SMART EV

PRIVACY POLICY

Compliant with the Protection of Personal Information Act 4 of 2013 (POPIA)

Last reviewed: April 2026

1. Who Are We?

This privacy policy applies to Smart EV, which is a business operated by Smart EV (Pty) Ltd, registration number 2025/228053/07, with its registered address at 223 The Quays, 8 Park Lane, Century City, 7441, South Africa.

Smart EV is committed to providing our customers with excellent service. We recognise that customers value their data and privacy, and we treat customer data with the utmost care. This policy sets out how and when we collect, use, and share your personal information that you, or others, provide to us.

For the purposes of the Protection of Personal Information Act 4 of 2013 (POPIA), Smart EV is the responsible party in relation to your personal information.

If you have any questions regarding this policy, please contact our Information Officer by email at info@smartev.group, or you can use any of the contact methods listed on our website at www.smartev.group.

2. How Do We Collect and Use Your Data?

We only collect and process personal information about you where we have a lawful basis for doing so under POPIA. This section sets out how we collect and use your personal information.

It is important that you keep your personal information with us up to date, so please let us know if anything changes.

When you purchase products or services from our website or apps

When you take products or services from us, we will use your personal information to complete your transaction. The details we collect from you (or your fleet administrator) may include your name, address, email address, account password, your vehicle’s details (such as its make, model, registration number, and vehicle identification number or VIN), and payment details such as credit or debit card information or debit order details.

We need to process your personal information in this way to enter into and perform the contract for the product or service you (or your employer) have asked us to supply to you. This processing is justified under Section 11(1)(b) of POPIA (contractual necessity).

When you email or contact us via in-app chat or on social media

When you email or contact us via in-app chat with general queries, we may process your personal information including your name, address, contact details, and other personal information you have provided to us in order to deliver the services you have requested.

We rely on your consent to handle your personal information in this way. If you do not provide us with the information we request for customer service purposes, we may not be able to fully answer your queries.

We may also log and record the interactions you have with us, such as email opens and click-throughs, to help us better service your requests.

Marketing communications

This section applies if you have opted in to receive marketing communications from us, or have previously expressed an interest in our products and services and have not opted out. We may process your personal information including your name, address, contact details, and other personal information you have provided to us, in order to send you marketing communications in line with any preferences you have told us about.

Where you have opted in to receive marketing communications, we rely on your consent to contact you for marketing purposes. If you have not opted in and we send you marketing communications, we do so on the basis of our legitimate interest to promote the products and services you have expressed an interest in. This may include sending you information about discounts and offers from our charge point operator partners, which you can access via the App.

Every marketing communication we send will contain instructions on how to unsubscribe, or you can contact us at any time at support@smartev.group.

We never share your personal information with any third parties for their direct marketing purposes without your consent.

Third-party platforms

We may sometimes provide personalised advertising via third-party platforms. For example, we may hash your personal information (so it cannot be viewed) and reference it against information on platforms such as Facebook or Google.

We do this on the basis of legitimate interest to ensure that you receive more tailored and relevant information about our products and services.

To make our website or apps better and more secure

We may use your personal information to provide you with a more effective user experience, such as by displaying services we think you will be interested in. We also share aggregated, anonymised information with third-party analytics and search engine providers that assist us in the improvement and optimisation of our website and apps.

We will use your personal information for the purposes of administering our website and apps and making them more secure, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. We process your personal information for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our website and apps are kept secure.

Technical information and analytics

When you visit our website, we may automatically collect technical information including the IP address used to connect your device to the internet, your login information, browser type and version, time zone setting, screen resolution, operating system, and platform.

We may also collect information about your visit, including URLs, clickstream data, page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).

When you use our apps, we may automatically collect technical information including the number of users, session duration, operating system, device model information, IP address, and the occurrence of software bugs.

We may also collect location data when you access our website or apps, in line with the location settings on your device. This can be disabled via your device settings.

Electric vehicles and charge points

If you sign up for access to electric vehicle charge points through Smart EV, we will collect information about your consumption (including charge point location) as well as your name, address, and vehicle information (such as vehicle make/model, licence plate number, and state of charge) in order to accurately bill you. We receive your consumption data from the charge point operator, which we process to calculate charges for your account.

Product and service development

We are always looking for ways to make e-mobility better, for both our customers and for South Africa. We sometimes process your information where we have a legitimate interest for doing so, for example:

       To better understand our customer demographic and create more relevant campaigns, products, and services.

       To make predictions about future behaviour based on current behaviour, to help develop and tailor our products and services.

       To build a profile for you, so we can show you products and services of particular interest and relevance to you.

       For data analysis, testing, research, statistical, and survey purposes.

Information we receive from third parties

If you use our electric vehicle charge point services, we may receive your location data in line with the location settings on your phone when you use our mobile app. This can be disabled via your device settings.

Charge point operators will share relevant identification data (such as RFID card hex codes or digital tokens) of customers using our services. We use this information to locate your account and process your bills.

Vehicle databases may also provide us with details of vehicle make, model, battery capacity, range, and other relevant information.

Automated decision-making

We may use automated decision-making processes to enhance your experience with our services. For example, our system may review certain criteria to determine whether a pre-authorisation charge will be held on your card when starting a charging session. The logic may consider factors such as your charging location, your email domain, your IP address, and your previous payment history with us.

Under POPIA, you have the right not to be subject to a decision based solely on automated processing that significantly affects you. If you believe an automated decision has had such an impact, you have the right to request human intervention, to express your point of view, and to contest the decision. To exercise these rights, please contact us using the details provided in the “Contact Us” section of this Privacy Policy.

3. Sharing Your Information

Where we share your personal information with any third parties, we always do so in line with this privacy policy and in compliance with POPIA. We also ensure that these third parties only use your personal information in line with our instructions. Some of the organisations we may share your personal information with include:

       Our group companies, where necessary for the provision of our services.

       Payment providers to help us process your payments.

       Debt collectors where we have a legitimate interest to recover sums owed to us.

       Electric vehicle charge point operators and associated parties necessary to communicate your usage data where you use our charging network services.

       Where an RFID card is used, we may share your name and postal address with third-party RFID card providers.

       Third-party service providers where required to deliver a service to you or your employer.

If our business is sold

We may transfer your personal information if we sell or buy any business or assets, or if Smart EV or the majority of its assets are acquired by another party. In such cases, your personal information will be transferred to the buyer in accordance with POPIA.

Where we have a legal obligation

In some circumstances, we may need to share your personal information if we are under a duty to disclose or share it to comply with a legal or regulatory obligation, for example to investigate theft or fraud.

4. Cookies

A cookie is a small file of letters and numbers that we store on your device. Cookies are an essential and widely used tool that enable our website to function properly and efficiently, and provide us with helpful information about how people use our website.

Our website uses cookies to distinguish you from other users, provide you with a good user experience, keep your visit secure, and allow us to improve our website.

Third parties (including advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we do not have control over.

Cookie preferences

You can manage your cookie preferences on our website at any time. We group our cookies into three categories:

       Essential: Necessary cookies that are required for our website to function properly.

       Analytics and customisation: Cookies that help us understand how our customers use our site, so we can build better features.

       Marketing and social media: Cookies that help us reach you on social media or other websites.

You can block cookies by activating the setting on your browser that allows you to refuse cookies. However, if you block all cookies, you may not be able to access all features of our website.

5. Where Is My Personal Information Stored?

Smart EV is headquartered in South Africa. As a business, we may store data we collect from you outside of South Africa, or transfer it to organisations outside South Africa.

Whenever we transfer your personal information outside of South Africa, we will ensure that it is protected as required by POPIA. In particular, Section 72 of POPIA requires that cross-border transfers of personal information only take place where the recipient country has adequate data protection laws, or where we have appropriate contractual safeguards in place.

You can contact us at support@smartev.group for details of how we protect specific transfers of your personal information.

6. How Long Do We Retain Your Data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, regulatory, accounting, or administrative requirements. In accordance with POPIA, we will take reasonable steps to destroy or de-identify personal information once it is no longer needed for the purpose for which it was collected.

7. What Are My Rights Under POPIA?

Under POPIA, you have the following rights, which you can exercise by contacting our Information Officer at info@smartev.group:

Right to object

The right to object to the processing of your personal information where we are processing it based on our legitimate interests. You can also ask us to stop processing your personal information for direct marketing purposes at any time (Section 11(3) of POPIA).

Right of access

The right to request access to your personal information and to be told what personal information we hold about you (Section 23 of POPIA).

Right to rectification

The right to request the correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully (Section 24 of POPIA).

Right to restriction

The right to request that we restrict processing of your personal information in certain circumstances.

Right to erasure

The right to request the destruction or deletion of personal information that we are no longer authorised to retain (Section 24 of POPIA).

Right to complain

If you have queries or concerns, please contact us using the details below. If you remain dissatisfied, you have the right to lodge a complaint with the Information Regulator of South Africa.

Information Regulator (South Africa)

Website: https://inforegulator.org.za

Email: complaints.IR@justice.gov.za

Rights in relation to automated decision-making

The right not to be subject to a decision based solely on automated processing of your personal information that significantly affects you, and the right to request human intervention in such decisions.

8. What About Websites We Link To?

Our website and apps may contain links to third-party websites. If you click on a link to any of these websites, you will leave our website or app and this may allow third parties to collect or share your data. We have no control over the contents of those third-party websites and will not accept any responsibility or liability for any materials on them. We encourage you to check their privacy policies before submitting any personal information.

9. Our Websites and Services Are Not Intended for Children

Our websites and services are meant for adults. We do not knowingly collect personal information from children under 18. If you are a parent or legal guardian and believe your child has provided us with personal information, please contact us using the details set out below. In accordance with POPIA, we recognise that the personal information of children requires additional protection.

10. Protection of Personal Data

We have appropriate technical and organisational measures in place to safeguard the personal data you provide from unauthorised access, loss, or misuse, as required by Section 19 of POPIA. These measures include access controls, encryption of data in transit and at rest, regular monitoring, and secure third-party partnerships. We also apply data minimisation and retention practices while maintaining an incident response process to manage and report any data breaches to the Information Regulator where required under Section 22 of POPIA.

11. Updates and Contact

We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

Please check back frequently to see any updates or changes to our privacy policy.

Contact Us

Information Officer: Holly Watt

Email: info@smartev.group

Address: 223 The Quays, 8 Park Lane, Century City, 7441, South Africa

Website: www.smartev.group

Support: support@smartev.group