Privacy Policy - T-Power

T-Power Pty Ltd ACN 651 645 948 (T-Power, we, or our) has implemented this privacy policy to provide information about how we collect, store, and use personal information and customer data.

This privacy policy applies to the information we collect through T-Power’s electric vehicle charging point open network (charging points), the T-Power App (T-Power App, T-Power Smart Charge App, T-Power ESS App), and the T-Power Website (t-power.com.au) (website).

We are committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) (as amended from time to time) (Privacy Act) and the Australian National Privacy Principles set out in the Privacy Act (Privacy Principles).

If you have any inquiries about this privacy policy, you should contact us using the contact information provided in clause 10.

We may review and update this privacy policy from time to time. All personal information we hold will be governed by the latest privacy policy posted on our website.

1. What is “Personal Information” and “Customer Data”?

“Personal Information” means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether recorded in a material form or not. Personal information collected may include (but is not limited to) the following:

• Name, mailing address, billing address, email address, and social media address (e.g., Facebook);
• Contact details, including telephone numbers (landline, mobile, and fax);
• Vehicle registration information;
• Payment details; and
• Certain information about how an individual uses our T-Power network.

“Customer Data” refers to customer information we collect that is not considered personal information because it does not reasonably identify an individual. Customer data collected may include (but is not limited to) the following:

• Details of vehicles using our charging points;
• Charging capacity of vehicles using our charging points; and
• Frequency of use and location information of vehicles using our charging points.

2. When and Why We Collect Personal Information

We collect your personal information to manage our relationship with you and perform functions and activities related to our business, as further described in clauses 5 and 6.

We may collect your personal information when you:

• Register an account to use our T-Power network, T-Power app, or website;
• Access or use our T-Power network, T-Power app, or website;
• Request information about us, our products, or our services;
• Request technical support or assistance;
• Provide feedback or make new service requests;
• Complete forms on our T-Power network, T-Power app, or website; or
• Contact us by telephone, email, social media (e.g., Facebook), mail, or in person.

The personal information we collect may include your name, email contact details, billing and delivery addresses, and payment details.

3. Information We Collect Through the T-Power Applications

When you use any of our T-Power apps (T-Power App, T-Power Smart Charge App, T-Power ESS App), we may collect the following information:

Use of the T-Power App

Register & Login

When you register and log in to any of our T-Power apps, we may collect:

• User Phone Number: We may collect your phone number to verify your identity and communicate with you.
• Email Address: We may collect your email address for communication purposes, including sending you updates and notifications.
• Name and Address: We may collect your name and physical address for account verification, billing, and other purposes related to the provision of our services.
• Payment Information: We may collect payment information, such as details from third-party payment platforms, to process transactions related to the use of our services.
• Username and Password: We may collect a unique username and password to facilitate secure access to your account.

Usage Data

When you use our T-Power apps, we may collect additional data about your usage, including:

• Location Data: We may collect your location data to provide location-based services, such as identifying nearby charging points.
• App Usage Data: We may collect data about how you use the app, including the features you access and the actions you take within the app.
• Device Information: We may collect information about the device you use to access the app, including hardware model, operating system, app version, and device identifiers.

Charging Data

When you connect an electric vehicle to a charging point or otherwise use the T-Power network through our apps, we may collect:

• Charging point Usage: Information about the charging points you use, including location, time, and duration of use.
• Vehicle Information: Details about the vehicles using our charging points, including make, model, and charging capacity.
• Charging Activity: Data on the frequency of use, charging patterns, and energy consumption.

Additional Information

We may also collect any other information you provide to us through the app, such as:

• Feedback and Support Requests: Information you provide when you contact us for support or provide feedback.
• Form Submissions: Information you enter when filling out forms or participating in surveys.

All collected data will be used in accordance with this Privacy Policy to enhance your experience, improve our services, and provide you with relevant information and support.

4. Information We Collect Through Our Website

Unless actively provided by users or as otherwise described herein, we do not collect any personal information from users of the website.

Clickstream Data

When you visit and browse our T-Power app or website, our T-Power app/website host may collect information for statistical, reporting, and maintenance purposes. The information collected may include:

• The number of users visiting our T-Power website and the number of pages viewed;
• The date, time, and duration of visits;
• The IP address of your computer or other device;
• The path taken to access our T-Power website.

We may use Google Analytics to help analyze how you use our website. Google Analytics generates statistical and other information about website use by means of cookies stored on users’ computers. The information generated is used to create reports about the use of the website. Google will store this information. We do not (and will not allow any third party to) use Google Analytics to track or collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifiable information from any source as part of our use of Google Analytics.

If you do not wish for your website visit data to be reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling this add-on, please visit the Google Analytics opt-out page at: Google Analytics Opt-out.

Cookies

Cookies are small text files that a website transfers to a user’s hard drive for the purpose of storing information about a user’s identity, browser type, or website visiting patterns. Cookies may be “persistent” or “session” cookies. Persistent cookies will be stored on a user’s computer and will remain valid until their set expiry date, unless deleted by the user before the expiry date. Session cookies will expire at the end of the user’s session when the browser is closed.

When you visit our website, a cookie will be downloaded to your device upon first login. Our website uses session cookies but also uses Google Analytics persistent cookies.

You can adjust your internet browser to disable cookies or delete already stored cookies from your computer. However, if you choose to do so, we may not be able to provide you with all the services or functionality you require on the website.

5. How We Use Collected Personal Information

We use the personal information we collect to perform our business functions and activities, which may include the following:

Website

• Communicating and Providing Information: Interacting with you and delivering the information, products, or services you request through the T-Power website or other means.
• Marketing and Promotion: Promoting and marketing our products and services to you.
• Service Arrangement: Coordinating with third parties to provide services.
• Personalization: Tailoring and enhancing your experience on the T-Power website.
• Customer Research: Gaining insights into customer needs to better understand your requirements and those of our broader customer base. Note: Customer research follows our Data Anonymization and Aggregation policy.
• Service Improvement: Conducting research to enhance our services, develop new offerings, or update products available through the T-Power network or website. Note: Analysis for these purposes follows our Data Anonymization and Aggregation policy.
• Partner Research: Performing research, marketing, and analysis on behalf of our business partners (e.g., electric vehicle original equipment manufacturers and auto clubs). Note: These activities follow our Data Anonymization and Aggregation policy.
• Performance Monitoring: Monitoring and improving the performance of our T-Power website.
• Technical Analysis: Diagnosing and resolving technical issues.
• Security: Preventing and addressing fraud, intellectual property infringement, or technical security issues.
• Legitimate Business Purposes: Pursuing other legitimate purposes where necessary to protect our business, customers, or third parties.
• Data Anonymization and Aggregation: Where legally permissible and subject to your consent where required, we may anonymize or aggregate your personal information to ensure it cannot be used to identify you. Anonymized or aggregated data may be utilized for purposes such as statistical analysis, trend analysis, actuarial work, customizing products and services, and conducting risk assessments and cost analysis related to our offerings. We may also share such anonymized or aggregated data with other third parties. This Privacy Policy does not limit our ability to use or share non-personal, summarized, derived, anonymized, or aggregated information. Note: Customer research and partner research will follow this clause and will not use your personal information.

App (T-Power Drive App, T-Power Smart Charge App, T-Power ESS App)

• Communicating and Providing Information: Interacting with you and delivering the information, products, or services you request through the T-Power app.
• Account Management: Managing and administering your account, including billing for your subscription, use of the T-Power app, or responding to any inquiries you may have about your account.
• Service Arrangement: Coordinating with third parties to provide services.
• Personalization: Tailoring and enhancing your experience on the T-Power app.
• Customer Research: Gaining insights into customer needs to better understand your requirements and those of our broader customer base. Note: Customer research follows our Data Anonymization and Aggregation policy.
• Service Improvement: Conducting research to enhance our services, develop new offerings, or update products available through the T-Power app. Note: Analysis for these purposes follows our Data Anonymization and Aggregation policy.
• Partner Research: Performing research, marketing, and analysis on behalf of our business partners (e.g., electric vehicle original equipment manufacturers and auto clubs). Note: These activities follow our Data Anonymization and Aggregation policy.
• Performance Monitoring: Monitoring and improving the performance of our T-Power app.
• Technical Analysis: Diagnosing and resolving technical issues.
• Security: Preventing and addressing fraud, intellectual property infringement, or technical security issues.
• Legitimate Business Purposes: Pursuing other legitimate purposes where necessary to protect our business, customers, or third parties.
• Data Anonymization and Aggregation: Where legally permissible and subject to your consent where required, we may anonymize or aggregate your personal information to ensure it cannot be used to identify you. Anonymized or aggregated data may be utilized for purposes such as statistical analysis, trend analysis, actuarial work, customizing products and services, and conducting risk assessments and cost analysis related to our offerings. We may also share such anonymized or aggregated data with other third parties. This Privacy Policy does not limit our ability to use or share non-personal, summarized, derived, anonymized, or aggregated information. Note: Customer research and partner research will follow this clause and will not use your personal information.

Retention Period for Personal Data

We retain personal data based on the following principles, unless required or permitted by law to retain it for a longer period:

• Account Information: Kept for the duration of your account's active status and for a reasonable period thereafter, in case you decide to reactivate your account.
• Transaction Data: Retained as required by law for accounting and tax purposes.
• Technical Data: Used to maintain system security and performance.
• Marketing Data: Deleted promptly upon you opt-out from marketing communications or after a reasonable period.

Upon request for deletion of personal data by users, we will immediately delete all personal data, except for transaction data necessary for calculating financial performance and fulfilling accounting and tax obligations. In certain circumstances, data may be retained for longer periods as required by law or for legitimate business purposes.

These retention periods are subject to specific legal requirements or compliance policies of the company.

Important Notice Regarding Personal Data

First and foremost, we do not sell your personal data or the personal data of your end-users. Additionally, we do not allow any personal data to be used by third parties for their own marketing purposes, except in cases where you explicitly request or consent to such use (e.g., when you direct us to share your information with a sponsor at a conference).

However, there are instances where sharing your personal data is necessary. This may be to provide you with services (e.g., to route a call or send an email), to enable our suppliers to provide services to us, or for other reasons listed in this Privacy Policy.

6. Marketing

We may use your Personal Information to provide you with marketing material about us, our services, or products that we think may be of interest to you. We do not disclose any personally identifiable information of our users to advertisers.

You may opt-out of receiving marketing information from us at any time by:

• clicking on the “Unsubscribe” link included in any marketing email you receive from us; or
• contacting us as specified in clause 10.

Unless otherwise specified in this Privacy Policy, we or our Website/T-Power App host will not disclose any of your Personal Information to any other organization unless the disclosure is required by law or is otherwise permitted by the Privacy Principles.

7. Security and Storage

We are committed to taking all reasonable steps to protect your personal information from misuse, loss, unauthorized access, modification, or disclosure.

We protect our paper and electronic records through physical and electronic security measures, including firewalls, encryption, and access control measures.

While we will take all reasonable steps to protect your personal information, we cannot guarantee the security of any information transmission and you agree that we will not be held responsible for any breach of security.

8. Access, Correction, and Deletion of Your Personal Information

Access

You have the right to request access to the personal information we hold about you. You can contact us at any time using the contact details provided in clause 10 to request access. We will respond to your request within a reasonable timeframe and provide you with access unless there is a lawful reason for withholding access, such as when granting access would unreasonably impact the privacy of others or in other specific circumstances. If we refuse your access request, we will provide you with reasons for the refusal.

Correction

Under privacy laws, we take reasonable steps to ensure that any personal information we hold is accurate, complete, up-to-date, and relevant. If you believe that any personal information we hold about you is inaccurate, incomplete, or unauthorized, please contact us using the contact details provided in clause 10, and we will promptly take reasonable steps to correct the information.

Account Deletion (see clause 13)

If you wish to delete your account and associated personal information from our systems, please contact us using the contact details provided in clause 10. We will process your request within a reasonable timeframe, subject to any legal obligations or legitimate interests that may require us to retain certain information.

Deletion

You may also request the deletion of your personal information held by us. Please contact us using the contact details provided in clause 10 to request deletion. We will review your request and, subject to our legal obligations and legitimate business interests, take reasonable steps to delete your personal information from our records.

Privacy Contact

For any questions regarding access, correction, or deletion of your personal information, please contact our Privacy Issues Contact at support@t-power.com.au.

9. Complaints

10. Contact Details

If you have any questions about this Privacy Policy or wish to make a request for access, correction, or complaint, please contact us using the following methods:

We may update this Privacy Policy from time to time, with all updates published on our website.

11. Mailchimp Privacy

T-Power uses Mailchimp to provide electronic newsletters to subscribers. In distributing newsletters, Mailchimp will collect personal information from you, including:

• Email addresses you have provided to T-Power for the purpose of receiving electronic updates;
• All information relating to those email addresses.

Mailchimp also uses cookies, web beacons, and Flash player codes to collect information about:

• When you access the T-Power electronic newsletters;
• Your browser type and version;
• Your operating system and other similar information.

For more information on the information Mailchimp will collect, please refer to the Mailchimp Privacy Policy and the Mailchimp Terms of Use.

Mailchimp will use the information collected from you for the purpose of hosting the online platform to enable T-Power to create, send, and manage electronic newsletters. Mailchimp will also use this information to measure the performance of T-Power’s email campaigns.

Mailchimp may transfer this information to its contractors or other third parties who process the information on Mailchimp’s behalf, or where otherwise required to do so by law.

Mailchimp is based in the United States of America (USA) and is subject to the laws of the USA. Your information (including your IP address) will be transmitted to and stored by Mailchimp on servers located outside Australia.

By signing up to electronic newsletters about network updates, partnerships, and deals, you:

• Consent to your personal information being collected, used, and disclosed as set out in these terms and conditions, and in Mailchimp’s Privacy Policy and Terms of Use;
• Consent to your personal information being sent and stored overseas, and acknowledge that Australian Privacy Principle 8.1 contained in Schedule 1 to the Privacy Act 1988 (Cth) will not apply to the use of the information;
• Acknowledge that Mailchimp is not subject to the Privacy Act 1988 (Cth) and you will not be able to seek redress under the Privacy Act 1988 (Cth) for any privacy breaches by Mailchimp but will need to seek redress under the laws of the USA.

You can unsubscribe from the T-Power electronic newsletter at any time by selecting the “unsubscribe” option in every email sent to you by Mailchimp.

If you have any questions or concerns relating to the use of your personal data, please contact us at support@t-power.com.au.

12. Active Campaign Privacy

T-Power uses Active Campaign to manage communications with subscribers. In distributing communications, we will collect personal information from you, including:

• Email addresses you have provided to T-Power for the purpose of receiving electronic updates;
• All information relating to those email addresses.

Active Campaign also uses cookies, web beacons, and Flash player codes to collect information about:

• When you access the T-Power electronic newsletters;
• Your browser type and version;
• Your operating system and other similar information.

For more information on the information Active Campaign will collect, please refer to the Active Campaign Privacy Policy and the Active Campaign Terms of Use Policy.

Active Campaign will use the information collected from you for the purpose of hosting the online platform to enable T-Power to create, send, and manage electronic communications. Active Campaign will also use this information to measure the performance of T-Power’s email campaigns.

Active Campaign may transfer this information to its contractors or other third parties who process the information on Active Campaign’s behalf, or where otherwise required to do so by law.

Active Campaign contractually agrees to process personal information in compliance with all applicable privacy laws, including the Australian Privacy Act (please see Section 3(b)).

By signing up to electronic communications about network updates, partnerships, and deals, you consent to your personal information being collected, used, and disclosed as set out in these terms and conditions, and in Active Campaign’s Privacy Policy and the Active Campaign Terms of Use Policy.

You can unsubscribe from the T-Power electronic newsletter at any time by selecting the “unsubscribe” option in every email sent to you by Active Campaign.

If you have any questions or concerns relating to the use of your personal data, please contact us at support@t-power.com.au.

13. How to Delete Your Account

To delete your account, you can:

• Send an email to our customer services at: support@t-power.com.au
• Use the form provided below:

Field	Description
Name	Your name
Phone	Your phone number
Email	Your email address
Request type	Specify the type of request
Request detail	Provide details of your request

• Or call us using the contact information provided in clause 10.

We will process your request within approximately 2-5 business days. Once the request is completed, you will receive an email confirmation.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, including to reflect new laws, regulations, and technology. All updates will be published on our website. Please check regularly to understand any changes to our privacy practices.