Privacy Policy

This Privacy Policy ("Policy") explains how the operator of ChargeN (the "App", "we", "our", or "us") collects, uses, discloses, stores and protects your personal data when you install and use the App to bind, configure, monitor and control your electric vehicle (EV) charging equipment. Please read this Policy carefully before using the App. If you do not agree with any part of it, please do not use the App.

1. Data Controller

Unless stated otherwise, the data controller responsible for the processing of your personal data through the App is the App operator ("Operator"). You may contact us using the details provided in Section 13 (Contact Us).

2. Scope of This Policy

• This Policy applies to the mobile application and any related services (collectively, the "Services").
• This Policy does not apply to third-party services, websites or products that may be linked from the App. Such third parties operate under their own privacy notices.

3. Information We Collect

We only collect data necessary to provide, operate, secure and improve the Services. Categories include:

3.1 Account and Identity Data

• Email address and email verification code.
• Password and authentication credentials used to register, sign in and recover your Account.
• Authentication token issued after login (used in the Authorization request header).
• Account identifier, nickname or display name where provided.

3.2 Charger and Device Data

• Charger serial number / pile code, gun code, custom pile nickname.
• Bluetooth device identifier / MAC address of the charger (used to identify and reconnect to your equipment).
• Firmware version, OTA upgrade status and progress.
• Charging telemetry: voltage, current, power, State of Charge (SOC), gun status, session duration, energy delivered (kWh).
• Charging strategies you configure (smart charging, scheduled charging, current limit, plug-and-charge, authentication mode, grounding detection, self-recovery, card reader mode).

3.3 Order and Usage Data

• Charging orders and history, order code, order status, statistics by day/period and by pile.
• Sharing relationships, including the display name and email address you enter when inviting another user.

3.4 Device, Network and Log Data

• Server request data such as IP address, request time, authentication status and error codes, used to deliver and secure the Services.
• App version and local diagnostic / operation logs used to troubleshoot charger, Bluetooth and Wi-Fi setup. In the current production build these logs remain on your device and are not uploaded through the App.

3.5 Sensor and Permission-Based Data

Permission	Data Accessed	Purpose
Bluetooth (BLE)	Nearby BLE advertisement data, MAC of your charger, bonded device info	To discover, pair with and securely exchange configuration and control messages with your charger over BLE.
Location While Using the App (Android and iOS) / Nearby Wi-Fi Devices	Current Wi-Fi network name (SSID) and the location result temporarily returned by the operating system	Used only during charger network setup because the operating system restricts access to Wi-Fi information. ChargeN discards the returned GPS coordinates and does not send or store them.
Wi-Fi State / Change Wi-Fi State	Wi-Fi state, current SSID, connection status and the Wi-Fi password you enter	To provision your charger. The SSID and password are sent directly to your charger over Bluetooth and are not sent to the ChargeN server by the App.
Camera	Camera stream and the charger code contained in a scanned QR code	To scan the QR code printed on a charger for binding. Camera frames are processed on-device and are not uploaded. For a ChargeN encrypted QR code, only the encoded charger-code text is sent to our server for decoding.
Vibrate / Wake Lock	—	To provide interaction feedback and help keep a user-initiated BLE / OTA operation reliable. These capabilities do not provide ChargeN with personal data.

You can grant or revoke permissions at any time in your operating system settings. Revoking a permission may disable related features (for example, revoking Bluetooth will prevent pairing).

3.6 Data We Do Not Collect

• We do not collect your contact list, SMS, call history, microphone recordings or media library.
• We do not store or transmit your precise GPS location.
• We do not use advertising SDKs, the Apple advertising identifier (IDFA), or your data to track you across apps or websites.
• We do not knowingly collect personal data of children under 16.

4. How We Use Your Data (Purposes and Lawful Bases)

Purpose	Lawful Basis (GDPR Art. 6)
Account creation, authentication, password recovery, account cancellation	Performance of a contract
Binding, configuring, controlling and monitoring your charger; delivering charging orders	Performance of a contract
Bluetooth / Wi-Fi network provisioning of the charger	Performance of a contract
Firmware (OTA) upgrade and integrity checks	Performance of a contract; Legitimate interest (device safety)
Fraud prevention, service security, rate-limiting, abuse detection	Legitimate interest; Legal obligation
Local diagnostics and server-side service / security logs	Legitimate interest (reliability and security)
Responding to your requests and providing customer support	Performance of a contract; Legitimate interest
Compliance with legal, regulatory or safety obligations	Legal obligation
In-App messages / language-specific notices	Legitimate interest; Consent where required

5. How We Share Your Data

We do not sell your personal data. We may share limited data with the following categories of recipients:

• Service providers (processors): cloud hosting, email verification delivery and OTA distribution providers acting under written data processing agreements and on our documented instructions.
• Charger manufacturer / operator partners: where required to complete pairing, warranty, firmware distribution or after-sales service for the specific charger you have bound.
• Other users you authorise: if you share your private charger with another user through the "Sharing" feature, your pile identifier and permitted operations are visible to that user.
• Authorities: where disclosure is required to comply with applicable law, a valid legal request, or to protect rights, safety and property.
• Corporate transactions: in a merger, acquisition or reorganisation, subject to equivalent privacy protections.

6. International Data Transfers

Your data may be processed on servers located in the country or region where the Operator provides the Services and, for global support, may be transferred to affiliated entities or processors outside the European Economic Area (EEA). Where such transfers occur, we rely on appropriate safeguards under GDPR Chapter V, such as the European Commission's Standard Contractual Clauses (SCCs) and, where relevant, supplementary technical and organisational measures.

7. Data Retention

• Account data is retained while your Account is active. When you request Account deletion, the Account and associated personal data are deleted or anonymised, except data that must be retained for a stated legal, security, fraud-prevention or dispute-resolution obligation.
• Charging orders, telemetry and server-side security records are retained under our documented retention schedule for no longer than necessary for the purposes described in this Policy and any mandatory legal period.
• Local diagnostic logs use a rolling size limit and remain on your device in the current production build. You can remove local data by clearing App data or uninstalling the App.

8. Security

• Production API traffic is protected in transit using HTTPS.
• Bluetooth communication with the charger is protected by AES-based application-layer encryption.
• API requests carry an authentication token and are subject to server-side authorisation checks.
• We use access controls and other technical and organisational measures appropriate to the Services.

No method of transmission or storage is 100% secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority and, where required, affected users without undue delay.

9. Your Rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Erase your data ("right to be forgotten"), including by cancelling your account in the App.
• Restrict or object to certain processing.
• Data portability, where technically feasible.
• Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
• Lodge a complaint with your local data protection supervisory authority.

You can request Account deletion in the App under Profile > Delete Account. You may exercise other rights, or request deletion when you cannot access the App, by contacting us as described in Section 13. We will respond within one (1) month of receipt of your request, subject to extensions permitted by law.

10. Cookies and Similar Technologies

The App is a native mobile application and does not use browser cookies. Certain embedded web pages (such as this document) may use only strictly necessary local storage to render content correctly.

11. Children's Privacy

The Services are not directed to children under 16. If you believe a child has provided personal data to us without appropriate consent, please contact us and we will take steps to delete the data.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in the Services, technology or legal requirements. Material changes will be notified through in-App messages or by other appropriate means before they take effect. Continued use of the Services after an updated Policy comes into effect constitutes acceptance of the changes.

13. Contact Us

If you have any questions, requests or complaints regarding this Policy or the processing of your personal data, please contact us:

• App: ChargeN
• Support Email: support@csg-enlink.com.cn
• Website: http://csg-enlink.com.cn

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