Effective Date:  22 day of 02 2022

PLEASE READ THE FOLLOWING CAREFULLY

THIS STATEMENT PROVIDES GENERAL INFORMATION ABOUT THE PRIVACY STATEMENT OF THIS PLATFORM. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE BE SURE TO READ THIS PRIVACY STATEMENT WITH YOUR PARENTS OR GUARDIAN AND ASK THEM QUESTIONS ABOUT WHAT YOU DO NOT UNDERSTAND.

This Privacy Policy is designed to be read in connection with the Platform’s Terms of Service. YOUR USE OF THIS PLATFORM AND SERVICE CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICE.

MARRS GROUP LLC  ( “MARRS GROUP LLC”, “Company”, “we”, “our” and “us”) has created this privacy statement (“Statement”) in order to demonstrate Our firm commitment to the privacy of the details that you provide to us when using Our mobile application Sited on Apple store and Android Play store and website at https://www.vroomcharge.com (collectively, the “Platform”), as the data controller for the purposes of the Pennsylvania Data Privacy Laws,  California Consumer Protection Act (CCPA), California Online Privacy Protection Act, (CALOPPA) and the EU General Data Protection Regulation (GDPR) 2016.

At MARRS GROUP LLC, we are committed to maintaining the trust and confidence of all Users of our Platform. In particular, we want you to know that the website is not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes.

We believe your business is no one else’s. Your Privacy is important to you and to us. So, we’ll protect the information you share with us. To protect your privacy, MARRS GROUP LLC follows different principles in accordance with worldwide practices for customer privacy and data protection.

–               We won’t sell or give away your name, mail address, phone number, email address or any other information to anyone.

–               We ‘ll use state – of – the – art security measures to protect your information from unauthorized users.

Therefore, to provide you with our services we need (and sometimes are obliged by the law) to collect your personal data. This Privacy Policy (the “Policy”) informs Users (a “User”, or “You”) of our policies regarding the processing of Personal Information we receive from Users of the site whether you are a visitor to our website, or a user of electric vehicle charging stations on our platform.

In this Privacy Policy, we’ve provided detailed information on when and why we collect personal information, how we use it, the limited conditions under which we may disclose it to others, and how we keep it secure.

We take your privacy seriously and take measures to provide all visitors and users of the website with a safe and secure environment.

 

1. INFORMATION WE COLLECT AND OBTAIN

We obtain personal information about you from a variety of sources. This includes personal information you provide to us directly, information we obtain from other sources, and information we gather through automated means. Please note that we need certain types of information to provide the Service to you. We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise. We collect personal information from you when you use our Services.

If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain parts of our Service.

Information you provide to us. When you visit or use the Platform, use the Service, register for an account, List your charger, connect with Owners/Drivers etc. or directly correspond with us, we collect certain types of information you provide directly to Us:

1. • Contact information (such as name, postal address, email address, location and telephone and/or mobile numbers);
   • Payment Information: when you want to complete a transaction via the platform
   • information about your vehicle (e.g. make, model, color)

• EV Charging data such charging session date, start time, end time, duration, identification number, energy dispensed, current, station location and voltage.

1. • Reviews, comments, and/or surveys on our media blog; and
   • Other information you may provide to us when you fill a form, such as through our “Contact Us” feature.

Information obtained from other sources. We may obtain personal information about you in connection with the Services from publicly and commercially available sources and from our affiliates and/or business partners (such as advertising networks or social networking services), including:

1. • Demographic data (such as gender, age range, educational level, household income range, number of children in household, ethnicity to the extent permitted);
   • Occupational data (such as profession, position, title, industry; and business address);

We may also collect information about you from non-affiliated third parties for fraud or safety protection purposes, or for marketing purposes. We likewise may combine information that we collect from you through the Service with information that we obtain from such third parties and information derived from any other products or services we provide.

Information Collected by Automated Means through Our Services. We may gather by automated means (such as cookies, web beacons, web server logs, JavaScript and other similar technologies) certain information through our Services:

1. • Your Internet Protocol (IP) address;
   • Device information, including unique identifiers and connection information, including mobile device advertising IDs (e.g., Apple’s IDFA or Google’s AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law;
   • Your device type and settings, software used, browser type and operating system;
   • Websites or other services you visited before and after visiting the Platform (referring URL);
   • Web pages and advertisements, you view and links you click on within, and what search queries you may have run on, the Services (clickstream);
   • Viewing behavior, including the content you view, how long you view content, the quality of the service you receive, and advertisements you have been shown or interacted with;
   • Dates and times, you access the Platform or use the Services;
   • Location information, including the city, state and zip code associated with your IP Address, information derived through WiFi triangulation, and precise location information from GPS-based functionality on your mobile apps, with your consent;
   • Your phone number and mobile carrier details in connection with our mobile app.

 

2. COOKIES AND SIMILAR TECHNOLOGIES

What is a cookie? A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our Platform.

Why do We use cookies and similar tracking technology?

We use cookies to recognize your device and provide you with a personalized experience on our Platform, or otherwise through the Services. We use strictly necessary, performance, functionality and targeting or advertising cookies on the Platform. These cookies may allow;

• Strictly Necessary – These are essential to enable you to move around the Website and use its features. Without these cookies, the Service you have requested cannot be provided.
• Functionality – us to remember choices you make to improve your experience such as your Username.
• Advertising or targeting – third party advertising companies to display advertisement more relevant to you and your interests. As part of their services, they will place a separate cookie on your computer to help them precisely target advertising to you. These third-party advertising companies do not collect personally identifiable information; and
• Performance – us or/and third-party partners collect anonymous information including but not limited to performance and Platform improvement. This may include web analytics, error management and testing designs.

You may choose not to accept cookies, but this may prevent the Platform from functioning properly, or may affect your experience on the Platform, or you may not be presented with relevant advertising. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

 

3. HOW WE USE THE INFORMATION WE OBTAIN

We, or service providers acting on our behalf, may use the information collected from and about you to provide and improve our Services, complete your profile, provide you with a personalized experience on our Platform, contact you about your account and our Services, for billing purposes, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities. We will not sell, trade, or rent your Personal Information.

VroomCharge will not use personally identifiable information to send commercial or marketing messages without your consent except as part of a specific program or feature for which you have explicitly opted-in to, and will have the ability to opt-out of at any time.

VroomCharge uses non-personally identifiable information so that, we can:

• Improve the quality and design of our website and services and to create new features and functionality
• Monitor the effectiveness of our marketing campaigns
• Monitor aggregate metrics such as total number of visitors, pages:

We may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. For example, we may combine personal information you provide us, such as an email address, with information automatically collected about your device.

 

4. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information to selected parties, including:

• Third party service providers who perform services on our behalf, such as providers of IT, customer support platforms, data storage providers and email distribution services;
• With Charge Station Owners when you connect for EV charging;
• At your direction or with your consent such as when you direct us to share information with third parties such as utility companies;
• In connection with the negotiation, diligence, or actual merger, acquisition or any form of sale of some or all of MARRS GROUP LLC’s assets or business;
• In the unlikely event of insolvency, bankruptcy or receivership in which your information would be transferred as one of VroomCharge’s business assets;
• Analytics providers that assist us in the improvement and optimization of our Websites;
• Where we are legally obligated to disclose information to the government or third parties for the purposes of criminal or fraud investigations, national security, law enforcement or other issues of public importance; and
• if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to (i) comply with any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms of Use including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect against harm to the rights, property or safety of VroomCharge, its users, yourself or the public.

 

5. HOW WE HOLD AND PROTECT YOUR PERSONAL INFORMATION

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy policy. All information you provide to us is stored on our secure servers. Any payment transactions will be carried out by third parties over encrypted connections using SSL technology. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. You should take steps to keep your information safe (including your password) and to log out of your account after use. Where we have given you (or where you have chosen) a password or API key which enables you to access certain parts of our Platform, you are responsible for keeping this password or API key confidential. We ask you not to share a password or API key with anyone. You should update your password periodically to help reduce the risk of unauthorized access to your account with us. When you do, you should strengthen your password with the combination of uppercase and lowercase letters, numbers, punctuation and other symbols.

Phishing

Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to us. If you believe you have received an email or had a similar interaction with a third party pretending to be VroomCharge, please report it to us.

 

6. OUR RETENTION OF YOUR PERSONAL INFORMATION

We may retain Personal Information about the User, as long as it is necessary for business and/or legal purposes. The periods for which we keep your information depend on why your information was collected and what we use it for. We will not keep your personal information for longer than necessary other than for our business purposes or for legal requirements.

 

7. WHAT ARE YOUR RIGHTS TO YOUR DATA?

All Your Personal Information we collect will always belong to you. However, we are a collector and a processor of Your Personal Information. That implies on us obligations to respect your rights to Personal Information and facilitate the exercise of your rights thereto. In order to use any of your rights at any time please contact us and we will facilitate the exercise of your rights free of charge. We will inform you on the actions taken by us under your request as soon as practically possible, but in any case, not later than in 30 (thirty) calendar days.

In accordance with effective regulations, particularly the GDPR, you have a significant number of rights related to your Personal Information, such as e.g.:

Right to access. You may obtain from us the confirmation as to whether or not personal data concerning you is being processed and get an access to such personal data. You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection office at info@MARRS Group LLC and we will work with you to remove any of your personal data we may have.

Right to rectify your inaccurate Personal Information and to have incomplete personal data completed, including by means of providing a supplementary statement

Right to erase your Personal Information. Please note that a request to erase your Personal Information will also terminate your account on the Site. We will automatically and without undue delay erase your Personal Information when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed. To delete Personal information sent to payment processor like Stripe, User needs to directly work with Stripe.

Right to restrict processing of your Personal Information;

Right to data portability. You may obtain from us the personal data concerning you and which you have provided to us and transmit it to another Personal Information Controller;

Right to object to processing of Your Personal Information,

Right to withdraw your consent to the usage of your Personal Information at any time

Right to lodge a complaint. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Information, you may contact our respective Data Protection Office. We will investigate your complaint promptly and will reply you within 30 (thirty) calendar days.

 

Local laws may also grant you additional rights. For example, Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has accessed the Platform or Services, you may submit a request to opt out of any potential future sales under Nevada law by emailing support@vroomcharge.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change

California Residents

Under California’s civil code section 1798.83, also known as the “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the third parties’ direct marketing purposes.

Under the California Consumer Privacy Act (“CCPA”), California consumers certain rights, which can be exercised directly or in certain cases, through an authorized agent.  These includes the following;

• Right to Know: If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
• Right to Delete: If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
• Right to Opt-Out of Sale of Personal Information: If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).
• Right not to be subject to discrimination for the exercise of rights: We won’t discriminate against you because you exercise any rights herein.

 

8. GOOGLE ANALYTICS

We use Google Analytics to help us to understand how you use our site and tools, which allows us to know how to improve our products for your benefit. It follows your progress through the website, collecting anonymous data on where you have come from, which pages you visit, and how long you spend on the site. Google then stores this data in order to create reports. But don’t worry; they do not store your personal data. Google will track your IP address, and it may be transmitted to and stored by Google on servers in the United States. Google may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for us, and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information on Google’s privacy policies, please visit https://policies.google.com/privacy. Google Analytics services are governed by the Google Analytics Terms of Service which can be found at: https://marketingplatform.google.com/about/analytics/terms/us/.

 

9. TAILORED ADVERTISING.

We and our third-party service providers may use device identifiers and other automated technologies (including cookie identifiers on our website), along with other collected information, to deliver content or tailor ads when you are on our Service or on other devices, apps or websites. These ads may be based, for instance, on the types of websites that you visit over time, the types of apps you have on your device, or de-identified information about you and your likely interests, based on your activities off of our Service. Partners that we or others work with to do the above may track your activities over time (including across different apps or websites) by collecting information through automated means, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you. You may control and block the cookies used by the Website by modifying the settings in your browser or on your device that allow you to refuse the setting of all or some cookies. You can also adjust your settings so that your browser blocks all cookies or only cookies from third parties. You can also delete cookies that have already been placed. However, please note that if you use your browser or device settings to block all cookies you may not be able to access all or parts of our Website. For more information about how cookies can be managed and deleted please visit www.allaboutcookies.org or https://optout.networkadvertising.org.

 

10. LINKS TO OTHER SITES

Our Platform may contain links to other websites. If you choose to click on a third-party link, you will be directed to that third-party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

 

11. USER CONTENTS

You may be able to upload, store, publish, display and distribute information, text, photos, videos and other content accessible through the Platform (collectively, “User Content”). You are solely responsible for any and all User Content. By posting or distributing User Content on or through the Services, you represent and warrant to Vroomcharge that (i) you are the owner of the User Content (ii) you have all the necessary rights to post or distribute such User Content, and (iii) your posting or distribution of such User Content does not infringe or violate the rights of any third party. You hereby grant to Vroomcharge a non- exclusive, royalty-free, worldwide right and license to: (i) use, reproduce, publicly perform, publicly display, modify, translate, excerpt (in whole or in part), publish and distribute User Content; and (ii) make archival or back-up copies of User Content. Except for the rights expressly granted herein, Vroomcharge does not acquire any right, title or interest in or to the User Content, all of which shall remain solely with you.

 

12. MINORS

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Our policy is that we do not knowingly collect, use or disclose personally identifiable information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Site represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from user under 13 years of age on or through the Site, then we will take the appropriate steps to cause this personal information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a subscriber on the Site or has otherwise transferred personal information to the Site, please contact us to have that child’s account terminated and personal information deleted.

 

13. CHANGES IN THE PRIVACY STATEMENT

The effective date at the top of this page indicates when this Privacy Statement was last revised. We will notify you before any material change takes effect so that you have time to review the changes. Any change is effective when we post the revised Privacy Statement. Your use of the Services following these changes means that you accept the revised Privacy Statement.

 

14. GOVERNING LAW AND JURISDICTION

This general terms and conditions in relation to the use of the Platform is hereby governed by and constructed and enforced in accordance with the laws of the state of Pennsylvania.

 

CONTACT US

If you have any questions about these Terms and Conditions, You can contact us:

By email: support@vroomcharge.com

By visiting this page on our website: https://www.vroomcharge.com/contact-us/