1. Introduction
This Privacy Policy explains how linqEV Operators Inc. ("linqEV", "we", "us", or "our") obtains, uses, and discloses your personal information when you use our electric vehicle charging network, mobile applications (including the linqEV and linqNRG apps), website, and the Host a Linq partner programme (collectively, the "Services").
We process personal information in accordance with the Protection of Personal Information Act, 2013 ("POPIA") and other applicable South African data protection legislation.
By using our Services, you acknowledge that you have read and understood this Privacy Policy. We are committed to protecting your privacy and to handling your personal information lawfully, transparently, and only for the purposes set out below.
2. Definitions
In terms of POPIA, "personal information" means information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person. In the context of linqEV, this includes, but is not limited to:
- Names and contact details (email addresses, telephone numbers, physical and postal addresses)
- Vehicle details (make, model, registration number, battery capacity, connector type)
- Payment information (card details, billing address, transaction history)
- Charging session records (station ID, time, duration, kWh delivered, cost)
- Location data (when you search for nearby chargers or start a charging session)
- Device and technical identifiers (IP address, device model, operating system, app version, push-notification tokens)
- Host partner business information (company registration, VAT number, banking details for payouts, site address)
- Any other information defined as personal information under POPIA
"Processing" means any operation concerning personal information, including collection, storage, use, modification, dissemination, or destruction.
"Driver" means an end-user of the linqEV charging network and mobile app. "Host" means a business or property owner participating in the Host a Linq programme.
3. Information We Collect
We collect personal information through the following channels:
- Account registration: When you sign up for a linqEV account, we collect your name, email address, phone number, password (stored as a one-way hash), and optionally your vehicle make, model, registration, and battery details.
- Subscription & payment: If you subscribe to linqEV Plus or linqEV Pro, we collect billing information and your selected payment method. Card details are tokenised and handled by our PCI-DSS compliant payment processors — linqEV does not store full card numbers on its own systems.
- Charging sessions: Each time you start a charging session, we record the station, connector, start/end time, energy delivered (kWh), session cost, and the payment method used.
- App and website usage: We collect device identifiers, IP address, app version, operating system, push-notification tokens, crash diagnostics, and aggregated usage analytics to operate and improve the Services.
- Location data: When you use the map or initiate a charging session, we collect location data to find nearby chargers, verify session start at a station, and present accurate availability — see section 5 for detail.
- Contact forms and support: When you submit a contact form, fault report, or support enquiry, we collect your name, contact details, message content, and any photos or attachments you provide (for example, when reporting a damaged charger).
- Host a Linq applications: When you apply to host a linqEV charger, we collect business contact information, company registration and VAT numbers, banking details for revenue payouts, site address, photographs of the proposed installation site, and electrical/grid specifications.
- Communications: Records of correspondence between you and our support team, including emails, in-app chat, and call logs.
Where possible, we will inform you what information is required and what is optional. Providing optional information helps us tailor the Service to you but is never a condition of using core charging functionality.
4. How We Use Your Information
We use your personal information only for the purposes for which it was collected and to which you have provided consent. This includes:
- Creating and managing your linqEV account and any subscription plan
- Authorising, processing, and recording charging sessions and associated payments
- Displaying real-time charger availability, pricing, and station information in the app
- Sending session receipts, charging notifications (start, end, fault), and transactional communications
- Providing customer support and responding to enquiries, fault reports, and refund requests
- Calculating and disbursing revenue share to Host partners
- Conducting internal analytics to improve charger uptime, network coverage, app performance, and the customer experience
- Detecting and preventing fraud, abuse of the network, payment fraud, or other malpractice
- Sending you marketing communications about linqEV products, promotions, and partner offers — only where you have opted in (see section 14)
- Complying with applicable laws, tax obligations, regulatory requests, and legal proceedings
- Audit, record-keeping, and dispute resolution purposes
5. Location & Charging Session Data
The linqEV mobile app may request access to your device's location services. We collect location data only for the following purposes:
- Finding nearby chargers: When you open the map or perform a search, we use your approximate location to surface relevant stations. You can disable location access in your device settings; the map will still work, but you will need to search by address or town.
- Starting a session: When you tap to start a charging session at a station, we verify that your device is within proximity of the selected charger to prevent accidental or fraudulent activation.
- Service quality and coverage planning: Aggregated and de-identified location data may be used to identify network coverage gaps and to plan future charger deployments. This data cannot be linked back to you as an individual.
We do not track your location continuously in the background, sell location data to third parties, or use it for advertising. You may revoke location permissions at any time from your device settings.
Charging session records (station, time, kWh, cost) are retained as part of your account history and for billing, tax, and dispute-resolution purposes.
6. Payment Information
linqEV uses PCI-DSS compliant third-party payment processors to handle card payments and recurring subscription billing. When you add a payment method:
- Card details are submitted directly to the payment processor and tokenised. linqEV stores only a token, the card brand, the last four digits, and the expiry month/year for display purposes.
- Full card numbers, CVV codes, and PIN data are never stored on linqEV systems.
- Refunds, chargebacks, and disputed transactions are handled jointly with the payment processor and may require additional information from you for verification.
For Hosts receiving revenue payouts, we collect bank account details and any tax registration information required for payments and reporting. This information is stored securely and disclosed only to the financial institutions involved in the payout, and to regulatory authorities where required by law.
7. Cookies, App Analytics & Tracking
Our website and mobile applications use cookies, software development kits ("SDKs"), and similar technologies to collect standard internet and app-usage information. These help us to:
- Keep you signed in across sessions
- Remember your preferences (language, units, default vehicle)
- Understand which features are used most and where users encounter difficulties
- Diagnose crashes and performance problems
- Measure the effectiveness of marketing campaigns (only with your consent where required)
You can manage cookie preferences through your browser settings, and analytics/marketing consent through the app's privacy settings. Declining non-essential cookies and analytics will not prevent you from using core charging functionality.
8. Disclosure of Information
We may disclose your personal information to the following parties, subject to appropriate contractual safeguards:
- Payment processors and financial institutions: To process charging payments, subscriptions, refunds, and Host payouts.
- Charging hardware operators & roaming partners: To authorise and meter charging sessions on chargers operated by linqEV or by interoperability partners on whose network you may roam.
- Hosts: Hosts receive aggregated, de-identified utilisation statistics for chargers on their sites. Personally identifying information about Drivers is not shared with Hosts unless required for a specific incident (e.g. fault at a host's premises).
- Cloud hosting, infrastructure, and SaaS providers: Including hosting, database, email, push-notification, customer-support, and analytics services that operate the platform on our behalf.
- Professional advisors: Auditors, legal counsel, and insurers as required.
- Regulatory and legal authorities: Where we have a duty or right to disclose in terms of law, regulation, court order, or to protect the safety of any person.
- Successor entities: In connection with a merger, acquisition, or sale of business assets, your information may be transferred subject to equivalent privacy protections.
We will not sell, rent, or trade your personal information to third parties for their own marketing purposes.
9. Cross-Border Data Transfers
Some of the cloud and SaaS providers we use may store or process data outside the Republic of South Africa. Where this occurs, we ensure that the recipient is subject to laws, binding corporate rules, or contractual obligations that provide an adequate level of protection for your personal information consistent with POPIA.
By using the Services, you consent to the transfer of your personal information across borders for the purposes set out in this Policy.
10. Information Security
We are legally obliged to provide adequate protection for the personal information we hold and to prevent unauthorised access, use, or disclosure. We continuously review our security controls and related processes to safeguard your data.
Our security measures include:
- Encryption of data in transit (TLS) and at rest
- Password hashing using industry-standard one-way functions
- Tokenisation of payment card data via PCI-DSS compliant processors
- Role-based access controls and least-privilege principles for internal staff
- Logging, monitoring, and incident detection on our infrastructure
- Secure software development practices and regular security reviews
- Contractual security obligations imposed on third-party service providers
- Secure retention and disposal procedures for personal information
While we strive to use commercially acceptable means to protect your personal information, no method of electronic storage or transmission is entirely secure, and we cannot guarantee absolute security. In the event of a security compromise affecting your personal information, we will notify you and the Information Regulator in accordance with POPIA.
11. Data Retention
We retain your personal information only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Specifically:
- Account information: Retained for the duration of your account and for a reasonable period after closure to address any follow-up queries, disputes, or legal requirements.
- Charging session and payment records: Retained for at least five (5) years from the end of the relevant tax year, in accordance with South African tax and financial record-keeping obligations.
- Host payout records: Retained for the duration of the Host partnership and for the period required by tax and accounting legislation thereafter.
- Support correspondence: Retained for a reasonable period for quality, training, and dispute resolution purposes.
- Marketing preferences and consent records: Retained while your account is active and as evidence of consent or opt-out.
- App usage and diagnostic data: Retained in identifiable form for a limited period, after which it is aggregated or anonymised.
When data is no longer required, it is securely deleted, anonymised, or aggregated in accordance with our data disposal procedures.
12. Your Rights
Right to Access
You have the right to request a copy of the personal information we hold about you. To exercise this right, contact us using the details in section 17. We may require proof of identity before fulfilling your request, and access may be subject to a legally allowable fee.
Right to Correction or Deletion
You have the right to ask us to update, correct, or delete your personal information. Most account details can be updated directly in the linqEV app or your account settings. We will require verification of your identity before making changes via our support team. Note that we may need to retain certain information for legal, tax, or fraud-prevention purposes even after a deletion request.
Right to Object
You have the right to object to the processing of your personal information where such processing is carried out on grounds other than consent or a legal obligation, and to opt out of direct marketing at any time.
Right to Complain
If you believe we have not handled your personal information lawfully, you may lodge a complaint with the Information Regulator (South Africa):
- Website: inforegulator.org.za
- Email: enquiries@inforegulator.org.za
13. Children's Privacy
The linqEV Services are not directed at, or intended for use by, children under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information without verifiable consent of a parent or guardian, please contact us and we will take steps to delete such information.
14. Marketing Communications
We will send you marketing communications about new linqEV features, promotions, network milestones, and partner offers only where you have opted in or where permitted by law.
You can opt out of marketing communications at any time by:
- Clicking the "unsubscribe" link in any marketing email
- Updating your notification preferences in the linqEV app
- Contacting us at support@linqev.com
Opting out of marketing will not affect transactional communications such as session receipts, charger fault notifications, subscription renewals, or other operational messages required to deliver the Services.
15. Consent & Withdrawal
By providing your personal information to us — through our website, the linqEV app, contact forms, or any other channel — you consent to its processing in accordance with this Privacy Policy.
You may withdraw your consent at any time by contacting us. Upon withdrawal, we will cease processing your personal information for the relevant purpose, subject to any legal obligations that require us to retain certain data. Please note that withdrawal of consent may affect our ability to provide the Services to you (for example, you cannot use the charging network without an active account).
When we delete data following consent withdrawal, we follow a secure deletion process to ensure your information is safely and completely removed from systems where retention is no longer required.
16. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, Services, or applicable legislation. Material changes will be communicated via the linqEV app, our website, or by email to the address associated with your account. We encourage you to review this policy periodically. Continued use of the Services after changes have been communicated constitutes acceptance of the revised Policy.
17. Contact Us
If you have any queries about this Privacy Policy, wish to exercise your rights, withdraw consent, or access or correct your personal information, please contact us: