Privacy Policy

Clarification Statement

For the purposes of this Privacy Policy, "ChaCha Charging Australia" is a business name of Thoritech Australia Pty Ltd (ACN 605 834 615). Any reference to "ChaCha Charging Australia" or "Thoritech Australia" refers to the same legal entity, and the terms are used interchangeably throughout this document. All rights, obligations, and responsibilities related to personal information apply equally to both names.

Definition

ChaCha Charging Australia (referred to as "we", "us", or "our"), a business name of Thoritech Australia Pty Ltd (ACN 605 834 615), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you and during your use of our website or any other platform through which we make our services available from time to time (ChaCha Charging Australia Platform).

This Privacy Policy takes into account the requirements of privacy laws, codes and regulations in New Zealand and Australia, including the Privacy Act 2020 and the Privacy Act 1988 (Cth) where applicable (Privacy Laws).

In addition to the Privacy Laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.

This Privacy Policy also applies to any information we collect through the following channels, including but not limited to:

  • ChaCha Charging Australia mobile application (ChaCha Charging Australia App);

  • Interactions through social media platforms (e.g., Facebook, Twitter);

  • Any other platforms or services we may offer from time to time.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

  • Identity Data including your first name and last name.

  • Contact Data including your telephone number, address and email.

  • Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).

  • Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

  • Technical and Usage Data when you access the ChaCha Charging Australia Platform, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of the ChaCha Charging Australia Platform (including through the use of Internet cookies), and communications with the ChaCha Charging Australia Platform.

  • Profile Data including your username and password for the ChaCha Charging Australia Platform, charging sessions you have made with us, and support requests you have made.

  • Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.

  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

  • Technical and Usage Data: When you access the ChaCha Charging Australia Platform, we automatically collect technical and usage data such as:

  • Internet protocol (IP) address;

  • Browser type and version;

  • Operating system and device information;

  • Log-in data and session information;

  • Geolocation data (where consented)

  • Geolocation Data: We may collect and generate your geolocation information when you use the ChaCha App or visit our website. This may include your precise location (e.g., via GPS) and any location data you provide when searching for charging stations. We use this data to offer location-based services, such as recommending nearby charging stations and improving user experience.

How we collect personal information

We collect personal information in a variety of ways, including:

  • when you interact directly with us, including face-to-face, over the phone, over email, or online;

  • when you complete a form, such as registering for newsletters or responding to surveys;

  • when you apply for a job with us;

  • from third parties, such as details of your use of the ChaCha Charging Australia Platform (from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies); or

  • from publicly available sources, such as social media, the New Zealand Companies Office or the Australian Securities and Investment Commission (ASIC).

Mobile Application Privacy Terms

When you download and use our mobile application (ChaCha Charging Australia App), we may collect the following types of data:

  • Device Information: Including device model, operating system version, and unique device identifiers.

  • App Usage Data: Including your interactions within the app, frequency of use, and accessed features.

  • Geolocation Data: With your consent, we may collect your real-time geolocation (via GPS or other positioning technologies) to provide location-based services, such as nearby charging station recommendations.

We commit to using this information solely to improve app performance, personalize user experiences, and deliver the services you request. You can manage app permissions in your device settings to control access to your device information and location data.

We retain app usage data and log data for a period that is necessary to improve app functionality and user experience. Users can request the deletion of such data at any time, subject to legal or operational retention requirements.

Mobile App Data Collection

When you use our mobile application, we may collect the following information:

  • Device Information: Such as device model, operating system version, and unique device identifiers (e.g., IMEI or UUID).

  • App Usage Data: Including your activity within the app, frequency of use, and interactions with features or pages.

  • Geolocation Information: With your permission, we may collect your real-time location data (via GPS or other positioning technologies) to offer location-based services, such as recommending nearby charging stations.

  • Log Data: We collect crash reports, error logs, and performance data to enhance app stability and user experience.

We use this information solely to improve app functionality, user experience, and provide personalized services. You can manage app permissions in your device settings to control the information we can access.

Why we collect, hold, use and disclose personal information

We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.

Purpose of use / disclosure

Type of Personal Information

To enable you to access and use the ChaCha Charging Australia Platform and our software, including to provide you with a login.

  • Identity Data

  • Contact Data

To provide our services to you, including to deliver charging sessions to you.

  • Identity Data

  • Contact Data

To contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us.

  • Identity Data

  • Contact Data

  • Profile Data

To contact and communicate with you about any enquiries you make with us via the ChaCha Charging Australia Platform and any website we operate.

  • Identity Data

  • Contact Data

For internal record keeping, administrative, invoicing and billing purposes.

  • Identity Data

  • Contact Data

  • Financial Data

  • Transaction Data

For analytics (including profiling on the ChaCha Charging Australia Platform), market research and business development, including to operate and improve our business, associated applications and associated social media platforms.

  • Profile Data

  • Technical and Usage Data

For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.

  • Identity Data

  • Contact Data

  • Technical and Usage Data

  • Profile data

  • Marketing and Communications Data

To run promotions, competitions and/or offer additional benefits to you.

  • Identity Data

  • Contact Data

  • Profile Data

  • Interaction Data

  • Marketing and Communications Data

If you have applied for employment with us, to consider your employment application.

  • Identity Data

  • Contact Data

  • Professional Data

To comply with our legal obligations or if otherwise required or authorised by law.

  • Any relevant Personal Information


Charging Network Data Analysis

We may analyse data generated from your use of the ChaCha Charging Australia network, including but not limited to:

  • Charging frequency and duration;

  • Charging location and patterns;

  • Usage of charging stations.

This data is used to optimize our charging network, improve service quality, conduct market analysis, and inform business decisions. We may share anonymized usage data with business partners for collaboration and innovation purposes.

Our disclosures of personal information to third parties

Personal information: We may disclose personal information to:

  • our employees, contractors and/or related entities;

  • IT service providers, data storage, web-hosting and server providers;

  • marketing or advertising providers;

  • professional advisors, bankers, auditors, our insurers and insurance brokers;

  • payment systems operators or processors;

  • our existing or potential agents or business partners;

  • sponsors or promoters of any promotions or competition we run;

  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

  • third parties to collect and process data, such as analytics providers and cookies; and

  • any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

Your personal information may be transferred outside of the country in which you are located.

Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Australia or New Zealand. Such countries may not have an equivalent level of data protection laws as those in Australia or New Zealand.

If you are based in Australia, we will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

If you are based in New Zealand, before disclosing any personal information to an overseas recipient, we will comply with the Information Privacy Principle 12 and only disclose the information if:

  • you have authorised disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020;

  • we believe the overseas recipient is subject to the Privacy Act 2020;

  • we believe the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act 2020;

  • we believe that the overseas recipient is a participant in a prescribed binding scheme;

  • we believe that the overseas recipient is subject to privacy laws in a prescribed country; or

  • we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).

Where the disclosure of your personal information is solely subject to the Privacy Laws, you acknowledge that some third parties may not be regulated by the Privacy Laws and if any such third party engages in any act or practice that contravenes the Privacy Laws, it would not be accountable under the Privacy Laws and you will not be able to seek redress under the Privacy Laws.

Overseas Data Transfer Security Measures

When we transfer your personal information overseas, we take the following steps to ensure the safety and compliance of your data:

  • Adequate Safeguards: We only transfer your personal information to countries that have been recognized by relevant data protection laws as providing an adequate level of data protection.

  • Standard Contractual Clauses: We implement standard contractual clauses with overseas recipients to ensure they adhere to the same data protection obligations as we do.

  • Encrypted Transfers: We use advanced encryption techniques (e.g., SSL/TLS) to protect your personal information during transmission.

  • Regular Audits: We regularly audit overseas recipients’ data protection measures to ensure they remain compliant with our privacy policy and applicable laws.

In the event of a data breach involving an overseas recipient, we will notify affected individuals in accordance with applicable privacy laws and take immediate steps to mitigate the impact.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Deleting Your Personal Information: You have the right to request the deletion of your personal information stored in our system. To exercise this right, please contact us using the details provided below. Please note that in certain situations, we may be required to retain your personal information to comply with legal obligations or resolve disputes.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the New Zealand Privacy Commissioner or the Australian Information Commissioner.

Data Encryption and Security Measures

To protect your personal information from unauthorized access, disclosure, modification, or destruction, we have implemented the following security measures:

  • Encrypted Transmission: All personal information transmitted over the internet is secured using SSL/TLS encryption to ensure confidentiality and integrity.

  • Encrypted Storage: Sensitive personal information stored on our servers is encrypted using Advanced Encryption Standard (AES).

  • Access Controls: Only authorized personnel and third-party service providers with strict confidentiality agreements have access to your personal information.

  • Regular Security Audits: We conduct regular security audits and vulnerability scans to detect and resolve potential risks.

  • Data Backups: Personal information is backed up regularly to prevent data loss, with backups also being encrypted and secured.

While we strive to protect your data, please note that no transmission of information over the internet is completely secure, and users should take their own precautions, such as using strong passwords and regularly updating them.

Cookies

We may use cookies on the ChaCha Charging Australia Platform from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Third-Party Cookies and Tracking Technologies

In addition to first-party cookies, our ChaCha Charging Australia Platform may use third-party cookies and tracking technologies, including but not limited to:

  • Advertising Network Cookies: Used to display personalized ads across websites and apps.

  • Analytics Cookies: Such as Google Analytics, used to track and analyse user behaviour on our platform to improve services and performance.

You can manage or block third-party cookies through your browser settings or use browser plug-ins to control tracking. For example, you can use the [Google Analytics Opt-Out Add-on](https://tools.google.com/dlpage/gaoptout) to prevent Google Analytics from tracking your data.

For more information about the cookies we use, please see the table below:

Cookie

Category

Purpose

Currency

Functionality

This cookie stores the currency used for the online Services (the Currency which is used in the country from which you are accessing the Platform).

Language

Functionality

This cookie stores the language used for the online Services (English)

PHPSESSIONID

Analytical/ performance

This cookie contains a unique ID to support functions (for example, last viewed pages) to improve user experience

newsbcsub

Functionality

This cookie is stored once the user has completed or closed the Register Pop Up, preventing it from re-appearing until after 7 days

TLSCookiesEU

Strictly necessary

This cookie tracks when a user has accepted that the online Services use cookies preventing the popup from being displayed again during that session

ga / gid / _gat

Analytical/ performance

These cookies are used by our Google Analytics account to track customer traffic through the website to help us understand how our website is being used by our users

Links to other websites

The ChaCha Charging Australia Platform may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check the ChaCha Charging Australia Platform regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Email: support@cccharging.com.au

© Thoritech Australia Pty Ltd


Appendix 1: Additional rights and information for individuals located in the EU or UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose of use / disclosure

Type of Data

Legal Basis for processing

To enable you to access and use the ChaCha Charging Australia Platform and our software, including to provide you with a login.

  • Identity Data

  • Contact Data

  • Identity Data

  • Contact Data

To provide our services to you, including to deliver charging sessions to you.

  • Identity Data

  • Contact Data

  • Performance of a contract with you

To contact and communicate with you about our business including in response to any support requests you lodge with us or other enquiries you make with us.

  • Identity Data

  • Contact Data

  • Profile Data

  • Performance of a contract with you

To contact and communicate with you about any enquiries you make with us via the ChaCha Charging Australia Platform and our website.

  • Identity Data

  • Contact Data

  • Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.

For internal record keeping, administrative, invoicing and billing purposes.

  • Identity Data

  • Contact Data

  • Financial Data

  • Transaction Data

  • Performance of a contract with you

  • To comply with a legal obligation

  • Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms of business and any other administrative points.

For analytics including profiling on the ChaCha Charging Australia Platform, market research and business development, including to operate and improve our business, associated applications and associated social media platforms.

  • Profile Data

  • Technical and Usage Data

  • Legitimate interests: to keep our website updated and relevant, to develop our business, improve our business and to inform our marketing strategy

For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.

  • Identity Data

  • Contact Data

  • Technical and Usage Data

  • Profile Data

  • Marketing and Communications Data

  • Legitimate interests: to develop and grow our business

To run promotions, competitions and/or offer additional benefits to you.

  • Identity Data

  • Contact Data

  • Profile Data

  • Interaction Data

  • Marketing and Communications Data

  • Legitimate interests: to facilitate engagement with our business and grow our business

If you have applied for employment with us, to consider your employment application.

  • Identity Data

  • Contact Data

  • Professional Data

  • Legitimate interests: to consider your employment application

To comply with our legal obligations or if otherwise required or authorised by law.

  • To comply with a legal obligation


If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.

Data Transfers

The countries to which we send data for the purposes listed above may be less comprehensive that is what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:

  • only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or

  • including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy.