Greenspot JC, LLC Privacy Policy

Effective Date: September 30, 2019

Greenspot JC, LLC (“us”, “we”, “our”, the “Company” or “Greenspot”) provides the services available on the
joingreenspot.com website (and any other Company website), the Greenspot Cloud Subscription Service and the
downloadable, mobile, Greenspot Network Application (collectively, the “Services” or “Service”), which allows you to
charge your vehicle on any electric vehicle service equipment (an “EVSE” or “Charging Station”) that has been
commissioned onto our Greenspot Cloud Network.
This Privacy Policy (“Privacy Policy” or “Policy”) informs you of our privacy practices and policies regarding the
collection, use and disclosure of Personal Information, Financial Information, Transaction History, Usage Data and Log
Data when you use our Service. We will not use or share your information with anyone except as described in this
Privacy Policy. When we collect personal information on joingreenspot.com, any Company website or Service, certain
additional disclosures, that are specific to the context of our collection and use of the information being collected (e.g.
an event or information request page), may be provided to you. For the avoidance of any doubt, we will adhere to those
commitments and any such additional privacy policy statements are hereby incorporated into this Privacy Policy.
By signing up to use our Service, and opting-in to our uses of your information, you agree to the collection and use of
information in accordance with this policy (the “Privacy Policy”).

Information Collection

Personal Information

When you sign-up for our Service, and while using our Service, you may provide us with certain personal and personally
identifiable information that can be used to contact or identify you. We collect personal information such as the make
and model of your vehicle and your geolocation and personally identifiable information such as your name, your email
address, your phone number and your postal address (collectively “Personal Information”).

Financial Information

When you sign-up for our Service, and while using our Service, you may also provide us with credit card information,
such as your credit card account number, expiration date, CSV and address (“Financial Information”).

Transaction History 

In the event our Service is used to process a credit card transaction, we will collect the date and amount of each
transaction, which will be associated with the last four digits of the credit card you utilized (collectively “Transaction
History”).

Usage Data

When you use our Services to charge a vehicle, we will collect usage data, such as the time and location of the charge,
duration of the charge, and amount paid for the charge (“Usage Data”).

Log Data

We may also collect information that your browser sends whenever you visit or use our Service, as well as any other
generic user information through the use of commonly-used information-gathering tools, such as cookies and Web
beacons (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address,
browser type, browser version, the type of mobile phone you are using to access our Service, the operating software
and firmware used by your mobile phone, the pages of our Service that you visit, the time and date of your visit, the
time spent on those pages and other data generated from cookies (see the Cookies section below for more information).

Use and Retention of Information

We collect Personal Information for the purpose of providing the Service, identifying and communicating with you,
responding to your requests/inquiries, servicing your account, improving our services, and to the extent you have not
opted-out, (i) contacting you with information about our Services and offers, and (ii) contacting your via text message
with updates about your charging session.
We will only retain your Personal Information and other Data for as long as necessary to fulfill the purposes we collected
it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
For clarity, retention periods may be extended if we are required to preserve your information or data because of
litigation, investigations and other similar proceedings, or if a longer retention period is required or permitted by
applicable law.
We collect Financial Data to charge you for your electric vehicle charging sessions, but we do not store or retain any
of your Financial Information, except for the last four digits of your credit card. Your Financial Information is processed
directly by the applicable third party processor through an API integration.
We collect your Transaction History so that we can accurately track the charges we have made to your credit card, so
that we can document our revenue and answer questions you may have in connection with any charges made to your
credit cards.
We collect Usage Data to analyze electric vehicle use. Usage Data may also be combined with data obtained about
the make and model of your vehicle and your geolocation and this combined information may be shared or sold to third
parties. We do not sell personally identifiable information.
We collect Log Data for the purpose of providing and improving the Service, and, as described in this Privacy Policy,
to advertise and send other communications to you.

We may link or combine the Personal Information we collect and/or receive about you and the Log Data we collect
automatically during your visit to our website or use of certain of our Services. This allows us to provide you with a
personalized experience and helps us to continually work to improve our Services.
Greenspot has separate agreements with the property owners of each location that uses our Greenspot Cloud
Subscription Service to make their EVSE available for your use (“Charging Site Hosts”). Charging Site Hosts have the
ability to set the prices for our Services on their EVSE and will have access to your Transaction History and Usage
Data when you use the EVSE located on their property. Except to the extent the Charging Site Host has established a
user group with special privileges, such as Charging Site Host employees that sign up for the Service with their
designated company email (in which case the Charging Site Host will be able to verify your Transaction History and
Usage Data in connection with your special user group status), none of the information shared with Charging Site Hosts
is Personal Information (as described in this Policy) that, itself, can be used to contact or identify you. If you have any
questions about the data practices of a Charging Site Host using our Services to process or obtain access to your
information or data, you need to contact the Charging Site Host directly, and ask for their Privacy Policy or Privacy
Statement. Certain Service functionalities allow Users to report issues regarding Charging Stations and Charging Site
Host locations. You acknowledge and agree that Greenspot may share any such information or material (e.g. photos)
you provide, including any Personal Information therein, with the applicable Charging Site Host.
Greenspot has separate agreement with municipalities and governmental agencies for when Greenspot has Charging
Stations in the public right of way or on public property. Greenspot is subject to legal requirements in certain jurisdictions
in which it operates that require Greenspot to collect, process, disclose and retain certain Charging Station data from
Greenspot users such as but not limited to Charging Station utilization, types of vehicles charging, and the duration of
charging. Greenspot uses your information to comply with such legal requirements to the extent they apply to your use
of Greenspot’s application.

Third Party Data Processors

Greenspot engages certain third parties that may process data submitted to Greenspot to perform certain business-
related functions and to increase the functionality of our Services. These companies provide various services to us,

such as processing of payments and monitoring and analyzing how our Services are used or performing. When we
engage another company to perform such functions, we may provide them with information, including Personal
Information, Financial Information, Transaction History, Usage Data and Log Data in connection with their performance
of such functions. These third parties may analyze the data we provide, combine that data with publicly available data,
and provide us with access to their analysis and reports. These subprocessors are listed below, as may be updated by
Greenspot from time to time:

● EV Connect, Inc.
● PayPal, Inc. (Braintree)
● Apple Inc. (Apple Pay)
● Google LLC (Google Pay, Google Analytics, Google AdWords, Crashlytics, Fabric and Firebase)
● Amazon Web Services, Inc.
● The Rocket Science Group LLC dba MailChimp
● Twilio Inc.
● ZenDesk, Inc.

● Bugsnag Inc.

To the extent these third parties have access to any of your data, and especially your Personal Information or a
combination of data that is deemed to be personally identifiable, please know that they are contractually (i) limited to
only use this data to perform specific tasks on our behalf and (ii) obligated not to disclose or use your information for
any other purpose.
For your information, Google LLC recommends installing the Google Analytics Opt-out Browser Add-on –
https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides
visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information
on the privacy practices of Google, please visit the Google Privacy & Terms web page:
https://www.google.com/intl/en/policies/privacy/

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to
your browser from a web site and transferred to your device. We use cookies to collect information in order to improve
our Services and provide you with the best user experience possible. The third-parties we work with may also use
cookies to help us analyze how our users are using the Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most
browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.
If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you
leave them turned on.

Behavioral Remarketing
Greenspot may use Google AdWords to advertise to you on third-party web sites after you have visited or used our
Service. We, and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to
our Service.
Google AdWords remarketing service is provided by Google LLC. You can customize the Google Display Network ads
by visiting the Google Ads Settings page: https://adssettings.google.com/authenticated

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials, charging
status notifications, and other information that may be of interest to you. If you do not want to receive such messages
from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details.
For the purpose of clarification, in jurisdictions which require an opt-in for such communications, you will not receive
such communications unless you have affirmatively opted-in. You may also opt out of receiving any, or all, of these
communications from us by updating your preferences from your account page or following the unsubscribe link or
instructions provided in any email we send or by contacting us.

Compliance With Laws
We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action
is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity
of our Service or when requested by governmental authority in regards to our Charging Stations in the public right of
way or on public land.

Your Rights in Respect to Your Personal Information
Users who wish to correct, update, change, or erase the Personal Information they submit to the Service should be
able to go back into the applicable account page to edit the submitted information. For your information, in accordance
with certain, possibly applicable, privacy laws, you may have the following rights in respect of your Personal Information
that we hold:

● Right of access and portability. The right to obtain access to your Personal Information along with certain
information, and to receive that Personal Information in a commonly used format and to have it ported
to another data controller.
● Right to rectification. The right to obtain rectification of your personal information without undue delay
where that personal information is inaccurate or incomplete.
● Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in
certain circumstances, such as where the Personal Information is no longer necessary in relation to the
purposes for which it was collected or processed.
● Right to restriction. The right to obtain the restriction of the processing undertaken by us on your
Personal Information in certain circumstances, such as where the accuracy of the Personal Information
is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
● Right to object. The right to object, on grounds relating to your particular situation, to the processing of
your Personal Information, and to object to processing of your Personal Information for direct marketing
purposes, to the extent it is related to such direct marketing.

For additional information, assistance with any problems accessing your information or if you wish to exercise one of
these rights, please contact us at support@joingreenspot.com.
Upon request, we will provide you with information about whether we hold any of your personal information. Again, you
may access, correct or request deletion of your personal information by logging into your account, or by contacting us.
We will respond to your request within 30 days.

Business Transaction

Greenspot may share your Personal Information or Data with Company affiliates for the purpose of any necessary
collaboration. In addition, if Greenspot JC, LLC. is involved in a merger, acquisition or asset sale, your Personal
Information and Data may be transferred as a business asset. In such cases, we will provide notice before your Personal
Information is transferred and/or becomes subject to a different Privacy Policy.

Security
The security of your Personal Information is important to us, and we strive to implement and maintain administrative,
technical, and physical security measures appropriate to the nature of the information we store, in order to protect it
from unauthorized access, destruction, use, modification, or disclosure.
However, please be aware that no method of transmission over the internet, or method of electronic storage is 100%
secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer

To facilitate Greenspot’s global operations, we may store, transfer and access the information and personal data you
submit to our Services around the world, including the United States, Canada and other countries in which Greenspot
or its third party service providers have operations. This Privacy Policy shall apply even if Greenspot transfers such
information or personal data to other countries. By consenting to this Privacy Policy and using our Services (or, for the
avoidance of any doubt, providing information or personal data to us on any Company website in any other context),
you consent to the transfer of your information and personal data among these facilities, including those located outside
your home country.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing
adequate protection for the transfer of personal data to recipients in countries outside of the EEA. In all such cases, we
will only transfer your personal data if:

● The country to which the personal data will be transferred has been granted a European Commission
adequacy decision;

● The recipient of the personal data is located in the U.S. and has certified to the EU-U.S. Privacy Shield
Framework; or
● We have put in place appropriate safeguards with respect to the transfer, for example the EU Model
Clauses.

You may request a copy of the safeguards that we have put in place in respect of any applicable transfers of personal
data by contacting us as described in the Contact Us section below.
For the avoidance of any doubt, if you are located outside United States and choose to provide information to us, please
note that our current practice is to transfer the information, including Personal Information, to United States, where it is
processed. Your consent to this Privacy Policy followed by your submission of such information represents your
agreement to that transfer.

Your New Jersey Privacy Rights
As already stated elsewhere in this Privacy Policy, and in accordance with New Jersey STAT 56 §§ 11-53 – 11-55,
please know that Greenspot does not disclose personal data collected on the Service to third parties for their direct
marketing purposes. Greenspot abides by New Jersey STAT 56 §§ 11-53 – 11-55.

Children’s Privacy
Only persons age 16 or older have permission to access our Service. Our Service does not address anyone under the
age of 13 (“Children”).
We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian
and you learn that your Children have provided us with Personal Information, please contact us. If we become aware
that we have collected Personal Information from a children under age 13 without verification of parental consent, we
take steps to remove that information from our servers.

Changes To This Privacy Policy
This Privacy Policy is effective as of September 30, 2019 and will remain in effect except with respect to any changes
in its provisions in the future, which will be in effect immediately after being posted.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy
periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will

constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy
Policy.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have
provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us support@joingreenspot.com.
For our Canadian users, please know that this Policy is made under the Personal Information Protection and Electronic
Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too
detailed to set out here. There are some rare exceptions to the commitments set out above. For more general inquiries,
the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the
private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The information and Privacy
Commissioner can be reached at:

Address: 112 Kent Street, Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-Free: (800) 282-1376
Facsmile: (613) 947-6850
TTY: (613) 992-9190
Website: www.priv.gc.ca/en/

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