection laws, including GDPR and PDPL. This includes ensuring that any recipient of personal  data outside the EU/EEA and Egypt provides an adequate level of protection, through mechanisms 

such as the EU Standard Contractual Clauses (SCCs) or equivalent safeguards required by PDPL. Please contact info@evunity.co. 

5. Storage of your personal data 

Evunity will only store your personal data as long as it is deemed necessary to fulfil the purposes for  the processing of your personal data. Evunity maintains industry standard security safeguards to  protect your data. We encrypt data in transit and at rest, where appropriate, to ensure that your  information is kept private. 

Evunity securely stores your data on our secure (password- and firewall-protected) servers. All  payment information is fully encrypted and handled only by PCI certified organizations. You  acknowledge that the transmission of information over the internet is inherently insecure, and  Evunity cannot guarantee the security of data sent over the internet. Emails sent via the internet  might not be encrypted, so we advise you not to include any confidential or sensitive information in  your emails to us. 

Access controls are in place to limit access to your information to those who need it to perform  their jobs. For example, information about you may be provided to our customer support team to  help you with your requests. 

5.1 Visitors on our Website, user portals, and/or mobile applications, and newsletters recipients 

Personal data related to your newsletter account is stored until you withdraw your consent and no  longer wish to receive newsletters from us. 

Personal data collected via cookies through use of our Website, user portals, and/or mobile  applications are stored for different periods depending on the type and purpose of the cookie in  question. 

Personal data collected in relation to the use of social media will be erased when the content is  deleted or when you withdraw your response to our content (likes, sharing, etc.). See more in  section 6 below. 

5.2 Customers 

Personal data about customers are generally deleted when they are no longer necessary for the  purpose of collection. Personal data is deleted 3 years after termination of the contractual  relationship between Evunity and the customer, if it is assessed that continued storage is not  necessary for documentation purposes. If storage is not necessary for documentation purposes,  the personal data will be deleted upon termination of the contractual relationship. 

5.3 Contact person at a vendor or another business partner 

If you are a contact person at a vendor or another business partner, Evunity will store personal data  about you as long as Evunity communicates with you because you are Evunity's point of contact, 3  years after termination of the contractual relationship, or until it is no longer necessary for the  establishment, exercise, or defence of a legal claim. 

5.4 Inquiries via chat function in our user portals and mobile applications

The inquiries from potential customers will be deleted 3 years after the inquiry is resolved, unless it  is deemed necessary to store such inquiries for documentation purposes e.g., due to a dispute,  including for the establishment, exercise or defence of legal claims. 

The inquiries from existing customers will be deleted 3 years from the termination of the  contractual relationship, unless it is deemed necessary to store such inquiries for documentation  purposes e.g., due to a dispute, including for the establishment, exercise, or defence of a legal  claim. 

5.5 Bookkeeping material 

Evunity will store your personal data to the extent it is necessary for bookkeeping purposes such as  personal data related to invoicing. Such personal data will be stored for a period of 5 years from the  end of the financial year to which the accounting records relate. The purpose is to comply with the  legal obligation pursuant to the Egypt Bookkeeping Act. 

5.6  

In the event of a data breach that is likely to result in a risk to your rights and freedoms, Evunity will  notify the relevant data protection authorities and affected individuals in accordance with GDPR  and PDPL requirements. 

6. Social media 

Our Website use social media plug-ins ("plug-ins") from the social networking sites Facebook,  Instagram, LinkedIn. When you visit our social media sites on Facebook, Instagram and LinkedIn or  our Website where social media plugins have been installed, our social media service providers  collect and process your personal data using cookies, subject to your consent to the service  provider, as applicable. Such collection and processing take place even if you have no account on  the social media. 

If you access our Website using such a plug-in, your browser will contact the server of the  underlying social networking site, load the visual presentation of the plug-in, and present it to you.  While this is happening, the social networking site receives information concerning your visit to our  website, as well as further data such as your IP address. Evunity receives anonymous demographic  and geographic statistics from the social media on the visitors on our Website and our social media  sites. 

Evunity is joint data controller with our social media providers for personal data collected and  processed in connection with your visit to our social media sites and our Website. It means, among  other things, that you may contact both Evunity and the social media providers to exercise your  rights under the GDPR and PDPL. Facebook, Instagram, and LinkedIn have primary responsibility  for ensuring compliance with the GDPR and PDPL and responding to requests from visitors on  Facebook, Instagram, and LinkedIn. If you are registered as user of Facebook, Instagram and/or  LinkedIn, you may exercise your rights via your account settings on Facebook, Instagram and/or  LinkedIn. 

We have no influence on the amount of data that social networking sites collect via an active plug in. For more information, please consult the relevant data privacy notice:

Facebook: www.facebook.com/policy Instagram:  

https://help.instagram.com/519522125107875/?maybe_redirect_pol=0 LinkedIn:  https://www.linkedin.com/legal/privacy-policy 

7. Your rights 

Evunity has implemented several measures to protect your personal data and ensure your rights.  As a data subject, you can exercise the rights listed below. 

The Egypt Data Protection Agency has prepared guidelines regarding the data subjects’ rights  available on the agency's website. 

As a data subject you have the following specific rights, unless otherwise exceptionally provided by  the data protection legislation: 

Right of access Right of rectification Right of erasure ("right to be forgotten") Right to restriction of  processing Right to data portability Right to object 

7.1 Right to complain to the Data Protection Agency 

If you disagree with the way in which Evunity processes your personal data, you may file a  complaint with the Egyptian Data Protection Agency. However, we hope that you will contact us  first to resolve any concerns. 

7.2 Right to withdraw a former consent 

If the processing of your personal data is based on your consent, cf. Art. 6(1)(a) of the GDPR and PDPL, you have the right to withdraw your consent at any time. Please note that your withdrawal  does not affect the lawfulness of the previous processing of your personal data which until your  withdrawal has been based on your consent. 

If you wish to exercise any of the above-mentioned rights, or if you wish to withdraw a former  consent, you are welcome to contact us at info@evunity.co. 

8. Questions or complaints 

If you have any questions relating to this Privacy Policy, you wish to exercise your rights as  mentioned above, or you disagree with the way Evunity processes your personal data, you can  contact Evunity at info@evunity.co. 

You can also file a complaint to the relevant data protection supervisory authority, which is an  independent public authority that, inter alia, is responsible for monitoring and enforcing the  application of the GDPR and PDPL. In Egypt, the relevant authority is the Egyptian Data Protection  Agency.  

9. Amendments to this privacy policy 

Evunity has the right to modify this Privacy Policy regarding new technologies, regulatory  requirements, or other purposes. For this reason, please visit this page periodically. Below is  highlighted the date when the last version of this Privacy Policy has been uploaded.

Date of the most recent version of this Privacy Policy: 21 June 2024.