1 ABOUT CHARGING CHAMPION

Brand Name: Charging Champion

Data Controller: EOSVOLT ApS

Address: Arne Jacobsens Alle 15, 2300 Copenhagen S, Denmark

CVR: 44305844

Email: contact@eosvolt.com

Platform Provider & Operating Partner: Zhejiang Chaoxiang New Energy Co., Ltd.

No.16, Chuangzhi Road, Lijia Xiang Town, Changxing County, Huzhou City, Zhejiang Province, China

Email: info@chargingchampion.com

Charging Champion provides software and digital infrastructure services for electric vehicle charging management, analytics, payment functionality, mobile applications, and related operational services (powered by EOSVOLT).

2 SCOPE OF THIS POLICY

This Privacy Policy applies to:

• visitors to the Charging Champion web platform and portal (including spark.eosvolt.com and related subdomains);
• users of the Charging Champion mobile application;
• charging point operators (“CPOs”);
• fleet operators;
• business customers;
• End Users of charging services; and
• individuals communicating with Charging Champion.

This Privacy Policy does not apply to third-party services, websites, or charging operators operating independently of Charging Champion.

3 TYPES OF PERSONAL DATA WE COLLECT

Depending on how you use the Services, Charging Champion may collect and process the following categories of personal data.

3.1 Account and Contact Information

• name;
• email address;
• phone number;
• company information;
• billing details;
• account credentials; and
• communication preferences.

3.2 Charging and Platform Data

• charging-session information;
• charging duration;
• charging consumption;
• charging location;
• charger identifiers;
• fleet information;
• roaming information;
• platform usage activity; and
• account activity.

3.3 Technical and Device Information

• IP addresses;
• browser information;
• operating system information;
• device identifiers;
• mobile-device information;
• crash reports;
• application logs;
• infrastructure telemetry; and
• API interaction data.

3.4 Location Data

Where permitted by device settings and applicable law, Charging Champion may process location data to:

• display nearby charging stations;
• provide navigation functionality;
• improve charging availability; and
• support charging-related services.

Users may manage location permissions through device settings.

3.5 Payment Information

Payment transactions are processed through licensed third-party payment service providers, including Stripe and related payment infrastructure providers.

Charging Champion may receive limited transaction-related information such as:

• transaction identifiers;
• payment status;
• payout information;
• settlement information; and
• billing metadata.

3.6 Support and Communications

We may process information contained in:

• support requests;
• emails;
• chats;
• customer-service communications;
• diagnostics;
• troubleshooting requests; and
• operational inquiries.

3.7 Charger Diagnostics and Operational Logs

Charging Champion may process:

• charger diagnostics;
• OCPP logs;
• technical telemetry;
• infrastructure metadata;
• charging-session logs;
• fault reports; and
• operational monitoring information

for:

• troubleshooting;
• cybersecurity;
• operational analytics;
• fraud prevention;
• service optimisation; and
• platform reliability.

4 HOW WE USE PERSONAL DATA

Charging Champion may process personal data for the following purposes:

• providing and operating the Services;
• enabling charging sessions;
• managing accounts and subscriptions;
• processing payments and payouts;
• maintaining platform security;
• fraud prevention;
• cybersecurity monitoring;
• customer support;
• diagnostics and troubleshooting;
• service analytics;
• improving platform functionality;
• operational reporting;
• legal compliance;
• enforcing agreements;
• communication with users and customers; and
• marketing communications where permitted by law.

5 LEGAL BASES FOR PROCESSING

Depending on the context, Charging Champion processes personal data based on:

5.1 Contractual Necessity

Processing necessary to provide the Services or fulfil contractual obligations.

5.2 Legitimate Interests

Processing necessary for:

• platform operations;
• fraud prevention;
• cybersecurity;
• diagnostics;
• analytics;
• service improvement;
• business operations; and
• customer support.

5.3 Legal Obligations

Processing necessary to comply with:

• tax laws;
• accounting obligations;
• regulatory requirements;
• fraud-prevention obligations; and
• law-enforcement requests.

5.4 Consent

Where required by law, Charging Champion may rely on consent for:

• marketing communications;
• location permissions;
• cookies; or
• optional functionality.

Users may withdraw consent at any time where consent is the legal basis.

6 AI-ASSISTED PROCESSING AND OPERATIONAL ANALYTICS

Charging Champion may use automated analytics systems, machine learning technologies, and AI-assisted tools to support:

• charger diagnostics;
• charger log analysis;
• fault detection;
• cybersecurity monitoring;
• fraud prevention;
• operational analytics;
• customer support assistance;
• service optimisation; and
• platform improvement.

These systems are used to support operational processes and improve service quality, operational efficiency, and platform reliability.

Charging Champion does not use solely automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR unless explicitly disclosed and permitted under applicable law.

Where reasonably possible, Charging Champion applies:

• data minimisation;
• pseudonymisation;
• access restrictions; and
• security safeguards

to reduce unnecessary processing of personal data in connection with AI-assisted systems.

7 PAYMENT PROCESSING

Payment transactions initiated through the Platform are processed using licensed third-party payment service providers, including Stripe and related payment infrastructure providers.

Depending on the payment flow and operational setup, payment transactions and settlement processes may involve temporary routing or processing through payment infrastructure configured in connection with Charging Champion's Platform before payout to the applicable charging operator.

Charging Champion does not independently operate as:

• a bank;
• a licensed payment institution;
• an electronic money institution; or
• an escrow provider.

Payment providers may impose additional:

• onboarding requirements;
• identity verification procedures;
• fraud-prevention checks; and
• compliance obligations.

Users and CPOs may also be subject to separate terms imposed by payment providers.

8 SHARING OF PERSONAL DATA

Charging Champion may share personal data with:

• charging point operators;
• roaming providers;
• payment providers;
• cloud infrastructure providers;
• analytics providers;
• customer-support providers;
• cybersecurity providers;
• communication-service providers;
• AI and diagnostic service providers;
• professional advisers; and
• public authorities where legally required.

Charging Champion requires service providers processing personal data on its behalf to implement appropriate contractual and security safeguards.

9 SERVICE PROVIDERS AND SUBPROCESSORS

Charging Champion may use trusted third-party service providers and subprocessors to support:

• cloud hosting;
• infrastructure monitoring;
• analytics;
• payment processing;
• communications;
• notifications;
• customer support;
• AI-assisted diagnostics;
• fraud prevention;
• cybersecurity; and
• operational monitoring.

Such providers may process personal data on Charging Champion's behalf subject to contractual and technical safeguards.

Where Charging Champion processes personal data on behalf of business customers or Charging Point Operators as a processor under applicable data protection laws, the applicable Data Processing Agreement (“DPA”) may apply.

10 INTERNATIONAL DATA TRANSFERS

Personal data may be processed in countries outside the European Economic Area (“EEA”) where Charging Champion, EOSVOLT, or their subprocessors operate.

Where required by applicable law, appropriate safeguards are implemented for international transfers, including:

• Standard Contractual Clauses approved by the European Commission; or
• equivalent legal transfer mechanisms.

11 DATA RETENTION

Charging Champion retains personal data only for as long as reasonably necessary:

• to provide the Services;
• to comply with legal obligations;
• to maintain platform security;
• to prevent fraud;
• to resolve disputes;
• to enforce agreements; or
• to maintain operational integrity.

Retention periods may vary depending on:

• account activity;
• charging-session records;
• invoicing requirements;
• fraud-prevention needs;
• support obligations;
• security requirements; and
• applicable legal obligations.

Certain financial and transactional records may be retained for longer periods where required by applicable accounting, tax, or regulatory laws.

12 SECURITY MEASURES

Charging Champion uses commercially reasonable technical and organisational measures designed to protect personal data against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• destruction; or
• damage.

Security measures may include:

• access controls;
• encryption;
• monitoring systems;
• authentication procedures;
• infrastructure protections; and
• cybersecurity safeguards.

13 USER RIGHTS

Subject to applicable law, individuals may have rights to:

• access personal data;
• request correction of inaccurate data;
• request deletion of personal data;
• restrict processing;
• object to certain processing activities;
• request data portability; and
• lodge complaints with a competent supervisory authority.

Requests relating to personal data may be submitted using the contact details below.

Charging Champion may request identity verification before responding to requests.

14 COOKIES AND TRACKING TECHNOLOGIES

Charging Champion may use:

• cookies;
• SDKs;
• analytics tools;
• crash-reporting technologies; and
• similar tracking technologies

to:

• improve platform functionality;
• analyse usage;
• maintain security;
• personalise experiences; and
• support operational analytics.

Users may manage cookie preferences through browser settings where applicable.

Additional information may be available in the Charging Champion Cookie Policy.

15 MARKETING COMMUNICATIONS

Charging Champion may send:

• service announcements;
• operational notifications;
• security alerts;
• product updates; and
• marketing communications

where permitted by applicable law.

Users may unsubscribe from marketing communications at any time.

Operational or service-related communications may still be sent where necessary.

16 CHILDREN

The Services are not intended for individuals under eighteen (18) years of age.

Charging Champion does not knowingly collect personal data from children where prohibited by applicable law.

17 THIRD-PARTY SERVICES

The Services may integrate with third-party services including:

• roaming networks;
• payment providers;
• mapping providers;
• charger manufacturers; and
• analytics platforms.

Charging Champion is not responsible for the privacy practices of third-party services operating independently of Charging Champion.

Users should review the applicable privacy policies of third-party providers where relevant.

18 CHANGES TO THIS PRIVACY POLICY

Charging Champion may update this Privacy Policy from time to time.

Updated versions become effective upon publication on the Charging Champion website or Platform.

Continued use of the Services following publication of updated versions constitutes acknowledgement of the revised Privacy Policy.

19 LANGUAGE

This Privacy Policy is provided in English and may be made available in other languages. In the event of any inconsistency or conflict between the English-language version and any translated version, the English-language version shall prevail.

20 CONTACT INFORMATION

Questions or requests regarding this Privacy Policy or Charging Champion's processing of personal data may be directed to:

Platform Provider & Operating Partner:

Zhejiang Chaoxiang New Energy Co., Ltd.

Address: No.16, Chuangzhi Road, Lijia Xiang Town, Changxing County, Huzhou City, Zhejiang Province, China

Email: info@chargingchampion.com

Data Controller:

EOSVOLT ApS

Address: Arne Jacobsens Alle 15, 2300 Copenhagen S, Denmark

Email: contact@eosvolt.com

If you are located in the European Union, you may also have the right to lodge complaints with your local data protection authority.