ANNEX 1 PRIVACY POLICY

1. GENERAL CONDITIONS

1.1. The application is a digital application called ChargeNet (hereinafter "App") through which Chargenet offers its users a battery bank rental service (see Terms of Use). This Privacy Policy regulates the collection, storage and use of personal data collected, stored and used in the App.

1.2. The developer and owner of the application is Shenzhen D-Tool Technology Co., Ltd. (hereinafter also the data importer), registered in the People's Republic of China, which has access to the data collected through the application and is therefore the controller of the data collected in the App. The user and controller of the application in Estonia is Chargenet OÜ, registry code 16862057, registered office Maakri tn 36-55, Republic of Estonia. Personal data shall be transferred to the owner of the application outside the European Union and the European Economic Area on the basis of Implementing Decision 2021/914 of the European Commission of 04.06.2021 and following the data protection measures concluded between the parties. General terms and conditions of data protection measures are available at Chargenet OÜ by contacting customer support at the e-mail address info@chargenet.ee.

1.3. The purpose of processing personal data is to apply the battery bank rental service to customers (including getting fee for it), to communicate with customers, to maintain customer relations, to implement, develop and monitor customer service, and to implement communication and marketing, etc. Personal data is processed for reporting purposes and for the development of a company. The User confirms that he/she is aware that the controllers process personal data for the authentication of the User, for the provision of the charging service (battery bank rental service) and for the service of the User in the application, ensuring the fulfilment of mutual obligations and the protection of other legal interests in accordance with the requirements of the legal provisions on data processing and protection.

1.4. The processing of personal data is based on the implementation of a contract between Chargenet and the user and partly on the consent given by the user (e.g. for marketing purposes).

1.5. When creating and using a user account and accessing the application, you confirm that you have read and understood this privacy policy and consent to it (including the transfer of personal data to the co-controller outside the European Union and the European Economic Area). For questions (including what personal data are processed, for what purpose and by whom, in terms of liability division, etc.), it is possible to contact Chargenet customer support.

2. PERSONAL INFORMATION

2.1. When you visit the app, we automatically collect information about your device about your web browser, IP address, time zone, geo-location, and certain cookies on your device.

2.2. When browsing the app, we collect information about which websites or search units directed you to the app and how you interact with the app.

2.3. We collect information about your device using the "cookies" data file and "log files" that collect data, including IP address, browser type, Internet service provider, referencing/exit pages, and date/time stamps.

2.4. When you interact with any Service Provider page or account on a social media platform, such as Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest, we may collect the personal information that you make available to us on that page or account including your account ID or “handle.” However, we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such personal information that we are permitted to collect by these social media platforms. If you publish your social media profile on our Service, we may collect personal information that you make available as part of that profile.

2.5.For the provision of services, we collect the information you provide to register your user account (name, email address, phone number, etc.), transactions between you and the controller (including order information) and any other information you wish to send to us (both via the app and off-app).

2.6.We use information:

2.6.1.location data is collected only when the application is activated, location data collection stops when the application is closed;

2.6.2.we can use location information to identify nearby devices;

2.6.3.we use user contact information to inform you about updates to the app;

2.6.4.customer support service data is collected on a case-by-case basis and stored to resolve disputes and service quality issues;

2.6.5. to contact you and respond to your queries;

2.6.6.to verify information about possible fraud or other irregularities;

2.6.7. to provide information or advertising related to our products or services according to your preferences.

2.7.We use the information we collect to help us prevent potential risks and fraud attempts (particularly your IP address) and generally improve and optimize our app (e.g. by generating analytics on how our customers browse and interact with the app to measure the success of our marketing and advertising campaigns, provide the best possible visual and technical experience for your particular device model, screen size and web browser).

3. POLICY OF COOKIES

3.1. Session cookies allow us to track your activity during one browsing session, but do not stay on your device later. Persistent cookies stay between sessions on your device. We use them to authenticate you and remember your preferences. We also use third-party cookies to ensure the safe and convenient operation of the application and to create internal statistics (including to analyse visitor-user interactions).

3.2. We use your personal data to provide you with targeted advertising or custom marketing offers that we believe may be of interest to you.

3.3. We may partner with third party advertising companies to better provide advertisements about our goods and services that may be of interest to you. These third-party advertisers may use cookies alone or in combination with web beacons or other tracking technologies to collect information about you when using apps. They may collect information about your online activities over time and through various applications and other online services. They may use this information to provide you with interest-based advertising or other targeted content. They may use permanent identifiers to anonymously monitor your internet usage on their networks outside of these applications. Third parties with sufficient data from other sources may be able to identify you personally, without our knowledge.

3.4. Third-party ad serving companies and other unaffiliated advertisers also display advertisements on our Apps. As part of their service, they may place a separate cookie on your computer or utilize other data collection and tracking technologies, to collect information such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to a particular advertisement. We may allow third party companies to place cookies to serve ads on the Apps. We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect and we are not responsible for the privacy policies or the content of those third parties. Please visit the sites of those businesses at the links above to review their privacy policies. We may add or change the list of third-party ad servers from time to time and we encourage you to check this section for changes.

3.5. We do not change our data collection and usage practices in the App section even if we see a "no trace" signal from the browser.

3.6. We use Google Analytics and Facebook Pixel to help us understand how our customers use the app.

3.7. We may share your personal data in order to comply with applicable laws and regulations, to respond to a lawful request for information from an authority in compliance with the law, or to otherwise protect our rights.

4. RIGHTS AND STORAGE OF DATA OF THE USER

4.1. If you are a resident of Europe, you have the right to access the personal data we hold and to ask us to correct, update or delete your personal data. If you wish to exercise this right, please contact us by email at info@chargenet.ee. The same rights apply to the data importer by contacting the data importer by e-mail at info@chargenet.ee. The data importer is required to deal with the corresponding request no later than 1 month after the receipt of the request or request. You have the right to receive information in an understandable and easily accessible form and in clear and simple wording.

4.2. Your personal data will be stored in data centres located in the territory of the People's Republic of China.

4.3. Data collected for accounting purposes shall be stored for 7 (seven) years after the last service. In the case of suspicion of a criminal offence, attempted fraud or false information, the data shall be stored for 10 (ten) years. In the case of a dispute, the data shall be preserved until the resolution of the dispute or expiry of the claim for dispute pursuant to the legislation of the Republic of Estonia.

4.4. Deleting the app from your device does not result in erasing your personal data.

5. FINAL PROVISIONS

5.1. Our privacy policy does not apply to other websites to which you may link from our app.

5.2. We may update this Privacy Policy from time to time for legal or regulatory reasons.

5.3. If you have any questions or would like to make a complaint, please contact us at info@chargenet.ee.

5.4. The supervisory authority of the Republic of Estonia is the Data Protection Inspectorate (www.aki.ee) who can be contacted by e-mail at info@aki.ee .