myChargepoint Apps Privacy Policy

myChargepoint by Infra Tenaga EV Sdn Bhd. (with the principal place of business at No 32, Aras 1, Jalan Kota Raja E27/E, Hicom Town Centre, Seksyen 27, 40400 Shah Alam, Selangor, Malaysia. (“we,” “us,” “myChargepoint,” “our”, or the “Company“) takes your privacy very seriously and has created this Application Privacy Policy (the “Privacy Policy”) to inform you on how we process your personal information when you use the myChargepoint Charge or myChargepoint Config Applications (the “APP“).

This Privacy Policy will explain to you how the APP collects, uses, and stores your personal information and the rights and choices you have. Please be sure to read and fully understand the terms of this Privacy Policy, especially those that exclude or limit liability, which may be brought to your attention in bold or other forms. Unless you have read and accepted all of the terms of this Privacy Policy, you are not authorized to use the APP.

This Privacy Policy applies to the services of the APP itself and does not apply to products or services provided by any other third party through the APP (“Third-party Services”). You should fully understand the product functions and privacy policies of the third-party services before choosing to use them.

(A) WHAT INFORMATION DO WE COLLECT?

We may need you to provide personal information to us directly, in which case you are generally free to choose which personal information you want to provide us. However, if some personal information is required for the performance of our Service and you choose not to provide that personal information, we may not be able to provide you with the Service you requested. Personal information we directly collect from you may, for instance, include the following:

 

1. Personal information required for user registration

When you log in and register an APP account for the first time, you are required to provide us with information including but not limited to:

  • Name
  • Country and Region
  • Email address
  • Phone number

The above information is necessary for you to use the APP. If you do not provide such information, you will not be able to use the APP service normally.

 

2. Personal information required to provide services

2.1 Equipment Information

According to your device model and permission granted during installation and use of the APP, we may collect and use your device-related information:

  • Device model
  • Unique device identifier
  • Operating system
  • Software version
  • Network status
  • IP address
  • Time stamp
  • Time zone
  • Country code
  • Telecom operator

2.2 Location Information

When you use location-related services, such as charger sharing, we collect your location information and provide such services based on your location. When you enable the device location function and use services such as sharing, we may collect and use your location or charging device location information.

Please note that most mobile devices allow you to turn off location-based services. Once you turn off location-based services, we will stop collecting your location information and you may not be able to use our location-based services for you.

2.3 Log Information

When you use the APP, we will automatically collect the details of your use of the App and save them as relevant network logs, including but not limited to:

  • IP address
  • Browser type
  • Language used
  • Date and time of access
  • Connection status
  • Charger status
  • Charging record and
  • Your request record

2.4 Device Invoked Information

We may invoke some of your device permissions according to the different functions you use. The following is the function used by the invoking permissions, the purpose for which we invoke the permissions, and the information we asked you before invoking the permissions. You can disable some or all permissions in the Settings function of the device to deny permission calls.

Permission Purpose Whether to ask open
Camera
Scan the QR code of the charger to start charging
Yes
Bluetooth
Connect the phone to the charger via Bluetooth
Yes
Location
Search nearby chargers based on location
Yes

(B) HOW WE USE THE INFORMATION WE OBTAIN

We may process your personal information, with your consent and for the purposes stated in this Privacy Policy, when we need to fulfil our obligations to you under the user agreement and/or service contract, other legally binding obligations, or when we believe that such processing is required to protect the legitimate interests of ours or third parties after evaluation. We will use your personal information in strict accordance with this Privacy Policy and its updated content for the following purposes:

  • Manage and improve the content of the APP and/or Services and enhance your experience;
  • Provide the APP and/or Services, including but not limited to the facilitation of service;
  • Send correspondence about the APP and/or Services, including by sending you information regarding changes to our policies, terms, and conditions, as well as other information, including newsletters, announcements, information about us, special offers, or promotional materials on our behalf or behalf of third parties;
  • Analyze trends and statistics;
  • Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving the APP and/or the Services; managing and evaluating the effectiveness of our communications; and performing other internal functions);
  • Enforce this Privacy Policy, User Agreement, and any other terms that you have agreed to;
  • Maintain and enhance the safety and security of the APP and/or Services and prevent misuse;
  • Process billing functions, including payment fees;
  • Communicate with you regarding the Service or enable you to communicate with other users;
  • Comply with and enforce applicable legal requirements, relevant industry standards and policies; and
  • Maintain and service accounts, provide customer service, verify customer information, process and complete payments and transactions on the APP and/or via the Service;
  • Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • Remember your information so you will not have to re-enter it; and
  • Allow and manage your participation in prize draws, contests or similar promotional activities held by us and
  • Pursue or defend against legal claims;
  • Otherwise manage and enhance the APP and/or Services.
  • Remotely analyze the faults and safety risks of chargers to improve the performance and user experience of chargers.

 

(C) HOW WE STORE THE INFORMATION

We have adopted industry-standard security measures to protect the personal information you provide and prevent unauthorized access, public disclosure, use, modification, damage or loss of data.

Our company will take all reasonable and practicable measures to protect your personal information. We will store personal information collected and generated within Malaysia in a server located within US in accordance with relevant laws and regulations. If the storage location of your personal information is transferred from Malaysia to overseas, we will strictly comply with relevant laws and regulations.

We will store your personal information according to the retention period stipulated by relevant laws and regulations. If laws and regulations stipulate different retention periods for the same kind of personal information, we will keep the maximum retention period, unless otherwise stipulated by laws and regulations.

In the absence of clear provisions of relevant laws and regulations, we will store your personal information for such a period as is necessary for the purpose of processing. We will keep your personal information for three years, calculated from the date when you terminate your use of the Application services. We judge that the storage period of personal information will be reasonably assessed and determined based on risk control, security, business management, national and industrial standards and other factors.

 

(D) WHEN WE SHARE YOUR INFORMATION

We do not share your personal information except as described in this Privacy Policy. We may share information collected about you in the following ways:

1. Share with associated companies or third parties

  • We may, from time to time, share the information with affiliated companies. We will only share collected information that is necessary, and such sharing is restricted to the purpose stated in this Privacy Policy. If we or our affiliates change the use and processing purpose of personal information, we will ask for your authorization again.
  • In some cases, we will entrust a third party to process your personal information on our behalf. For example, companies that send text messages or emails and provide technical support on behalf of us. These companies can use your personal information solely to provide services to you on our behalf, however, you can also choose to disable certain “push notifications”.
  • When we are in a process of merger, acquisition or bankruptcy liquidation, and if such process involves a transfer of your personal information, we will require the new company or organization that shall hold your personal information to continue to be bound by the restrictions stated in this Privacy Policy, otherwise we will require this company or organization to ask your permission and consent again. If it does not involve the transfer of personal information, we will fully inform you and delete or anonymize all personal information under our control.

We will require the above-mentioned third parties to take appropriate confidentiality and security measures to process personal information through agreements or other appropriate means.

2. Necessary for the implementation of third-party services

In order to ensure the stable operation and functional realization of the APP and enable you to use and enjoy more services and functions, we will embed SDK or other similar applications of authorized partners into the APP according to the needs of product functional realization, and we will carefully evaluate the purpose and mode of use of third parties. Unless otherwise authorized by you or provided by laws and regulations, third-party SDK operators have no right to use your personal information for any other purpose.

3. Situations in which your prior consent is not required

3.1 Related to the performance of our obligations under laws and regulations;

3.2 Directly related to national security and national defence security;

3.3 Directly related to public safety, public health, and significant public interest;

3.4 Directly related to criminal investigation, prosecution, trial, and sentence enforcement;

3.5 Difficult to obtain authorized consent but must safeguard the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals;

3.6 Personal information that the subject of personal information discloses to the public on his own;

3.7 Collection of personal information from legally publicly disclosed information, such as news reports, government information disclosure, etc.

 

(E) YOUR RIGHTS WITH RESPECT TO THE PERSONAL

We respect your right to your personal information. Below is a list of your legal rights as well as the measures that we take to protect these rights. Please note that, due to security reasons, we may verify your identity before processing your request.

  • Right to be informed: We publish this Privacy Policy to inform you of how we process your personal information. We are committed to being open and transparent about how we use your personal information.
  • Right to withdraw consent: To function properly, each service requires some basic personal information (please refer to the Section 1 of this Privacy Policy). For the collection and use of additional personal information, you can grant or withdraw your authorization and consent anytime. If you withdraw your authorization or consent, we will no longer be able to provide you with the corresponding service for which you have withdrawn your authorization or consent. If you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information based on your previous consent prior to the withdrawal. You may change the scope within which we are authorized by you to continue to collect personal information or withdraw your authorization by such action as deleting information or disabling device functions.
  • Right to know what personal information we have about you and request a copy of the same, and to ask us to make rectifications if you find that the personal data we process about you is inaccurate or incomplete.
  • You may also have further legal rights concerning your personal data, depending on the jurisdiction in which you are located. In this respect, please see the GDPR-specific section if you live in Europe.
  • Account cancellation: We fully guarantee your right to cancel your account and stop using this APP. When you need to cancel your account, you can click your profile picture and select “Delete account” to cancel your account, once the procedure is finished, your account will be deleted.

Please note that after the account is cancelled, you will no longer be able to use any service related to the APP or retrieve any content or information you browse, follow, add or bind. We will no longer retain any personal data of you.

If you wish to do any of the above, please send an email request to customercare@mychargepoint.com.my

In principle, we do not charge any fees if your request is reasonable. However, based on the actual situation, we may impose a certain fee to cover our costs for repeated requests or requests that extend beyond reasonable limits. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), may be detrimental to the legal rights and interests of others, or are very impractical. In addition, we may not be able to respond to your request if your request is directly related to matters involving national security, national defence, public health, criminal investigation and other public interests, or if the request may severely impair the legitimate rights and interests of yours or those of other individuals and organizations.

 

(F) PROTECTION OF PERSONAL INFORMATION

We have taken reasonable and feasible technical security and organizational measures to protect the information collected for the services. However, please note that while we have taken reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is absolutely secure.

We have adopted security measures that are in line with industry standards to protect the personal information you provide and to prevent alteration, public disclosure, misuse, modification, damage or loss of the data. We will take all reasonable and practical steps to protect your personal information, including:

  • We will use “Secure Socket Layers” or SSL to protect your data. We will regularly examine our practice of information collection, storage, and processing (including physical security measures) to prevent unauthorized system access.
  • The security of your information is of great importance to us. Therefore, we will continue our efforts to protect your personal information and implement safeguard measures, such as providing full encryption for information storage and transmission, to prevent your information from unauthorized access, usage or disclosure. For certain specific contents of encrypted data, no one but the user has the right to access them.
  • We will prudently select business partners and service providers, and implement the requirements for personal information protection to the business contracts or audits and assessments between both parties.
  • We will conduct security and privacy protection training courses, testing and publicity activities to enhance employees’ awareness of the importance of protecting personal information.
  • We will use international and industry-recognized standards to protect your personal information and actively pass relevant security and privacy protection certifications.
  • In the event of a personal information security incident, we will, in accordance with the requirements of relevant laws and regulations, promptly inform you of the following: the basic situation and possible impact of the security incident, disposal measures we have taken or will take, suggestions for your self-protection and risk mitigation, remedies for you, etc. We will timely inform you of the relevant situation of the event by email, letter, telephone, or push notification. When it is difficult to inform the personal information subjects individually, we will issue an announcement in a reasonable and effective manner. Meanwhile, we will also actively report the handling of the personal information security incident in accordance with the requirements of the regulatory authorities.

 

(G) THIRD PARTY SERVICE

In order to ensure the stable operation of the APP or to achieve the relevant functions, we may access the software development kit (SDK) provided by third parties to achieve the aforementioned purposes. We will conduct a strict audit of the SDKs from which the partners obtain personal information in order to protect the security of your personal information. The relevant third-party SDKs that we access are listed in the following directory. You can view the privacy policy of the third party through the relevant link.

Please note that the third-party SDKs to be accessed may vary depending on the APP version, such as the Android version and the iOS version. The details will be distinguished in the list. In addition, the personal information processing type of the third-party SDK may change due to the version upgrade or policy adjustment. Please refer to the official instructions published by the third-party SDK.

Third Party SDK List:

1. Sensors

Version

Android\iOS

Purpose

Data collection; Data analysis; User behavior analysis

Data Collection

Device manufacturer, Device brand, Device model, Operating system, Operating system version, Screen height, Screen width, Wi-Fi status information, Carrier name, Network type, Time zone offset, Device ID, Android ID, Operation record

Link

https://www.sensorsdata.cn/compliance/privacy.html

Incumbent Operators

Sensors Network Science and Technology(Beijing) Co., Ltd.

2. JPush

Version

Android\iOS

Purpose

Notification push

Data Collection

Device information, Android ID, Network information, Location information, Application information, Phone number, User chat information, APP application page information, APP application page, APP function event related information, User sharing information content

Link

https://www.jiguang.cn/license/privacy

Incumbent Operators

Shenzhen Hexun Huagu Information Technology Co., Ltd.

3. Xiaomi Push

Version

Android

Purpose

Notification push

Data Collection

Device information, device identifier

Link

https://dev.mi.com/console/doc/detail?pId=1822

Incumbent Operators

Beijing Xiaomi Mobile Software Co., Ltd.

4. HMS Core Push

Version

Android

Purpose

Notification push

Data Collection

Basic app information, in-app device identifier, device hardware information, basic system information and system settings

Link

https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/sdk-data-security-0000001050042177

Incumbent Operators

Huawei Software Technologies Co., Ltd.

5. OPPO Push

Version

Android

Purpose

Notification push

Data Collection

Device information

Link

https://open.oppomobile.com/wiki/doc#id=10288

Incumbent Operators

Guangdong HeyTap Technology Co., Ltd.

6. Vivo Push

Version

Android

Purpose

Notification push

Data Collection

Device information

Link

https://www.vivo.com.cn/about-vivo/privacy-policy

Incumbent Operators

Guangdong Telcheer Network Technology Co., Ltd., and the assignee of operating Vivo Developer Platform

7. NETEASE YIDUN

Version

Android\iOS

Purpose

Registration protection and Login protection

Data Collection

Device unique identifier, Device brand, Device name, Device model, Device system type, Detailed Settings and version information, Android ID, Device IP address, Router ID (BSSID, SSID, MAC) and IP address, Network operator information, Network connection status, End user boot, Click, Install behavior information, Sensor information

Link

https://dun.163.com/clause/privacy

Incumbent Operators

Hangzhou Netease Zhiqi Technology Co., Ltd.

8. Freshchat

Version

Android\iOS

Purpose

Instant communication

Data Collection

Device unique identifier, IP address, Language, Name and Email address when you provide feedback, Session start and end times, Browser type, Operating system

Link

https://www.freshworks.com/privacy/?utm_source=freshdesk&utm_medium=referral&/privacy

Incumbent Operators

Freshworks Inc.

9. Bugly

Version

iOS

Purpose

Provide exception reporting and operation statistics for mobile developers to quickly find and solve bugs

Data Collection

Log information, Device ID, Network information, System name, System version, Country code

Link

https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

Incumbent Operators

Shenzhen Tencent Computer Systems Company Limited

10. Amap

Version

Android

Purpose

Provide location services

Data Collection

Location information, Device information, Device identification information, Current application information, Device parameters, System information

Link

https://lbs.amap.com/pages/privacy/

Incumbent Operators

Amap Software Co., Ltd.

11. Google Maps

Version

Android

Purpose

Provide location services

Data Collection

Location information, Operating system version, Name, Model, brand, Appearance specifications, IP address

Link

https://policies.google.com/privacy?hl=zh-CN

Incumbent Operators

Google LLC

(H) HOW YOUR PERSONAL INFORMATION IS TRANSFERRED ACROSS BORDERS

In compliance with local laws and regulations and with your authorization, your personal information may be transferred to, or accessed from, the jurisdictions outside the country/region in which you use the product or service, to locations that may have different levels of privacy protection than in your own country.

You understand that different data protection laws involve different risks. In such cases, we will take measures to ensure that the data we collect is processed in accordance with this Privacy Policy and applicable laws, and that your personal information is equally protected in the country/region where you use the product or service. For example, we will ask your permission to transfer your personal information across borders, and we will implement security measures such as encryption, de-identification, and signing necessary data transmission/sharing agreements with data recipients prior to cross-border data transfer.

 

(I) CHILDREN’S PRIVACY

The Services are intended for persons licensed to drive. In Malaysia, this typically means individuals over the age of 17. We do not knowingly collect any information from anyone under 17 years of age. If you are less than 17 years of age, we request that you do not submit information to us. If we become aware that we have inadvertently collected “personal information” from children under the age of 13 without parental consent, we will take reasonable steps to delete it as soon as possible as required by applicable law.

 

(J) UPDATE OF THIS PRIVACY POLICY

Please note that we may modify this Privacy Policy at any time, at our sole discretion, by updating the modified policy directly. The modifications will be effective upon updating and releasing, unless some other date is specified. You should review this Privacy Policy periodically so that you are aware of any modifications. Your use of the App constitutes your full acceptance of the Privacy Policy in its then-current form.

For any update or revision of this Privacy Policy, we will show you the changed Privacy policy in the form of announcements, push notifications or pop-ups. If we make any changes to this Privacy Policy in accordance with applicable laws and regulations, we will notify you through appropriate ways and re-obtain your consent.

Changes within the meaning of this article include, but are not limited to:

  • Major changes have taken place in our service mode, such as the purpose of processing personal information, the type of personal information processed and the way of using personal information;
  • Major changes in our ownership structure and organizational structure, such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions;
  • The main object of personal information provision, transfer or public disclosure has changed;
  • Your rights to participate in personal information processing and the way in which they are exercised have changed significantly;
  • Our contact information and complaint channels have changed.

 

(K) QUESTIONS OR COMMENTS

If you have any questions, comments or concerns regarding this Privacy Policy and/or the practices described herein, please email us at customercare@mychargepoint.com.my