Privacy Policy

1. Who We Are

Volnity provides integrated electric mobility and energy solutions, including:

• Electric vehicles, batteries, and battery swapping stations;
• Rider applications and operations applications;
• Fleet, rental, battery, and asset management platforms;
• IoT, big data, and artificial intelligence services;
• White-label software and private deployment services;
• Real-world asset, or RWA, technology and data infrastructure;
• Operational consulting and project incubation services.

For applicable data protection laws, the data controller responsible for your personal information is:

Where a local Volnity affiliate provides services to you, that affiliate may also act as a data controller or data processor.

2. Scope of This Policy

This Privacy Policy applies to personal information collected through:

• Volnity websites and landing pages;
• Contact, partnership, quotation, and demonstration request forms;
• Rider, operations, fleet, management, and RWA applications;
• SaaS and privately deployed software platforms;
• Battery swapping, vehicle, battery, charging, and IoT systems;
• Email, WhatsApp, telephone, and other business communications;
• Events, exhibitions, training sessions, and partnership meetings;
• Other services that link to this Privacy Policy.

This Privacy Policy does not apply to third-party websites or services that have their own privacy policies.

3. Information We Collect

The information we collect depends on how you interact with Volnity and which services you use.

3.1 Information You Provide to Us

You may provide us with:

• Your name;
• Email address;
• Telephone or WhatsApp number;
• Company name and job title;
• Country, city, and business location;
• Project requirements and estimated fleet size;
• Product, software, or partnership interests;
• Messages, documents, and other information submitted through forms;
• Meeting, demonstration, quotation, and support requests;
• Billing, invoicing, and payment information;
• Feedback, survey responses, and customer service communications.

3.2 Account and Platform Information

When you create or use an account, we may collect:

• Account name and user ID;
• Login credentials;
• Contact information;
• User role and access permissions;
• Language and regional preferences;
• Subscription, rental, or service plan information;
• Transaction and payment records;
• Support and maintenance history;
• Records of actions taken within the platform.

Passwords are stored using appropriate security controls and are not intended to be stored in readable form.

3.3 Vehicle, Battery, and IoT Information

When you use our connected mobility or energy services, we may collect operational information such as:

• Vehicle identification numbers;
• Battery serial numbers and BMS information;
• Swapping and charging records;
• Battery state of charge and state of health;
• Voltage, current, temperature, and fault information;
• Vehicle status, mileage, speed, and energy consumption;
• Swapping station status and operating records;
• Maintenance, repair, and diagnostic information;
• Approximate or precise location, where enabled and legally permitted;
• Device, SIM card, network, controller, and communication-module information.

Some IoT information may be associated with a rider, operator, account, vehicle, or business customer and may therefore constitute personal information.

3.4 RWA and Digital Asset Information

Where you use RWA-related services, we may collect:

• Wallet addresses;
• Digital asset holdings and transaction records;
• Asset subscription and redemption records;
• Staking and reward information;
• Project participation information;
• Records connecting digital assets with physical vehicles, batteries, or equipment;
• Identity verification and compliance information;
• Information required for KYC, AML, sanctions screening, or investor eligibility checks;
• Supporting identity, company, source-of-funds, or accreditation documents where required.

The exact information collected will depend on the project structure, service provider, jurisdiction, and applicable law.

3.5 Information Collected Automatically

When you visit our website or use our applications, we may automatically collect:

• IP address;
• Browser type and version;
• Device type and operating system;
• Device identifiers;
• Language and time-zone settings;
• Referring website or advertising source;
• Pages visited and features used;
• Date, time, and duration of visits;
• Application activity and diagnostic data;
• Crash reports and performance information;
• Cookie and similar technology identifiers.

3.6 Information from Third Parties

We may receive information from:

• Local operating partners;
• Distributors, agents, and service providers;
• Payment and financial service providers;
• Identity verification and compliance providers;
• Fleet operators and business customers;
• Public databases and company registries;
• Marketing, analytics, and event partners;
• Social media and communication platforms;
• Hardware and IoT integration partners.

We only use third-party information for legitimate business purposes and as permitted by applicable law.

4. How We Use Your Information

We may use personal information to:

• Respond to inquiries and partnership requests;
• Prepare quotations, proposals, and technical solutions;
• Provide products, software, and services;
• Create and manage user accounts;
• Process payments, subscriptions, rentals, and transactions;
• Operate vehicle, battery, charging, and swapping networks;
• Monitor equipment condition, performance, and safety;
• Provide remote diagnostics, maintenance, and technical support;
• Manage riders, vehicles, batteries, assets, partners, and service providers;
• Customize and localize our software;
• Integrate third-party vehicles, batteries, BMS systems, and IoT equipment;
• Improve product performance and user experience;
• Develop reports, analytics, forecasts, and AI-supported insights;
• Detect fraud, abuse, security incidents, and unauthorized activity;
• Verify identities and perform legal or compliance checks;
• Operate eligible RWA and digital asset services;
• Communicate service, security, and operational updates;
• Send marketing communications where permitted;
• Comply with legal, regulatory, tax, accounting, and contractual obligations;
• Establish, exercise, or defend legal claims;
• Protect Volnity, our customers, users, partners, and the public.

We may use aggregated or anonymized information for analytics, research, product development, business planning, and statistical purposes. Where information has been properly anonymized so that it can no longer identify an individual, it may no longer be considered personal information under applicable law.

5. Legal Bases for Processing

Where required by applicable law, we process personal information under one or more of the following legal bases:

Contract

Processing may be necessary to enter into or perform a contract with you, including providing software, hardware, rental, fleet, support, or other services.

Legitimate Interests

We may process information for legitimate business interests, including:

• Operating and improving our services;
• Responding to business inquiries;
• Protecting our systems and equipment;
• Preventing fraud and misuse;
• Developing products and business relationships;
• Managing customer and partner relationships.

We consider the potential impact on your rights before relying on legitimate interests.

Consent

We may rely on your consent for:

• Optional marketing communications;
• Non-essential cookies;
• Certain location services;
• Collection of information requiring consent under local law;
• Other activities where consent is legally required.

You may withdraw your consent at any time, although this will not affect processing that occurred before withdrawal.

Legal Obligations

We may process information to comply with legal, regulatory, tax, accounting, sanctions, KYC, AML, safety, or law-enforcement requirements.

Protection of Vital Interests

In limited circumstances, we may process information where necessary to protect the health, safety, or vital interests of an individual.

6. Cookies and Similar Technologies

We may use cookies, pixels, SDKs, local storage, and similar technologies to:

• Keep our websites and applications operating;
• Remember your preferences;
• Authenticate users;
• Protect accounts and systems;
• Understand website and application usage;
• Measure performance;
• Improve our services;
• Evaluate marketing campaigns;
• Provide relevant content or advertising, where permitted.

Cookies may include:

• Essential Cookies: Required for website operation, security, and account access.
• Preference Cookies: Remember language, location, and display preferences.
• Analytics Cookies: Help us understand how visitors use our services.
• Marketing Cookies: Measure campaigns or provide relevant advertising where used and legally permitted.

Where required, we will obtain your consent before placing non-essential cookies. You may manage cookies through our cookie banner or browser settings.

Disabling certain cookies may affect the operation of some website or platform features.

7. How We Share Information

We may share personal information with the following recipients where necessary:

Volnity Affiliates

We may share information among Volnity companies for administration, service delivery, technical support, project implementation, and business operations.

Service Providers

We may use service providers for:

• Cloud hosting and data storage;
• Website and software development;
• Communications and customer support;
• Payment processing;
• Data analytics;
• Cybersecurity;
• Identity verification and compliance;
• Logistics and installation;
• Accounting, audit, insurance, and professional advice.

Service providers are authorized to process information only for agreed purposes and subject to appropriate contractual obligations.

Business Customers and Local Partners

Where our services are provided through a local fleet operator, distributor, agent, project company, or white-label partner, relevant information may be shared with that organization to operate and support the service.

Hardware and Integration Partners

We may share limited technical information with vehicle, battery, BMS, swapping station, charging, IoT, and telecommunications partners where necessary for integration, diagnostics, maintenance, and safety.

Financial and RWA Service Providers

RWA-related information may be shared with regulated financial institutions, payment providers, digital asset service providers, custodians, auditors, trustees, KYC providers, legal advisers, smart-contract providers, or project issuers.

Legal and Regulatory Authorities

We may disclose information where required to:

• Comply with law, court orders, or regulatory requests;
• Respond to lawful requests from public authorities;
• Prevent fraud, money laundering, or illegal activity;
• Protect the rights, safety, and property of Volnity or others;
• Establish, exercise, or defend legal claims.

Business Transactions

Information may be disclosed as part of a merger, acquisition, financing, restructuring, asset sale, joint venture, or similar corporate transaction, subject to appropriate confidentiality and legal safeguards.

8. Sale or Sharing of Personal Information

We do not sell personal information for monetary consideration.

Where applicable law defines “sale” or “sharing” more broadly, certain analytics or advertising technologies may be treated as sharing personal information. Where required, we will provide relevant consent or opt-out controls.

We do not knowingly sell or share the personal information of children.

9. International Data Transfers

Volnity operates internationally, and your information may be transferred to or processed in countries other than the country where it was collected.

These countries may have different data protection laws. Where required, we use appropriate safeguards, which may include:

• Standard contractual clauses;
• Data processing agreements;
• Transfer impact assessments;
• Contractual confidentiality and security obligations;
• Local storage or localization arrangements;
• Other legally recognized transfer mechanisms.

Business customers using private deployment may be able to select dedicated hosting locations, depending on the agreed technical solution.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods may depend on:

• The duration of our relationship with you;
• The type of service provided;
• Contractual requirements;
• Product warranties and maintenance periods;
• Safety and operational requirements;
• Tax, accounting, and regulatory obligations;
• KYC, AML, and financial recordkeeping requirements;
• Applicable limitation periods;
• Ongoing disputes, investigations, or legal claims.

When information is no longer required, we will delete, anonymize, or securely isolate it, subject to applicable legal and technical requirements.

11. Blockchain and Public Ledger Information

Certain RWA or digital asset services may use public or permissioned blockchain networks.

Wallet addresses, digital asset transfers, smart-contract activity, transaction timestamps, and related blockchain records may be visible to other network participants or the public.

Information recorded on a blockchain may be permanent and may not be capable of being changed or deleted by Volnity.

Where reasonably possible, we avoid recording directly identifying personal information on public blockchains. Identity verification documents and similar personal information should generally be stored in controlled off-chain systems rather than directly on a public ledger.

Users should understand the transparency and permanence of blockchain transactions before using RWA or digital asset services.

12. Data Security

We use reasonable technical, organizational, and administrative measures designed to protect personal information, including measures such as:

• Access controls and user permissions;
• Authentication and password controls;
• Encryption where appropriate;
• Network and application security;
• System monitoring and logging;
• Data backup and recovery measures;
• Employee and service-provider confidentiality requirements;
• Security testing and vulnerability management;
• Incident response procedures;
• Segregation of customer and operational data where appropriate.

No website, network, communication method, or storage system is completely secure. We therefore cannot guarantee absolute security.

You are responsible for protecting your login credentials and notifying us promptly if you suspect unauthorized access to your account.

13. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• Be informed about how your information is used;
• Request access to your personal information;
• Request correction of inaccurate or incomplete information;
• Request deletion of your personal information;
• Request restriction of processing;
• Object to certain processing;
• Withdraw consent;
• Request a portable copy of certain information;
• Opt out of direct marketing;
• Opt out of certain sales, sharing, or targeted advertising;
• Request information about categories of data collected and disclosed;
• Lodge a complaint with a data protection authority;
• Receive information about significant automated decision-making;
• Appeal a decision concerning a privacy request where applicable.

These rights may be subject to legal exceptions. For example, we may need to retain information to comply with legal obligations, complete transactions, protect security, or establish legal claims.

Blockchain records that are outside Volnity’s control may not be capable of correction or deletion.

14. How to Exercise Your Rights

To submit a privacy request, contact us at:

Email: privacy@volnity.com

Email Subject: Privacy Rights Request

Please include:

• Your name;
• Your contact information;
• Your relationship with Volnity;
• The service or account concerned;
• The specific request you are making.

We may need to verify your identity before processing a request. Authorized representatives may submit requests where permitted by law, subject to appropriate authorization and identity verification.

We will not unlawfully discriminate against you for exercising your privacy rights.

15. Marketing Communications

Where permitted, we may send you information about:

• Volnity products and services;
• Partnership programs;
• Product launches;
• Industry events;
• Project opportunities;
• Operational and technical solutions;
• Relevant business updates.

You may unsubscribe by using the link in a marketing email or contacting us.

Even after opting out of marketing, you may continue to receive necessary service, security, transaction, account, or contractual communications.

16. Location Information

Certain rider, fleet, vehicle, swapping, safety, or asset-management services may require location information.

Where required, we will request permission before accessing precise location information through your device. You may manage location permissions through your device settings.

Disabling location access may prevent certain features—such as locating nearby swapping stations, vehicle tracking, route management, or asset protection—from functioning correctly.

Business fleet customers may separately determine how driver, rider, vehicle, or employee location information is used within their organization.

17. Automated Processing and Artificial Intelligence

We may use automated tools, analytics, or artificial intelligence to:

• Identify equipment faults;
• Predict battery or vehicle maintenance needs;
• Detect unusual activity;
• Analyze fleet and energy performance;
• Support customer service;
• Generate operational reports and recommendations;
• Improve system efficiency.

Unless separately disclosed, we do not use website visitor information to make solely automated decisions that produce legal or similarly significant effects.

Where applicable law provides rights relating to significant automated decisions, you may contact us to request additional information or human review.

18. Children’s Privacy

Our websites, products, and business services are not directed to children under the age of 16.

We do not knowingly collect personal information directly from children without appropriate authorization. If you believe that a child has provided personal information to us without proper consent, please contact us so that we can take appropriate action.

19. Third-Party Links and Services

Our websites and applications may contain links to third-party websites, wallets, payment services, social networks, communication platforms, mapping services, or blockchain services.

We do not control the privacy practices of independent third parties. You should review their privacy policies before providing personal information or using their services.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes to our products or services;
• New technologies;
• Changes to our data-processing activities;
• Legal or regulatory developments;
• Security or operational requirements.

The updated version will be published with a revised “Last Updated” date. Where required, we will provide additional notice or request renewed consent.

21. Contact Us

For questions, complaints, or requests concerning this Privacy Policy or our use of personal information, contact:

You may also have the right to complain to the data protection authority in your country or region.

For example, individuals in Kenya may contact the Office of the Data Protection Commissioner, while individuals in the United Kingdom may contact the Information Commissioner’s Office. Individuals in the European Economic Area may contact the supervisory authority responsible for their place of residence, employment, or the location of the alleged infringement.