PRIVACY POLICY

Last updated: October 18, 2024.

Welcome to EVC Point Nigeria Limited (“Company,” “we,” “us,” “our”) Privacy Policy.

EVC Point Nigeria Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

We keep our Privacy Policy under regular review. This version was last updated on October 18 2024. Historic versions can be obtained by contacting us.

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

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS 

If you have any questions about this Privacy Policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: EVC Point Nigeria Limited

Email address: info@connectvolt.com

You have the right to make a complaint at any time to the Nigeria Data Protection Commission (NDPC), Nigeria’s regulator for data protection issues (www.ndpc.gov.ng). We would, however, appreciate the chance to deal with your concerns before you approach the NDPC; therefore, please contact us in the first instance.

INTERPRETATION AND DEFINITIONS

1. Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for you to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application means any software program provided by the Company for accessing its services, bearing the name Connect Volt.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to EVC Point Nigeria Limited.

Country refers to Nigeria.

Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Application.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Third-Party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

a. Personal Data

While using the Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

    1. Email address
    2. First name and last name
    3. Birth dates
    4. Gender
    5. Billing information
    6. Usage Data

b. Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

c. Location Data

The App makes use of functionalities on your device that can pinpoint your location. We do this in order to help you find the electric car charging point which is located the closest to you.

When you open the App for the first time, you will be asked whether the App can use your location and in what circumstances.  If you refused to authorise the location services the first time you opened the App, but change your mind later on, you can still update your choices at any time in the App settings. Conversely, you can also turn the location services off at any time, but please note that if you choose to do so, you may be unable to utilize the App effectively. This is because the “maps” feature allowing you to locate charging points on the app will be unavailable.

When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app. EVC Point Nigeria exerts no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protects personal data.  Please visit their site – https://policies.google.com/privacy?hl=en-NG.

d. Information from Third-Party Social Media Services

The Company allows you to create an account and log in to use the Service through the following Third-Party Social Media Services:

  • Google
  • Facebook
  • Apple

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect Personal Data that is already associated with your Third-Party Social Media Service’s account, such as your name, your email address, your activities or your contact list associated with that account.

You may also have the option of sharing additional information with the Company through your Third-Party Social Media Service’s account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect Personal Data that is already associated with your Third-Party Social Media Service’s account, such as your name, your email address, your activities or your contact list associated with that account.

You may also have the option of sharing additional information with the Company through your Third-Party Social Media Service’s account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

e. If You Fail to Provide Personal Data

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 the Service). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

f. Information Collected while Using the Application

While using the Application, in order to provide features of the Application, we may collect, with your prior permission:

  • Pictures and other information from your Device’s camera and photo library
    We use this information to provide features of our Service, to improve and customize our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on your Device.

You can enable or disable access to this information at any time, through your Device settings.

2.2 How Is Your Personal Data Collected?

  1. We use different methods to collect data from and about you including through:
    • Direct interactions: You may give us your Identity, Contact and e-mail address by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
      1. apply for our Services;
      2. create an account on our website;
      3. subscribe to our service;
      4. request marketing to be sent to you;
      5. give us feedback; or
      6. contact us
    • Automated technologies or interactions: As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy – https://www.connectvolt.ng/cookie-policy for further details.
    • Third parties or publicly available sources: We will receive Personal Data about you from various third parties as set out below:
      1. analytics providers such as Google;
      2. advertising networks;
      3. social media platforms such as Instagram, TikTok, Meta, Twitter, etc. and
      4. search information providers.
    • Contact, financial and transaction data from providers of technical, payment services such as Flutterwave and Paystack amongst others.
    • Identity and contact data from data brokers, among others.

2.3 Location services/data

The Application will request your consent to use location services to precisely identify your location each session (i.e. each time the app is opened or has been placed in the background for more than 30 seconds). This consent is a one-off consent upon first opening the app, which can always be retrieved and/or managed via your device. We require access to that data in order to identify real world locations to locate electric car charging points near you.

If you do not provide your consent, you may use the app but that will mean the “maps” feature allowing you to locate charging points on the app will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.

The location services in the app will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.

We at EVC Point Nigeria exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site – https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.

2.4 Use of Your Personal Data

We will only use your Personal Data as permitted by the Law. We may use Personal Data for the following purposes:

  1. To provide and maintain our Service, including to monitor the usage of our Service
  2. To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
  3. For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
  4. To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  5. To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  6. To manage your requests: To attend and manage your requests to us.
  7. To manage our relationship with you: This will include notifying you about changes to our terms or Privacy Policy and asking you to leave a review or take a survey.
  8. For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
  9. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  10. To comply with requests from law enforcement agencies or regulators, or in compliance with a court order or warrant.
  11. For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

2.5 Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:

  1. Promotional Offers From Us
    We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing).
    You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
  2. Third-Party Marketing
    We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
  3. Opting Out
    You can ask us or third parties 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 at any time.
    Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience or other transactions.
  4. Cookies
    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see – https://www.connectvolt.ng/cookie-policy

2.6 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.

We may share your personal information in the following situations:

  1. With Service Providers: We may share your Personal Data with Service Providers to monitor and analyze the use of our Service, to contact you.
  2. For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  3. With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  4. With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
  5. With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
  6. With Your consent: We may disclose your personal information for any other purpose with your consent.

3. Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

4. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

5. International Transfers  

5.1. We share your Personal Data within the Company and its subsidiaries. This may involve transferring your data outside Nigeria.

Many of our external third parties are based outside Nigeria so their processing of your Personal Data may involve a transfer of data outside Nigeria

Whenever we transfer your Personal Data out of Nigeria, we shall:

  • Record the basis of such transfer and the adequate level of protection afforded to such Personal Data by that country or recipient of the data
  • Comply with any applicable additional specified restrictions on cross-border transfer of Personal Data imposed by the Nigeria Data Protection Commission (NDPC) from time to time.
  • Ensure that such a country is listed on the Nigeria Data Protection Commission’s white list, or a similar degree of protection is afforded to your data; by ensuring at least one of the following safeguards are implemented:
    1. There are enforceable data subject rights which a data subject can rely on to seek redress through administrative or judicial process and the rule of law;
    2. There exists appropriate instruments between the NDPC and a competent authority in the recipient jurisdiction that ensures adequate data protection;
    3. The access of a public authority to data;
    4. The existence of effective data protection laws and the existence and functioning of an independent and competent data protection or other similar authority with adequate enforcement powers; and
    5. International commitments and conventions binding on the relevant country and its membership of any multilateral or regional organizations.
  • We may still transfer your data to another country where the above safeguards are not met however where you have not withdrawn your consent to such transfer, where such transfer is necessary for us to provide the Service to you, where such transfer is for your benefit but it is impractical for us to obtain your consent or in our discretion, you would likely give it, where the transfer is necessary in the interest of the public, for the defence of a legal claim or where such transfer is necessary to protect your vital interests where you can or cannot consent due to physical or legal incapacity. Note however, that we may transfer your data where there is a legitimate reason to do so.
  • Where we use certain service providers, we may use specific contracts approved for use in Nigeria which give personal data the same protection it has in Nigeria.
  • The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate levels of protection in place including the security of your data and other personal information.
  • Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of Nigeria.
  • Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

6. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors 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 a duty of confidentiality.

Please note that while the security of your Personal Data is important to us, no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We have also 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.

 7. Your Legal Rights

7.1 Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. We encourage you to consult the Nigeria Data Protection Act to read more on these rights. They include:

  • Request access to your Personal Data: (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of your Personal Data: 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be communicated 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. Where you object to such processing, we shall cease such processing.
  • Request restriction of processing your Personal Data: This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    1. If you want us to establish the data’s accuracy
    2. Where our use of the data is unlawful but you do not want us to erase it
    3. 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
    4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
  • Request transfer of your Personal Data to you or 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to withdraw consent: You have the right to withdraw consent at any time 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 at info@connectvolt.com

7.2 No Fee Usually Required

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 could refuse to comply with your request in these circumstances.

7.3 What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other 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.

7.4 Delete Your Personal Data

You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you. Our Service shall give you the ability to delete certain information about you from within the Service.

You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information that you have provided to us.

Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

8. Disclosure of Your Personal Data

8.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

8.2 Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

8.3 Other legal requirements

The Company may disclose your Personal Data in the good faith on belief that such action is necessary to:

    1. Comply with a legal obligation
    2. Protect and defend the rights or property of the Company
    3. Prevent or investigate possible wrongdoing in connection with the Service
    4. Protect the personal safety of Users of the Service or the public
    5. Protect against legal liability

9. Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information. We may require a form of government approved identification for the purpose of verifying parental consent.

We may waive parental consent to processing where the vital interests of a minor are concerned or where processing is necessary as part of judicial proceedings relating to the minor.

10. Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

11. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

By  : info@connectvolt.com

Scroll to Top