This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage of data made by Metrosphere Corp., d/b/a metroEV (collectively “metroEV”, “Company”, “we” or “us”).

This Privacy Policy concerns the data we collect from individuals who access and use our website available at https://www.metroev.ca/ (respectively “Website” and “Visitors”) and users who have installed and are interacting with our end-user mobile application or our back-office mobile application or web interface (respectively “App”, and “Users”, collectively, “Services” or “Product”). Each of the Visitors and Users shall also be referred to herein as “you”.

Definitions used herein but not defined herein shall have the meaning ascribed to them in the End User License Agreement (EULA). If you have any questions about this Privacy Policy, please contact us at: info@metrosphere.ca.

Business Partners

You may be provided with access to our Products through a “Business Partner” who is the entity providing you with our products as part of their service. Please note that in some cases this may be your condominium board.

Collection of Personal Data

During your use of the Website or the App, some individually identifiable information may be collected, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, names, emails, etc., subject to applicable law. If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data. You are not obliged to provide us with any of your Personal Data. However, if you refrain from doing so, we may not be able to provide all of our Services to its full extent.

Processing of Personal Data

We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so.

Type of Data	Purpose of Processing		Lawful Basis for Processing
As part of becoming a User of the Product and signing up for an account
If you are or wish to become a user of the Services, you will be required to provide us with certain information such as: ● Identification and contact data: Full name, Email address, password, etc. ● Your address and parking space ● Payment (Credit Card) information	We will use this data to designate your App account and allow you to use the Product and the App supporting its operation, including exercising payments in consideration of your electricity consumption. Also, your email address will be used to send you needed information related to our App (e.g., Statements, notify you regarding any updates to our App, etc.) and promotional and marketing emails.		Our lawful basis for collecting this information is the performance of a contract (i.e., providing you the Services as per your request). We will further retain your transactional and usage data as a User of our services under our legitimate interest. Also, some data (such as invoices and payment records) shall be kept under our legal obligations.
Through and during the use of the Product
Data which will be fed to the system from your charger: ● When you plug in and plug out your vehicle into the charger ● Amount and rate of energy provided to your vehicle by the charger	We collect and analyze this data to calculate the cost of charging so we can bill you for the service. As part of that and per your authorization and free will, we will transfer the data to the Business Partner who provided you with our products as part of their service. We also may use this data for upgrading and developing our Services.	The lawful basis for collecting this information is the performance of a contract (i.e., providing you the Services as you requested). We will further retain your transactional and usage data as a User of our services under our legitimate interest. Also, some data (such as invoices and payment records) shall be kept under our legal obligations.
When and if you contact us with any inquiry or request
If you voluntarily contact us in any manner, whether for support, to submit a request, or for other inquiries, whether by sending us an email or through other means of communications, e.g., any online form available on the Website, you may be asked to provide us with your contact information such as your full name, email address, and country.	We will use this data and our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law.		The lawful basis for processing your inquiries information as an active User will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries. After completing any such request, we will retain your information as part of our business records under our legitimate interest.
Online Identifiers and Other Technical Data
When you access our website or interact with our App, we may collect certain online identifiers, including your IP address, Advertising ID, and IDFA. We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the Website or App, your browser type, the language used, type of operating system, type of device, etc.) and approximate geographical location (country). See below for details regarding cookie usage.	We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing, and improving the Website and how we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; (iv) protecting the security of the Website, as well as our and third parties rights (subject to applicable law requirements); and (v) advertising purposes.		Such processing is part of our legitimate interests as a commercial business.

Data Controller / Data Processor for EU Residents

In case you are a resident of the European Union, and your use of the App is subject to the European General Data Protection Regulation (”GDPR”), we are the Data Controller of our direct Customers’ Personal Data and certain types of User’s Personal Data. If and when you use our Services as an end-user under a Business Partner we are the Processor of some of the Personal Data processed on behalf of the Business Partner, who is the Controller of the Personal Data, while we are still the Controller of other parts of the Data.

Collection of Non-Personal Data

We may collect aggregated, non-personal, and non-identifiable information that may be made available or gathered via your use of the Website or App (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected. Also, we may sometimes process and anonymize or aggregate personal data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified person. Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.

Other Companies We Work With

Intercom: Customer Messaging Platform (Intercom, Inc)

Intercom’s platform empowers our customer messaging and support process. Data sent to Intercom include your email, account details (account name, site name, etc.) conversation history, and product usage history. Intercom's widget uses these attributes to trigger personalized, automated marketing emails and in-app messages. Based on Intercom data we create and send targeted in-app messages to customers while they’re logged into our app.

To opt-out of Intercom communications, please contact Intercom help service https://www.intercom.com/help/. Please note that this will impact your ability to receive product news and updates from us.

Coralogix log analytics (Coralogix, Ltd.)

Our service uses the Coralogix log analytics platform to improve our backend server monitoring. Part of the system logs may contain your user identifier (email). This log analysis tool helps us provide better monitoring and uptime for our back-end systems.

Stripe: Payment processing

We use Stripe to process payments. When adding your credit or debit card it is processed and stored by the Stripe platform and is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS).

For more insight, you may also want to read Stripe’s Privacy Statement here: https://stripe.com/privacy

Cookies Usage

Like many other websites, the Website and parts of our System use cookies to improve your experience while you navigate the Website. We may use various types of Cookies:

Essential Cookies – which are necessary for the site to work properly (usually appear under our name/cookie tag);
Functional Cookies – designated to save your settings on the site - your language preference or other view preferences (also, under our name/cookie tag);  Session Cookies – used to support the Website's functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
Targeting Cookies – These cookies are used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
Social networks Cookies – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
Analytics Cookies – give us aggregated and statistical information to improve the Website and System and further develop it e.g., Google Analytics, Google Firebase Crashlytics, etc.
Third-party services used by us – for example, an external service supporting our career and recruiting options through the Website (e.g., Comeet or Workday), or an external service that allows us to screen short videos on our Website (e.g., YouTube or Vimeo).

Also note, that Cookies data is usually collected through third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might use it, as a “joint controller” of the data, meaning that the data is also “owned” and processed by them under their terms and conditions. Under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third party and processed in its systems, for its purposes, and under its management. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies on Our Website might be linked to other data Facebook collects and might be used by Facebook per the independent agreements between you and Facebook.

Managing cookies and opting out: aside from the Essential Cookies described above, you can always configure your browser or use the “cookies bar” installed in the Website to reject all cookies or notify you when a cookie is set, but sometimes, in that case, specific services, features, and functionality in the Website may not be available to you.

You can find more information about managing cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how to delete cookies already stored on your device.

Sharing Data with Third Parties

We may disclose your Personal Data to the following third parties:

Business Partners. We may share your information with service providers that we reasonably believe need the information to perform a technology, business, or other professional function for us, such as billing and collection, IT services, maintenance and hosting of our App, payment processors, marketing partners, accounting, auditing, and tax services, and other professional services. We will share your usage data with the Business Partner providing you services, to allow for the usage of our Services properly. The Business Partner (directly, or indirectly by us where instructed by the Business Partner) may share usage data with third parties governmental entities (such as energy departments, etc.) for the purpose of complying with certain environmental incentive plans or similar funding projects). Note that this usage data will include your identifying information such as name or contact details, rather solely information related to the charger you are using, its location and usage information.
We partner with analytics providers, who collect information via tracking technologies on our Website to assist us with measuring visits and traffic on our Website and the usage of our App and Services so we can measure and improve the performance of the Website, the App and our Services.
We partner with third parties who assist us in serving advertising regarding our Services to others, or who use cookies to display interest-based advertising to you. These third parties may use tracking technologies on our website or applications to collect or receive information from the website and elsewhere on the internet and use that information to target ads, or to better tailor communications to you. Third parties may allow other companies to access information about you so that they may market other products you may be interested in.
Social Media. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our website (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
We share information with other entities in our corporate family, for purposes consistent with this Privacy Policy.
Corporate Event. We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
We share information where necessary to comply with applicable law, regulations, subpoenas, or to respond to requests from law enforcement agencies or other government authorities or third-parties, as required by law and without your consent when it is necessary to protect our customers, employees, or property; detect, prevent, or otherwise address fraud, security, or technical issues; in emergency situations; or to enforce our rights under our terms of service and policies.

Accessing and Correcting Your Personal Information

Please keep us informed if your personal information changes. You have the legal right to request access to and correction of your personal information in our possession.

To review, verify, correct, or withdraw consent to the use of your personal information, please send an email address set out below. We'll do our best to accommodate your request. However, please note that we may refuse changes if they violate any laws, legal requirements, or accuracy standards.

We may request specific information to confirm your identity and ensure your right to access or modify your personal information. Applicable laws may permit or require us to deny access to certain portions or all of your personal information, or we may have deleted, erased, or anonymized your data as part of our record retention policies. We will explain the reasons if we cannot provide access, subject to legal or regulatory restrictions.

Data Retention

Unless you instruct us otherwise, subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable. We may keep some of your Personal Data as a user of our Services for more extended periods for protecting our legal interests or under any safety or other legal requirements.

Please note that where we act as a Processor on behalf of an account owner, the retention periods are under the sole discretion of the account owner, as the Data Controller.

Upon request, metroEV will delete personal identifiable data (PID) within 30 days. Other non-identifiable data may take longer (up to 90 days).

Security

We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

However, unfortunately, the transmission of information via the Internet and online data processing cannot be 100% secure. As such, we cannot guarantee the security of data transmitted via the Website, or App and any transmission of your data shall be done at your own risk.

Data Processing Location

We may store or process your Personal Data in a variety of countries, including the United States. Any such transfer of data shall be done in accordance with relevant and applicable law, and only after we have ensured the security and privacy of your data.

Links to Other Sites

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.

Children

Our App and Website are not directed, nor is it intended for use by children or minors and we do not knowingly process a child’s information. We will discard any information that we receive from a user who is considered a "child" immediately upon our discovery that such a user shared information. Please contact us if you have reason to believe that a child has shared any information with us.

Amendments

We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website or App. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

Who Are We and Contacting Us

7-80 Citizen Court
Markham, ON
L6G 1A7
Telephone: 833-882-1713
Email: info@metrosphere.ca

Questions, comments, requests, and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.