Privacy Policy for the Charly® Ecosystem

1.
Data Controller
The data controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:
  1.  
    KWMS GmbH
  2.  
    Stolberggasse 26/1.05
  3.  
    1050 Vienna
  4.  
    Austria

  5.  
    Email: [email protected]
  6.  
    Website: www.kw-solutions.at
The protection of personal data is a top priority for KWMS GmbH. We process personal data exclusively in accordance with applicable data protection regulations, in particular the General Data Protection Regulation (GDPR) and the Austrian Data Protection Act (DSG).
2.
Scope
This Privacy Policy applies to all digital platforms, applications, and services of the Charly® ecosystem.
These include, in particular:
  1. •
    charly.live
  2. •
    charlytransportation.live
  3. •
    Charly® App
  4. •
    Charge with Friends
  5. •
    future digital platforms, modules, and extensions of the Charly® product family
The Charly® ecosystem is designed for the management, optimization, monitoring, and billing of charging infrastructure, as well as energy and mobility management for individuals, businesses, housing developers, fleet operators, logistics companies, and other user groups.
3.
Categories of Processed Data
When using the Charly® ecosystem, the following categories of personal data, in particular, may be processed:
Master Data
  1. •
    First and last name
  2. •
    Company
  3. •
    Address
  4. •
    Phone number
  5. •
    Email address
  6. •
    Username
  7. •
    Customer number
Contract and Customer Information
  1. •
    Contract information
  2. •
    Customer relationships
  3. •
    Locations
  4. •
    Operator information
  5. •
    Billing information
  6. •
    Payment information
User and Platform Data
  1. •
    User roles
  2. •
    Permissions
  3. •
    Login data
  4. •
    Usage logs
  5. •
    Settings within the platform
Charging Infrastructure and Transaction Data
  1. •
    Charging sessions
  2. •
    Charging times
  3. •
    Charging point assignments
  4. •
    Energy volumes
  5. •
    Transaction data
  6. •
    RFID assignments
  7. •
    User authorizations
Energy and Grid Data
  1. •
    Electricity consumption data
  2. •
    Load profiles
  3. •
    Load management data
  4. •
    Energy management data
  5. •
    Grid-related operational data
  6. •
    Optimization data
Vehicle and Fleet Data
  1. •
    Vehicle assignments
  2. •
    Fleet information
  3. •
    Vehicle-related charging parameters
  4. •
    Transport and depot data
Communication and Support Data
  1. •
    Support requests
  2. •
    Tickets
  3. •
    Correspondence
  4. •
    Customer feedback
  5. •
    Survey results
4.
Purposes of Processing
Personal data is processed in particular for the following purposes:
Operation of the Charly® Ecosystem
  1. •
    Provision of the platform
  2. •
    User management
  3. •
    Authentication
  4. •
    Rights and role management
Charging Infrastructure Management
  1. •
    Management of charging points
  2. •
    Charging infrastructure monitoring
  3. •
    Operations management
  4. •
    Maintenance and support
Energy Management
  1. •
    Load management
  2. •
    Load optimization
  3. •
    Energy control
  4. •
    Electricity price optimization
  5. •
    Grid optimization
Mobility Management
  1. •
    Charging management
  2. •
    Fleet management
  3. •
    Transportation management
  4. •
    Depot management
Charge with Friends
  1. •
    Networking of charging infrastructure locations
  2. •
    Management of charging authorizations
  3. •
    Transaction processing
  4. •
    Cross-location use of charging infrastructure
Billing and Settlement
  1. •
    Billing for charging sessions
  2. •
    Generation of invoices
  3. •
    Credit notes
  4. •
    Payment processing
  5. •
    Reporting
Customer Support
  1. •
    Handling of inquiries
  2. •
    Support services
  3. •
    Contract management
  4. •
    Communication with users
Product Improvement
  1. •
    Analysis of user behavior
  2. •
    Quality assurance
  3. •
    Further development of existing products
  4. •
    Development of new features and services
Research and Innovation
  1. •
    Implementation of research and development projects
  2. •
    Analysis of energy and mobility data
  3. •
    Development of innovative energy management and charging infrastructure solutions
To the extent that data is used for research and development purposes, it is done so in anonymized or aggregated form whenever possible. Personal data is processed only to the extent that it is legally permissible and necessary for the respective purpose.
5.
Legal Basis
Processing is based on:
  1. •
    Art. 6(1)(b) GDPR (performance of a contract)
  2. •
    Art. 6(1)(c) GDPR (legal obligations)
  3. •
    Art. 6(1)(f) GDPR (legitimate interests)
  4. •
    Art. 6(1)(a) GDPR (consent)
Legitimate interests include, in particular:
  1. •
    the secure operation of the platform,
  2. •
    the optimization of charging and energy systems,
  3. •
    the further development of products,
  4. •
    improving the user experience,
  5. •
    ensuring IT security.
6.
Recipients of Personal Data
To the extent necessary for the provision of services, personal data may be transferred in particular to the following categories of recipients:
  1. •
    IT and hosting service providers
  2. •
    Payment and billing service providers
  3. •
    Contractual and business partners in connection with the operation of charging infrastructure and energy services
  4. •
    Tax, legal, and financial advisors
  5. •
    Government agencies and courts, to the extent required by law
Data is transferred only to the extent necessary.
7.
Retention Period
Personal data is stored only for as long as necessary for the respective processing purposes or as required by statutory retention obligations.
In addition, data is stored for as long as:
  1. •
    contractual relationships exist,
  2. •
    outstanding claims exist,
  3. •
    statutory documentation and retention obligations must be fulfilled,
  4. •
    legal claims can be asserted or defended.
Once the respective purposes no longer apply, the data will be deleted or anonymized.
8.
Data Security
KWMS implements appropriate technical and organizational measures to protect personal data. These security measures are continuously adapted to the state of the art and further developed.
9.
Your Rights
Data subjects have the following rights in particular:
  1. •
    Right of access
  2. •
    Right to rectification
  3. •
    Right to erasure
  4. •
    Right to restriction of processing
  5. •
    Right to data portability
  6. •
    Right to object
  7. •
    Right to withdraw consent
In addition, you have the right to file a complaint with the competent data protection authority.
10.
Contact
If you have any questions regarding data protection or the exercise of your rights, please contact:
KWMS GmbH
Stolberggasse 26/1.05
1050 Vienna
Email: [email protected]
11.
Governing Language
This Agreement has been drafted in German. The English version is provided for convenience purposes only. In the event of any discrepancy, inconsistency, ambiguity or conflict between the German and English versions, the German version shall prevail and be the legally binding version.
Date: June 2026