Privacy Policy

1. Who This Policy Applies To

This Privacy Policy applies to:

• All WattsApp customers, users, and account holders; and
• All information collected through the Platform, including data collected via connected devices, APIs, and third-party integrations.

This Policy works alongside our contractual agreements and does not limit our ability to share information when required by law or regulation, including under Canada’s Clean Fuel Regulations (CFR).

2. Information We Collect

We collect only the information needed to operate the Platform, support regulatory compliance, and provide our services.

a) Charging & Energy Data

When you connect charging equipment to WattsApp, we may collect:

• EV charging session details (energy delivered in kWh, start/end times, charger identifiers);
• Electrical consumption and load data;
• Metering and device telemetry;
• General charger location information (such as city or province, or site-specific data where required).

b) Account & Equipment Information

We may collect:

• Vehicle identifiers (such as VINs);
• Charger serial numbers or device IDs;
• Account authentication tokens;
• Contact details (name, email address, phone number);
• Business or site ownership information.

c) Technical & Usage Information

To keep the Platform secure and reliable, we may collect:

• IP addresses;
• Browser or device type;
• Session timestamps and access logs;
• General Platform usage and diagnostics data.

3. How We Collect Information

Information is collected through:

• EV charger manufacturer APIs;
• OCPP-enabled charging stations;
• Current transformers (CTs), gateways, and metering devices;
• Information you provide directly (forms or uploads);
• Automated system logs and monitoring tools;
• Trusted third-party service providers that support our Platform.

4. Why We Use This Information

We use your information for four main reasons:

a) Regulatory Compliance

A core purpose of WattsApp is participation in Canada’s Clean Fuel Regulations (CFR). Information is used to:

• Quantify and verify charging activity;
• Support audits and credit verification;
• Respond to regulatory inquiries or investigations.

b) Platform Operations

We use information to:

• Operate, maintain, and improve the Platform;
• Monitor performance and reliability;
• Provide customer support and account management.

c) Commercial & Program Purposes

Where applicable, information may be used to:

• Calculate incentives, rebates, or payments;
• Perform internal reporting and analysis;
• Develop aggregated or anonymized datasets.

d) Legal & Risk Management

Information may also be used for:

• Fraud prevention and security monitoring;
• Dispute resolution;
• Enforcing our agreements;
• Meeting legal obligations.

5. When We Share Information

a) Regulatory & Government Disclosure

We may share information with:

• Environment and Climate Change Canada (ECCC);
• Other government authorities with jurisdiction;
• Accredited auditors or verification bodies.

Some disclosures are mandatory under law and do not require additional consent.

b) Service Providers

We work with trusted third parties who help us operate the Platform, such as:

• Cloud hosting providers;
• Analytics and monitoring services;
• Verification and audit partners;
• Payment and communications providers.

These providers are required to protect your information and use it only to deliver services to WattsApp.

c) Aggregated & Anonymized Data

Where possible, data may be:

• Aggregated;
• De-identified or anonymized;
• Used for analytics, benchmarking, or commercial insights.

Anonymized data cannot reasonably be used to identify you.

6. Data Ownership vs. Personal Information

• Operational and aggregated charging data (including analytics and regulatory datasets) are owned by WattsApp for CFR participation and business purposes, subject to applicable law.
• Personal information is handled in accordance with this Privacy Policy and Canadian privacy legislation.

7. Where Data Is Stored

Information may be stored or processed in:

• Canada;
• The United States; or
• Other jurisdictions where WattsApp or its service providers operate.

Data stored outside Canada may be subject to foreign laws and lawful access requests by authorities in those jurisdictions.

8. How Long We Keep Information

We retain information:

• Only as long as necessary to support the purposes described above; and
• For at least seven (7) years where required for CFR compliance, audits, or legal obligations.

Some information cannot be deleted on request if retention is legally required.

9. Your Rights

Subject to applicable law, you may request:

• Access to your personal information; or
• Corrections to inaccurate information.

Requests may be limited or declined where:

• Disclosure would compromise regulatory compliance;
• Information has been aggregated or anonymized;
• Retention is required by law.

We may verify your identity and charge reasonable administrative fees where permitted.

10. Cookies, Logs, and Similar Technologies

WattsApp uses limited cookies, session identifiers, and server logs to:

• Enable secure log-in and authentication;
• Ensure Platform functionality and reliability;
• Detect fraud and security issues.

We do not use these technologies for advertising or cross-site tracking unrelated to Platform operations.

Disabling cookies may limit access to certain features.

11. Consent & Withdrawal

By using the Platform, you consent to the collection, use, and disclosure described in this Privacy Policy.

If you withdraw consent:

• Some Platform features may no longer work;
• Your access may be suspended or terminated;
• Previously collected data and data required by law may still be retained.

12. How We Protect Your Information

We use industry-standard safeguards, including:

• Administrative controls (policies and access restrictions);
• Technical protections (encryption, authentication, monitoring);
• Physical security measures.

No system is completely secure, and residual risk remains.

13. Disclaimers & Liability

WattsApp does not guarantee:

• Absolute security;
• Error-free operation; or
• Protection against all unauthorized access.

To the extent permitted by law, WattsApp is not responsible for privacy breaches unless caused by our gross negligence or wilful misconduct.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted with a revised “Last Updated” date. Continued use of the Platform means you accept the updated policy.

15. Contact Us

If you have questions or requests about privacy, contact:

16. Prevailing Terms

If there is any conflict between this Privacy Policy and another agreement, the provisions that allow regulatory compliance and disclosure will prevail.