Legal

Privacy Policy

BubbleCharge Inc.

Effective Date: September 01, 2026Last Updated: September 01, 2026
01

Introduction

BubbleCharge Inc. ("BubbleCharge," "BC," "we," "us," or "our") respects your privacy and is committed to handling your personal information responsibly, transparently, and securely.

BubbleCharge operates an online marketplace that connects electric vehicle ("EV") drivers with people that make EV charging equipment available through the BubbleCharge platform.

For purposes of this Privacy Policy, individuals who make EV charging equipment available through BubbleCharge are referred to as "Hosts," and individuals who search for, request, reserve, or use charging services through BubbleCharge are referred to as "Finders."

This Privacy Policy explains how BubbleCharge collects, uses, discloses, stores, protects, and otherwise processes personal information when you use the BubbleCharge website, account services, booking services, communications, payment services, identity verification services, and other products or services that link to this Privacy Policy (collectively, the "Services").

BubbleCharge currently operates throughout Canada, including Quebec. BubbleCharge also operates in the United States. Finders may sign up and use BubbleCharge in any U.S. state, subject to applicable law and BubbleCharge eligibility requirements. At the current time, Hosts may create and maintain charging listings in the United States only in Texas, Colorado, Georgia, Indiana, Michigan, Iowa, Montana, Oregon, Delaware, and New Hampshire.

This Privacy Policy applies to users in Canada and the United States, subject to any additional rights or requirements provided by the laws applicable to you.

Please read this Privacy Policy carefully.

1. Our Commitment to Privacy

BubbleCharge is committed to collecting and using personal information for identified and reasonable purposes and to limiting the information we collect to what is reasonably necessary for the operation and security of the Services.

We do not collect personal information simply because it may be useful in the future.

We seek to collect information that is relevant to providing the BubbleCharge marketplace, verifying accounts, facilitating bookings and payments, communicating with users, preventing fraud and abuse, protecting users and the platform, resolving disputes, complying with legal obligations, and improving the Services.

Where applicable law requires consent, BubbleCharge will obtain consent in the manner required by law.

Where applicable law permits the collection, use, or disclosure of personal information without consent, BubbleCharge may rely on the applicable legal exception.

2. Who Is Responsible for Your Personal Information

BubbleCharge Inc. is responsible for the personal information under its control.

BubbleCharge has designated a person responsible for privacy matters and privacy compliance.

Email: privacy@bubblecharge.com

The Privacy Officer is responsible for overseeing BubbleCharge's privacy practices, responding to privacy inquiries, receiving privacy complaints, and coordinating privacy requests.

The Privacy Officer may be supported by BubbleCharge personnel, professional advisers, service providers, or other individuals as reasonably necessary to address a privacy matter.

3. What Is Personal Information

"Personal Information" or "Personal Data" means information about an identifiable individual, or information that identifies, relates to, describes, or can reasonably be associated or linked with an identifiable individual, depending on the applicable law.

Personal information may include information such as your name, email address, telephone number, address, account information, vehicle information, transaction information, location information, identification information, communications, and information associated with your use of the Services.

Information that has been properly anonymized, de-identified, or aggregated so that it cannot reasonably be used to identify an individual may not be considered personal information under applicable law.

Where applicable law provides a different definition of personal information or personal data, the applicable legal definition will apply.

02

Information We Collect

4. Information We Collect

The information BubbleCharge collects depends on how you interact with the Services.

A Finder may provide different information from a Host, and additional information may be required when a user creates a listing, makes a booking, receives a payout, completes identity verification, contacts support, or reports an issue.

BubbleCharge may collect the following categories of information.

5. Account Information

When you create or maintain a BubbleCharge account, we may collect information such as your:

  • First and last name
  • Email address
  • Telephone or mobile number
  • Password or authentication information
  • Account identifier
  • User type
  • Country
  • Province, territory, or state
  • Postal or ZIP code
  • Account preferences
  • Account status
  • Account creation date
  • Information necessary to administer your account

Some information is required to create an account or use particular features.

If you do not provide information that is necessary to provide a requested Service, BubbleCharge may be unable to provide that Service.

6. Identity Verification Information

BubbleCharge may require users to complete identity verification before accessing certain Services.

Identity verification may be required to help protect the BubbleCharge community, reduce fraud, verify account ownership, support payment processing, protect Hosts and Finders, and meet legal or risk-management requirements.

Identity verification may be performed by BubbleCharge or by a third-party provider, including a payment or identity-verification provider.

Depending on the verification process, information may include your name, date of birth, address, identification information, government-issued identification information, verification status, and other information necessary to complete verification.

Where Stripe or another third-party provider performs verification directly, that provider may collect and process information under its own privacy policy and terms.

BubbleCharge may receive a verification result, status, account identifier, or other information needed to determine whether verification has been completed successfully.

BubbleCharge seeks to retain only the information reasonably necessary for its own legitimate purposes and does not intend to retain complete identity documents when retention is not necessary.

If a third-party provider independently retains information submitted during verification, that information may be subject to the provider's own retention practices and privacy policy.

7. Host Information

If you register as a Host, BubbleCharge may collect information necessary to create, operate, verify, and manage your charging listing.

This may include:

  • Host name
  • Email address
  • Telephone number
  • Property or charging-location address
  • Charger location
  • Charger type
  • Number of chargers
  • Charger-related information
  • Availability
  • Pricing
  • Session duration
  • Wi-Fi availability
  • Access instructions
  • Listing description
  • Booking information
  • Cancellation information
  • Payout information
  • Payment-provider information
  • Tax-related information where required
  • Communications with Finders
  • Communications with BubbleCharge
  • Dispute information
  • Information relating to incidents involving a listing or booking

A Host is responsible for ensuring that information provided to BubbleCharge is accurate and that the Host has the authority to provide the information and make the charging equipment available through the Services.

8. Finder Information

If you use BubbleCharge as a Finder, we may collect information such as:

  • Name
  • Email address
  • Telephone number
  • Address
  • Vehicle manufacturer
  • Vehicle model
  • Vehicle information you voluntarily provide
  • Booking date
  • Booking time
  • Requested session duration
  • Charging location
  • Check-in information
  • Booking history
  • Payment information received from payment providers
  • Cancellation information
  • Dispute information
  • Information provided to customer support

Vehicle information is collected to support charging-related functionality and help Hosts and Finders coordinate a booking.

BubbleCharge does not require information about your vehicle that is unrelated to the operation of the Services.

9. Charger and Listing Information

Hosts may provide information concerning the EV charging equipment they make available.

This may include:

  • Charger type
  • Charger quantity
  • Charger location
  • Availability
  • Price
  • Session duration
  • Access instructions
  • Wi-Fi availability
  • Listing description
  • Other information necessary to describe the charging opportunity

Certain information may be displayed to Finders so that they can search for and select charging opportunities.

Hosts should not include unnecessary personal, confidential, financial, security, or sensitive information in a public listing or description.

10. Booking Information

When a Finder requests or completes a booking, BubbleCharge may collect and retain information concerning the booking.

This may include:

  • Finder identity
  • Host identity
  • Charger location
  • Booking date
  • Start and end time
  • Duration
  • Price
  • Applicable fees
  • Payment status
  • Booking status
  • Check-in status
  • Cancellation status
  • Dispute information
  • Other information necessary to administer the booking

Booking information may be retained after a booking is completed where reasonably necessary for accounting, tax, customer support, fraud prevention, dispute resolution, legal compliance, or other legitimate purposes.

11. Communications and Customer Support

When you communicate with BubbleCharge, we may collect information contained in your communication.

This may include communications through:

  • Email
  • SMS
  • Customer support
  • Contact forms
  • Reports
  • Dispute forms
  • Other communication channels made available through the Services

We may retain records of communications when reasonably necessary to provide support, investigate a complaint, resolve a dispute, protect users, investigate fraud or abuse, enforce our Terms, or comply with legal obligations.

12. Payment Information

BubbleCharge uses third-party payment providers, including Stripe and related Stripe services, to process payments and facilitate payouts.

When you make or receive a payment through BubbleCharge, BubbleCharge may receive information such as:

  • Transaction identifier
  • Payment status
  • Amount
  • Currency
  • Booking associated with the transaction
  • Refund information
  • Dispute information
  • Chargeback information
  • Payout status
  • Payment-provider account identifier
  • Payment method type
  • Fraud or risk information

BubbleCharge does not intentionally store complete payment-card numbers when payment information is processed directly by Stripe or another payment provider.

Payment providers may independently collect and retain payment information under their own privacy policies and legal obligations.

13. Stripe Verification and Payment Services

BubbleCharge may use Stripe, Stripe Connect, Stripe Identity, or other Stripe services.

Stripe may collect personal information directly from you when required for payment processing, identity verification, account verification, fraud prevention, tax reporting, or payout purposes.

BubbleCharge may receive information from Stripe concerning the status or outcome of a verification, payment, payout, dispute, refund, or other transaction.

Information processed by Stripe may be subject to Stripe's own privacy policy, terms, security controls, and retention practices.

BubbleCharge does not control information that Stripe is required to retain independently for its own legal, regulatory, fraud-prevention, or contractual purposes.

14. Address Information

BubbleCharge may collect addresses from Hosts and Finders.

For Hosts, an address may be necessary to identify the location where charging is offered.

For Finders, an address may be collected as part of account, booking, verification, payment, fraud-prevention, or other Services.

Address information may also be used to provide mapping functionality and determine geographic availability.

BubbleCharge seeks to limit disclosure of residential or personal address information to what is reasonably necessary for the Services.

15. Location Information

Location is an important component of BubbleCharge because the Services allow Finders to locate nearby EV charging opportunities.

BubbleCharge may receive location information that you provide directly, such as an address or location entered into a search.

Where you give your permission through your browser or device, BubbleCharge may also receive location information made available by your device.

Location information may include approximate or precise geographic coordinates depending on the permissions granted and functionality used.

BubbleCharge may use location information to:

  • Display nearby chargers
  • Improve search results
  • Display maps
  • Assist with navigation-related functionality
  • Determine geographic availability
  • Support booking functionality
  • Help prevent fraud
  • Investigate disputes
  • Protect platform security
  • Improve the Services

BubbleCharge does not require continuous background location tracking merely to maintain a basic account.

You may be able to control location permissions through your browser or device settings. Disabling location access may prevent certain location-based features from functioning correctly.

16. Mapbox and Map Services

BubbleCharge uses mapping and location technology, including Mapbox, to provide mapping and geographic functionality.

When you use a map or location-related feature, certain information may be processed by Mapbox or another mapping provider.

Depending on the feature, this may include:

  • Search location
  • Address
  • Geographic coordinates
  • IP address
  • Device information
  • Browser information
  • Technical information required to display maps

Mapbox processes information under its own terms and privacy practices.

BubbleCharge uses mapping services to operate and improve the EV charging marketplace and does not use mapping information for purposes unrelated to the Services unless permitted by applicable law.

17. Device and Technical Information

When you access BubbleCharge, our systems may automatically receive certain technical information necessary to operate and secure the Services.

This may include:

  • IP address
  • Browser type
  • Operating system
  • Device type
  • Device information
  • Language
  • Time zone
  • Network information
  • Date and time of access
  • Login activity
  • Error information
  • Security logs
  • Pages requested
  • Technical information transmitted by your browser

This information may be used for security, authentication, troubleshooting, fraud prevention, performance monitoring, and maintaining the Services.

18. Server Logs and Security Logs

BubbleCharge may maintain server and security logs.

These logs may contain information such as IP addresses, timestamps, authentication events, account identifiers, error information, requests made to the Services, and other technical information.

Security logs may be used to detect:

  • Unauthorized access
  • Automated attacks
  • Fraud
  • Account abuse
  • Security vulnerabilities
  • Malicious activity
  • Other threats to BubbleCharge or its users

Security logs may be retained for periods reasonably necessary for security, investigation, legal, and operational purposes.

03

Cookies, Communications & Providers

19. Cookies and Tracking Technologies

BubbleCharge does not currently use cookies, advertising pixels, web beacons, or similar tracking technologies for advertising or cross-site behavioral tracking.

BubbleCharge does not currently use cookies to build advertising profiles about users.

If BubbleCharge introduces cookies or similar technologies in the future, BubbleCharge will update this Privacy Policy and provide any notices or consent mechanisms required by applicable law.

A third-party service used by BubbleCharge may independently use technologies that are necessary for that provider's service. Such third-party processing may be governed by the third party's own privacy policy.

20. Email Communications

BubbleCharge may send email communications necessary to operate the Services.

These may include:

  • Account verification
  • Password or account recovery
  • Booking confirmations
  • Booking changes
  • Payment notifications
  • Cancellation notices
  • Security alerts
  • Identity verification information
  • Customer support
  • Legal notices
  • Important service announcements
  • Promotional communications where permitted by law

BubbleCharge may use third-party email service providers to deliver these communications.

Transactional, security, legal, and booking-related emails may continue even if you unsubscribe from promotional communications.

21. SMS Communications

BubbleCharge may use SMS messages for:

  • Phone verification
  • Authentication
  • Security
  • Booking notifications
  • Booking changes
  • Customer support
  • Service notifications
  • Other communications necessary to provide the Services

BubbleCharge may use third-party communications providers, including Twilio.

Where required by law, BubbleCharge will obtain appropriate consent before sending commercial or marketing SMS messages.

You may opt out of promotional communications where applicable. Operational or security-related communications may continue when necessary to provide the Services.

Message and data rates may apply depending on your mobile service provider.

22. Google Sign-In and Authentication

BubbleCharge may allow you to create or access your account using Google Sign-In or another supported authentication provider.

If you use such a service, BubbleCharge may receive information authorized by you, such as:

  • Name
  • Email address
  • Account identifier
  • Profile information
  • Authentication status

BubbleCharge does not receive your Google password through standard third-party authentication.

Your use of Google or another authentication service is also subject to that provider's privacy practices.

23. Information from Third Parties

BubbleCharge may receive personal information from third parties where reasonably necessary to operate the Services.

Third parties may include:

  • Stripe
  • Identity verification providers
  • Payment processors
  • Mapbox
  • Authentication providers
  • SMS providers
  • Email providers
  • Cloud hosting providers
  • Security providers
  • Fraud prevention providers
  • Other service providers
  • Hosts
  • Finders
  • Government or regulatory authorities where legally permitted or required

BubbleCharge does not purchase personal information from data brokers for the purpose of creating advertising profiles about users.

04

How We Use Information

24. How We Use Personal Information

BubbleCharge may use personal information for the following purposes.

First, we use information to provide and operate the Services, including creating accounts, displaying charging listings, facilitating bookings, processing payments, facilitating payouts, communicating with users, providing customer support, and administering transactions.

Second, we use information to verify users and maintain trust and safety. This may include identity verification, payment verification, fraud detection, security monitoring, investigation of suspicious activity, and enforcement of platform rules.

Third, we use information to communicate with users about bookings, accounts, payments, security, technical problems, legal matters, and other matters relating to the Services.

Fourth, we use information to resolve disputes and investigate reports concerning cancellations, payments, charger access, damage, fraud, account misuse, or violations of our Terms.

Fifth, we use information to maintain, troubleshoot, secure, test, and improve BubbleCharge.

Sixth, we may use information to comply with applicable laws, regulations, court orders, tax requirements, accounting obligations, regulatory requests, and lawful government requests.

25. Legal Bases for Processing

Depending on the jurisdiction, BubbleCharge may process personal information because:

  • You have provided consent
  • Processing is necessary to provide a requested Service
  • Processing is necessary to perform a contract
  • Processing is required by law
  • Processing is necessary to protect users or the Services
  • Processing is necessary for fraud prevention or security
  • Processing is otherwise permitted under applicable privacy law
  • Another lawful basis applies

Where BubbleCharge relies on consent, you may withdraw consent where applicable law permits.

Withdrawal of consent may affect BubbleCharge's ability to provide certain Services.

26. Limiting Collection

BubbleCharge seeks to collect personal information that is adequate, relevant, and reasonably necessary for identified purposes.

We do not intentionally collect information indiscriminately.

If information is optional, BubbleCharge may identify it as optional where appropriate.

If you decline to provide information that is necessary for a particular feature, we may be unable to provide that feature.

05

Sharing & Disclosure

27. Information Shared Between Hosts and Finders

BubbleCharge is a marketplace, and certain information must be shared between Hosts and Finders to facilitate a booking.

Depending on the circumstances, a Host may receive information such as the Finder's name, vehicle information, booking date and time, session duration, relevant booking message, and information necessary to provide access to the charger.

A Finder may receive information such as the Host's name or account information, charger location, charger information, booking information, access instructions, and relevant communications.

BubbleCharge seeks to limit the personal information disclosed between users to information reasonably necessary for the applicable booking, communication, safety, or dispute.

Users should not request unnecessary personal information from another user.

28. Public and Private Information

Certain information associated with a Host's charging listing may be displayed to Finders because it is necessary to operate the marketplace.

This may include charging location, charger type, availability, price, session information, and listing descriptions.

Hosts should understand that information necessary to locate and use their charging location may be disclosed to a Finder who books the charger.

Hosts should not include passwords, financial information, government identification numbers, or unnecessary personal information in listing descriptions or access instructions.

29. Service Providers

BubbleCharge relies on service providers to operate the Services.

These may include providers of:

  • Payment processing
  • Identity verification
  • Mapping
  • Email delivery
  • SMS delivery
  • Cloud hosting
  • Database services
  • Authentication
  • Cybersecurity
  • Fraud prevention
  • Technical infrastructure
  • Customer support

Service providers may process personal information on BubbleCharge's behalf.

BubbleCharge seeks to use contractual, technical, or other appropriate safeguards designed to require service providers to protect personal information and process it only for authorized purposes.

30. When We Disclose Personal Information

BubbleCharge may disclose personal information in the following circumstances.

We may disclose information to Hosts and Finders when necessary to facilitate a booking.

We may disclose information to service providers that perform services for BubbleCharge.

We may disclose information to payment and identity verification providers.

We may disclose information when required or permitted by law.

We may disclose information to protect the rights, safety, property, or security of BubbleCharge, our users, or others.

We may disclose information to investigate fraud, abuse, security incidents, unlawful activity, or violations of our Terms.

We may disclose information to professional advisers, such as lawyers, accountants, auditors, insurers, or other advisers, where reasonably necessary.

31. Legal Requests and Law Enforcement

BubbleCharge may disclose personal information when required or permitted by applicable law.

This may include responding to:

  • Court orders
  • Subpoenas
  • Warrants
  • Government requests
  • Regulatory investigations
  • Legal proceedings
  • Tax authorities
  • Other legally valid requests

Where legally permitted, BubbleCharge may assess the validity and scope of a request before responding.

32. Corporate Transactions

If BubbleCharge participates in a merger, acquisition, financing, investment, restructuring, bankruptcy, reorganization, sale of assets, or similar transaction, personal information may be transferred as part of the transaction.

Where required by law, BubbleCharge will provide notice or obtain consent.

A successor organization may be required to continue protecting personal information in accordance with applicable law.

06

Hosts, Tax, Fraud & Safety

33. Business Hosts

Some Hosts may operate as businesses rather than individuals.

Business Hosts may provide information about owners, employees, representatives, or other individuals.

BubbleCharge may process such information to establish and administer the Host account, verify identity, process payments and payouts, facilitate bookings, communicate with the Host, prevent fraud, and comply with legal obligations.

Where applicable law distinguishes business information from personal information, BubbleCharge will apply the applicable legal requirements.

34. Tax, Accounting, and Recordkeeping

BubbleCharge may retain transaction and account information for tax, accounting, payment, financial reporting, dispute resolution, fraud prevention, and legal purposes.

This may include:

  • Booking amounts
  • Fees
  • Payments
  • Payouts
  • Refunds
  • Chargebacks
  • Tax information
  • Transaction dates
  • Payment-provider records

BubbleCharge may disclose such information to accountants, tax professionals, payment providers, government authorities, and other parties where reasonably necessary or legally required.

35. Fraud Prevention

BubbleCharge may use personal information to detect, prevent, investigate, and respond to fraudulent or abusive activity.

This may include evaluating:

  • Account information
  • Identity verification status
  • Payment activity
  • Booking activity
  • IP address
  • Device information
  • Location information
  • Communication history
  • Reports
  • Disputes
  • Other information relevant to platform security

BubbleCharge may restrict, suspend, or terminate accounts when permitted under the Terms of Service and applicable law.

36. Safety and Security

BubbleCharge may process personal information to protect the safety and security of users and the Services.

This may include investigating reports of:

  • Unauthorized access
  • Fraud
  • Harassment
  • Abuse
  • Threats
  • Misuse of the Services
  • Unauthorized charging access
  • Payment fraud
  • Identity fraud
  • Other conduct that may violate our policies or applicable law

37. Reviews, Reports, and Feedback

If BubbleCharge provides functionality allowing users to submit reports, feedback, or other content, BubbleCharge may collect and process that information.

We may use such information to:

  • Improve the Services
  • Investigate complaints
  • Enforce platform rules
  • Improve safety
  • Resolve disputes
  • Understand user experience

Information that you intentionally make public may be viewed by other users.

07

Sale, Advertising & Sensitive Information

38. De-Identified and Aggregated Information

BubbleCharge may create aggregated, statistical, or de-identified information that cannot reasonably be used to identify an individual.

This may include information about:

  • Charging demand
  • Booking volumes
  • Charger availability
  • General geographic trends
  • Session duration
  • Platform performance
  • Other aggregated marketplace activity

BubbleCharge may use and disclose such information where permitted by applicable law.

Where applicable law imposes restrictions on re-identification, BubbleCharge will comply with those restrictions.

39. BubbleCharge Does Not Sell Personal Information

BubbleCharge does not sell users' personal information to data brokers or advertisers for monetary consideration.

BubbleCharge's business is based on providing the EV charging marketplace and related Services.

BubbleCharge does not sell users' personal information merely because information is processed by Stripe, Mapbox, Twilio, email providers, hosting providers, or other service providers.

A service provider processing information on BubbleCharge's behalf is not considered a sale simply because it receives information necessary to provide its contracted services, subject to applicable law.

If BubbleCharge changes its business model in a way that creates a legally defined "sale," "sharing," or similar activity, BubbleCharge will update its privacy practices and provide legally required notices and choices.

40. Targeted Advertising

BubbleCharge does not currently use personal information for cross-context behavioral advertising.

BubbleCharge does not currently operate an advertising business based on users' personal information.

If BubbleCharge introduces targeted advertising in the future, it will do so in accordance with applicable law and will provide required notices and opt-out rights.

41. Sensitive Personal Information

Some information may be considered sensitive personal information under applicable law.

Depending on the circumstances, this may include:

  • Government identification information
  • Precise geolocation
  • Certain financial information
  • Certain authentication information
  • Biometric information processed by a verification provider
  • Other information legally classified as sensitive

BubbleCharge limits collection and use of sensitive information to purposes reasonably necessary to provide the Services, protect users, prevent fraud, comply with law, or otherwise as permitted by applicable law.

Where applicable law requires consent for sensitive information, BubbleCharge will obtain the required consent.

42. Biometric Information

If an identity-verification provider uses biometric technology as part of its verification process, such processing may occur directly through that provider.

BubbleCharge will not intentionally use biometric information for advertising purposes.

Where applicable law requires specific notice or consent for biometric processing, the applicable provider or BubbleCharge will provide the required notice and obtain the required consent.

BubbleCharge seeks to receive and retain verification results or other information reasonably necessary for the Services rather than unnecessary copies of biometric data.

08

Retention & Security

43. Data Retention

BubbleCharge retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Retention periods may depend on:

  • The nature of the information
  • The purpose for which it was collected
  • Whether the information is required to provide the Services
  • Transaction requirements
  • Tax and accounting requirements
  • Fraud prevention
  • Security
  • Dispute resolution
  • Legal obligations
  • Regulatory requirements
  • Potential legal claims

Different categories of information may therefore be retained for different periods.

When information is no longer reasonably necessary and there is no legal or legitimate reason to retain it, BubbleCharge may delete, destroy, anonymize, or de-identify it.

44. Account Closure and Deletion

You may request closure or deletion of your BubbleCharge account.

Closing an account does not necessarily require immediate deletion of every record associated with the account.

BubbleCharge may retain information where reasonably necessary to:

  • Complete or document a transaction
  • Process refunds
  • Resolve disputes
  • Prevent fraud
  • Protect platform security
  • Comply with tax or accounting obligations
  • Comply with legal requirements
  • Establish, exercise, or defend legal claims
  • Fulfill another lawful purpose

Where information is retained, BubbleCharge will continue to protect it in accordance with applicable law.

45. Data Security

BubbleCharge uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, theft, misuse, alteration, disclosure, or destruction.

Safeguards may include:

  • Access controls
  • Authentication
  • Encryption where appropriate
  • Secure transmission
  • Security monitoring
  • Logging
  • Restricted access
  • Vendor security controls
  • Account protections
  • Fraud detection
  • Other measures appropriate to the nature and sensitivity of the information

No electronic system or method of Internet transmission can be guaranteed to be completely secure.

Accordingly, BubbleCharge cannot guarantee absolute security of personal information.

46. User Account Security

You are responsible for maintaining the security of your account credentials.

You should use appropriate security practices and should not share passwords, authentication codes, or other security credentials with another person.

If you believe that your account has been compromised or accessed without authorization, you should notify BubbleCharge promptly.

BubbleCharge may take reasonable steps to secure an account following a suspected compromise.

47. Privacy Incidents and Data Breaches

BubbleCharge maintains procedures intended to identify, investigate, contain, and respond to privacy and security incidents.

If BubbleCharge determines that a privacy or security incident creates a legal notification obligation, BubbleCharge will provide notices to affected individuals, regulators, or other parties as required by applicable law.

The timing, content, and method of notification may depend on the circumstances and applicable legal requirements.

09

Canada

48. International and Cross-Border Data Processing

BubbleCharge is a Canadian corporation operating in Canada and the United States.

Personal information may therefore be processed, stored, or accessed in Canada, the United States, or another jurisdiction where BubbleCharge or its service providers operate.

Privacy laws in those jurisdictions may differ from the laws of the jurisdiction where you live.

Where applicable law requires additional safeguards for an international transfer, BubbleCharge will take the required steps.

49. Canada — Privacy Law

BubbleCharge is subject to applicable Canadian privacy legislation governing private-sector organizations.

Depending on the province, territory, nature of the activity, and circumstances, this may include federal PIPEDA and applicable provincial privacy legislation.

PIPEDA establishes principles including accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, and challenging compliance.

BubbleCharge intends to manage personal information in accordance with these principles where PIPEDA applies.

50. Canada — Accountability

BubbleCharge is responsible for personal information under its control.

BubbleCharge has designated a Privacy Officer who is responsible for privacy compliance and privacy-related inquiries.

BubbleCharge maintains privacy practices intended to address:

  • Collection
  • Consent
  • Use
  • Disclosure
  • Retention
  • Security
  • Access
  • Correction
  • Complaints
  • Privacy incident response

Canadian privacy guidance specifically recognizes organizational accountability and designation of a person responsible for privacy compliance.

51. Canada — Identifying Purposes

BubbleCharge identifies the purposes for collecting personal information at or before the time information is collected where required by applicable law.

Purposes may include:

  • Account creation
  • Identity verification
  • Booking
  • Payment
  • Host payout
  • Customer support
  • Fraud prevention
  • Security
  • Communications
  • Mapping
  • Dispute resolution
  • Legal compliance
  • Platform improvement

If BubbleCharge intends to use personal information for a materially different purpose, BubbleCharge will provide notice and obtain additional consent where required.

Canadian privacy guidance requires organizations to identify collection purposes and obtain additional consent where a new purpose is identified, subject to applicable exceptions.

52. Canada — Consent

Where consent is required, BubbleCharge seeks meaningful consent.

Depending on the sensitivity of the information and the circumstances, consent may be express or implied where legally permitted.

For sensitive information or uses that would not reasonably be expected, BubbleCharge may seek express consent.

You may withdraw consent where applicable law permits.

Withdrawal of consent may affect BubbleCharge's ability to provide certain Services.

53. Canada — Limiting Collection

BubbleCharge limits personal information collection to information reasonably necessary for identified purposes.

Canadian privacy guidance states that organizations should not collect information indiscriminately and should limit collection to information necessary for identified purposes.

54. Canada — Limiting Use, Disclosure, and Retention

BubbleCharge generally uses or discloses personal information only for the purposes for which it was collected, for compatible or reasonably expected purposes where permitted, with consent where required, or where permitted or required by law.

BubbleCharge retains personal information only as long as reasonably necessary for identified purposes or as required or permitted by law.

Canadian privacy guidance specifically requires organizations to limit use, disclosure, and retention.

55. Canada — Safeguards

BubbleCharge uses safeguards appropriate to the sensitivity of personal information.

More sensitive information may require stronger protections.

BubbleCharge also seeks to impose appropriate privacy and security obligations on service providers that process personal information on BubbleCharge's behalf.

Canadian privacy guidance requires organizations to protect personal information using safeguards appropriate to its sensitivity.

56. Canada — Access and Correction

Subject to applicable legal exceptions, you may request access to personal information BubbleCharge holds about you.

You may also request correction of inaccurate or incomplete personal information.

Canadian privacy guidance recognizes individuals' rights to access their personal information and challenge its accuracy and completeness.

Requests should be sent to:

privacy@bubblecharge.com

57. Canada — Privacy Complaints

If you have a concern regarding BubbleCharge's handling of personal information, we encourage you to contact the BubbleCharge Privacy Officer first.

BubbleCharge will review and investigate privacy complaints in accordance with applicable law and its internal procedures.

If you are not satisfied with the response, you may have the right to complain to the privacy regulator with jurisdiction over the matter, including the Office of the Privacy Commissioner of Canada or an applicable provincial privacy regulator.

10

Quebec

58. Quebec — Law 25

BubbleCharge operates in Quebec and recognizes the additional privacy requirements applicable under Quebec's private-sector privacy legislation, including amendments commonly referred to as Law 25, where applicable.

Quebec's privacy framework includes requirements relating to privacy governance, consent, privacy impact assessments, privacy by default, confidentiality incidents, retention and destruction, and communications of personal information outside Quebec.

BubbleCharge will comply with applicable Quebec privacy requirements.

59. Quebec — Privacy Officer

BubbleCharge's Privacy Officer is responsible for the protection of personal information.

Privacy Officer

BubbleCharge Inc.

Email: privacy@bubblecharge.com

The Privacy Officer may delegate operational responsibilities while retaining overall responsibility for BubbleCharge's privacy program.

60. Quebec — Consent

Where consent is required under Quebec law, BubbleCharge will seek consent in accordance with applicable requirements.

Where information is sensitive, BubbleCharge will obtain express consent where required.

Consent requests will be presented in a manner intended to allow users to understand the nature and purpose of the collection, use, or disclosure.

61. Quebec — Necessary Information

BubbleCharge seeks to collect only information necessary for the purposes for which it is collected.

Where information is not necessary to provide a requested Service, BubbleCharge may identify it as optional where appropriate.

62. Quebec — Privacy Impact Assessments

BubbleCharge may conduct privacy impact assessments when required by Quebec law.

This may include certain activities involving:

  • New information systems
  • Changes to information systems involving personal information
  • Electronic services
  • Communications of personal information outside Quebec
  • Other activities requiring an assessment

Where required, BubbleCharge will consider the privacy risks associated with the activity and implement appropriate safeguards.

63. Quebec — Privacy by Default

Where applicable, BubbleCharge seeks to configure privacy settings so that users receive an appropriate level of privacy by default.

BubbleCharge will not intentionally make personal information public merely because a user creates an account where such disclosure is unnecessary.

Certain information may nevertheless need to be disclosed to facilitate a Host listing or booking.

64. Quebec — Communication Outside Quebec

BubbleCharge may use service providers located outside Quebec.

Before communicating personal information outside Quebec where Quebec law requires an assessment or other safeguards, BubbleCharge will take the steps required by applicable law.

This may include assessing the applicable privacy protections and implementing contractual or other safeguards.

65. Quebec — Retention and Destruction

BubbleCharge retains personal information only as long as necessary for the identified purposes or as otherwise permitted or required by law.

When information is no longer required, BubbleCharge may destroy or anonymize it in accordance with applicable requirements and internal retention procedures.

66. Quebec — Privacy Incidents

BubbleCharge maintains procedures for responding to confidentiality incidents.

Where an incident presents a risk of serious injury or other legally defined risk requiring notification under Quebec law, BubbleCharge will provide notifications and take other required steps.

67. Quebec — Access, Correction, and Complaints

Quebec users may contact the BubbleCharge Privacy Officer regarding requests to access or correct personal information or concerns regarding privacy.

Requests should be directed to:

privacy@bubblecharge.com

Users may also have rights to make a complaint to the Commission d'accès à l'information du Québec.

11

United States

68. United States — General Privacy Rights

BubbleCharge operates in the United States while currently limiting Host registrations to:

Texas, Colorado, Georgia, Indiana, Michigan, Iowa, Montana, Oregon, Delaware, and New Hampshire.

Finders may sign up from any U.S. state, subject to applicable law and BubbleCharge eligibility requirements.

The fact that a state is not currently open to Hosts does not necessarily mean its privacy law cannot apply to a Finder who resides there.

State privacy laws differ in their definitions, thresholds, exemptions, rights, and applicability.

Where a state privacy law applies to BubbleCharge, BubbleCharge will provide the rights and disclosures required by that law.

69. U.S. Privacy Rights

Depending on the state in which you reside and the applicable law, you may have rights including:

  • Access to personal information
  • Confirmation of processing
  • Correction of inaccurate information
  • Deletion
  • Data portability
  • Information concerning categories of information collected
  • Information concerning categories of third parties receiving information
  • Opt-out of certain targeted advertising
  • Opt-out of certain sales of personal information
  • Opt-out of certain profiling
  • Appeal of a privacy-request decision
  • Other rights provided by applicable law

These rights may be subject to legal exceptions, verification requirements, statutory thresholds, and other limitations.

70. Texas

Where the Texas Data Privacy and Security Act ("TDPSA") applies, Texas residents may have rights including access, correction, deletion, portability, and certain opt-out rights.

The TDPSA also provides rights concerning targeted advertising, sale of personal data, and certain profiling.

BubbleCharge does not sell personal information for monetary consideration and does not currently conduct targeted advertising.

BubbleCharge will provide applicable Texas rights and request procedures where required.

71. Colorado

Where the Colorado Privacy Act ("CPA") applies, Colorado residents may have rights including access, correction, deletion, portability, and certain opt-out rights.

Colorado recognizes Global Privacy Control ("GPC") as a recognized universal opt-out mechanism for applicable opt-out rights.

Because BubbleCharge does not currently sell personal information or conduct targeted advertising, there may be no corresponding sale or targeted-advertising activity to opt out of.

If BubbleCharge's practices change, applicable opt-out mechanisms will be updated as required.

72. Georgia

Where applicable Georgia privacy law provides rights to a BubbleCharge user, BubbleCharge will provide those rights in accordance with applicable law.

Because privacy legislation and regulatory requirements may change, BubbleCharge may update this section as applicable requirements develop.

73. Indiana

Where applicable Indiana privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable access, correction, deletion, portability, and opt-out rights and other protections required by law.

74. Michigan

Where applicable Michigan privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable rights and request mechanisms required by law.

75. Iowa

Where applicable Iowa privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable privacy rights and request mechanisms required by law.

76. Montana

Where applicable Montana privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable access, correction, deletion, portability, and opt-out rights required by law.

BubbleCharge will also comply with applicable requirements concerning sensitive information and precise location information.

77. Oregon

Where applicable Oregon privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable rights concerning access, correction, deletion, portability, and legally applicable opt-outs.

BubbleCharge does not sell users' precise geolocation information.

Where Oregon law imposes restrictions on precise geolocation processing, BubbleCharge will comply with those requirements.

78. Delaware

Where applicable Delaware privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable access, correction, deletion, portability, opt-out, and other rights required by law.

79. New Hampshire

Where applicable New Hampshire privacy law provides rights to a BubbleCharge user, BubbleCharge will provide applicable access, correction, deletion, portability, opt-out, appeal, and other rights required by law.

80. California Users

Although California is not currently an approved state for Hosts, California residents may use BubbleCharge as Finders.

Where the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), applies, California residents may have rights including:

  • The right to know
  • The right to access
  • The right to correct
  • The right to delete
  • The right to opt out of sale or sharing where applicable
  • The right to limit certain uses of sensitive personal information
  • The right to non-discrimination for exercising applicable rights
  • Other rights provided by California law

BubbleCharge does not sell personal information for monetary consideration.

BubbleCharge also does not currently conduct cross-context behavioral advertising.

If applicable California law considers any future processing activity to constitute "sale" or "sharing," BubbleCharge will provide the required disclosures and opt-out mechanisms.

81. Other U.S. States

U.S. privacy laws continue to develop.

If you reside in a state not specifically described in this Privacy Policy and your state's privacy law provides rights applicable to BubbleCharge, BubbleCharge will provide those rights as required by applicable law.

This Privacy Policy may be updated as new laws become applicable.

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Privacy Requests

82. How to Submit a Privacy Request

You may submit a privacy request by emailing:

privacy@bubblecharge.com

You may request, where applicable:

  • Access
  • Correction
  • Deletion
  • Portability
  • Information about collection and disclosure
  • Withdrawal of consent
  • Opt-out of applicable processing
  • An appeal of a privacy decision
  • Other rights provided by applicable law

83. Identity Verification for Privacy Requests

BubbleCharge may need to verify your identity before responding to a privacy request.

Verification is intended to prevent unauthorized individuals from obtaining, deleting, modifying, or otherwise accessing another person's personal information.

The amount and type of verification information requested will depend on the nature and sensitivity of the request.

BubbleCharge will not intentionally require unnecessary information solely for the purpose of submitting a privacy request.

84. Authorized Agents

Where applicable law allows an authorized agent to submit a request on your behalf, BubbleCharge may require evidence of the agent's authorization.

BubbleCharge may also verify the identity of the individual whose information is the subject of the request.

85. Privacy Request Response Times

BubbleCharge will respond to privacy requests within the time period required by applicable law.

Where applicable law permits an extension, BubbleCharge may extend the response period when reasonably necessary.

If BubbleCharge denies a request, BubbleCharge will provide an explanation where required and will provide information regarding appeal rights where applicable.

86. Privacy Appeals

Where applicable law provides an appeal process, you may appeal a BubbleCharge privacy decision by contacting:

privacy@bubblecharge.com

The appeal should identify the original request and explain why you believe the decision should be reconsidered.

BubbleCharge will review applicable appeals in accordance with the requirements of the applicable law.

87. Non-Discrimination

BubbleCharge will not unlawfully discriminate against a person for exercising a privacy right protected by applicable law.

Where required by law, BubbleCharge will not unlawfully:

  • Deny Services
  • Charge a different price
  • Provide a different quality of Services
  • Penalize a user solely because the user exercised a legally protected privacy right

A Service may nevertheless become unavailable where the information necessary to provide that Service is lawfully deleted or where consent necessary to provide that Service is withdrawn.

88. Data Portability

Where applicable law provides a right to data portability, BubbleCharge may provide personal information in a portable and reasonably usable format.

Portability rights may be subject to applicable legal exceptions.

89. Correction

If you believe information held by BubbleCharge is inaccurate or incomplete, you may request correction.

BubbleCharge may verify the requested correction before making changes.

Where appropriate, BubbleCharge will correct the information or note the dispute in accordance with applicable law.

90. Deletion

Where applicable law gives you the right to request deletion, BubbleCharge will consider and process the request in accordance with that law.

Deletion may be subject to exceptions.

BubbleCharge may retain information necessary for legal compliance, security, fraud prevention, accounting, tax, dispute resolution, or establishment or defense of legal claims.

91. Withdrawing Consent

Where BubbleCharge relies on consent, you may withdraw consent where permitted by law.

Withdrawal does not affect processing that occurred before the withdrawal.

Withdrawal may prevent BubbleCharge from providing certain features or Services where the information is necessary to provide them.

13

Children, Third Parties & User Duties

92. Children and Minors

BubbleCharge is intended for adults.

The Services are not intended for children under 18 years of age.

BubbleCharge does not knowingly permit children under 18 to create or maintain accounts.

If BubbleCharge learns that an account was created by an individual under 18 in violation of our requirements, BubbleCharge may take steps to close the account and address associated information in accordance with applicable law.

If you believe a minor has provided personal information to BubbleCharge, contact:

privacy@bubblecharge.com

93. Third-Party Websites

BubbleCharge may provide links to third-party websites, services, applications, or resources.

This Privacy Policy does not apply to third-party websites or services that BubbleCharge does not control.

Third-party services may have their own privacy policies.

You should review those policies before providing personal information directly to a third party.

94. Third-Party Privacy Policies

Third-party providers used by BubbleCharge may independently process information under their own privacy policies.

These may include payment, identity verification, mapping, email, SMS, authentication, hosting, and other service providers.

BubbleCharge does not control the independent privacy practices of third parties.

Where BubbleCharge uses a third party as a service provider processing information on BubbleCharge's behalf, BubbleCharge seeks to establish appropriate contractual and other protections.

95. Data Relating to Vehicles

BubbleCharge may collect vehicle information voluntarily provided by Finders.

This may include:

  • Vehicle manufacturer
  • Vehicle model
  • Charging-related information
  • Other vehicle information voluntarily entered by the user

Vehicle information may be used to facilitate charger discovery, bookings, communication, and other charging-related Services.

BubbleCharge does not need to collect information about your vehicle that is unrelated to the Services.

96. Location and Privacy

Because BubbleCharge is an EV charging marketplace, location information is necessary for many core features.

For example, BubbleCharge may need to know the location of a charging listing to display it on a map.

BubbleCharge may also process a Finder's location to help display nearby charging opportunities.

Users should understand that a Host listing necessarily involves some disclosure of the location where charging is offered.

Hosts should consider the privacy and security implications of listing a residential charger before publishing it.

97. User Responsibility for Information They Provide

You are responsible for ensuring that information you provide to BubbleCharge is accurate and that you have the right to provide it.

You should not provide:

  • Another person's government identification
  • Another person's financial information
  • Passwords
  • Authentication codes
  • Sensitive personal information that BubbleCharge did not request
  • Confidential information belonging to another person

If you provide information about another individual, you should ensure that you are legally permitted to do so.

98. Privacy and Off-Platform Communication

BubbleCharge may process information concerning communications or transactions that are reported to BubbleCharge in connection with a booking or dispute.

Users should understand that moving a transaction outside BubbleCharge may reduce BubbleCharge's ability to provide booking records, fraud protection, dispute assistance, and other Services.

Users should not share unnecessary personal information with another user.

99. Records of Disputes and Incidents

BubbleCharge may retain information relating to:

  • Booking disputes
  • Payment disputes
  • Refund requests
  • Cancellation disputes
  • No-shows
  • Fraud reports
  • Safety reports
  • Account violations
  • Charger-related incidents
  • Customer support investigations

This information may be retained after a booking or account is closed where reasonably necessary for legal, security, fraud-prevention, or dispute-resolution purposes.

100. Privacy of Hosts and Finders

BubbleCharge recognizes that Hosts and Finders may have different privacy needs.

Hosts may need to disclose information necessary for Finders to locate and use charging equipment.

Finders may need to disclose information necessary for Hosts to understand and complete a booking.

BubbleCharge seeks to limit the disclosure of personal information between users to what is reasonably necessary.

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Changes & Contact

101. Privacy by Design

BubbleCharge seeks to incorporate privacy considerations into the design and operation of the Services.

This may include:

  • Limiting unnecessary data collection
  • Limiting access to personal information
  • Using third-party providers with appropriate safeguards
  • Limiting disclosure
  • Protecting account credentials
  • Monitoring security
  • Reviewing new technologies
  • Deleting or anonymizing information when it is no longer reasonably required

102. Changes to Our Privacy Practices

BubbleCharge may change its privacy practices as the Services, technology, business model, or legal requirements change.

If BubbleCharge introduces a materially different use of personal information, BubbleCharge will provide notice and obtain consent where required.

103. Changes to This Privacy Policy

BubbleCharge may update this Privacy Policy from time to time.

The updated Privacy Policy will be posted on the BubbleCharge website with a revised effective date.

Where applicable law requires additional notice or consent for a material change, BubbleCharge will provide that notice or obtain that consent.

You should periodically review this Privacy Policy.

104. Contact BubbleCharge

For privacy questions, requests, complaints, or concerns:

Privacy Officer

BubbleCharge Inc.

Email: privacy@bubblecharge.com

For general customer support:

Email: support@bubblecharge.com

Privacy-related requests should preferably be sent to:

privacy@bubblecharge.com

105. Privacy Complaints

If you have a privacy concern, please contact the BubbleCharge Privacy Officer first.

BubbleCharge will review the concern and take reasonable steps to investigate and respond.

Depending on where you live, you may also have the right to contact the applicable privacy regulator.

Canadian users may have the right to contact the Office of the Privacy Commissioner of Canada or an applicable provincial privacy regulator.

Quebec users may have the right to contact the Commission d'accès à l'information du Québec.

U.S. users may have rights to contact their state Attorney General or other applicable regulatory authority.

106. No Waiver of Legal Privacy Rights

Nothing in this Privacy Policy is intended to waive, restrict, or eliminate a privacy right that cannot legally be waived or restricted.

If applicable law provides a greater privacy right than described in this Privacy Policy, the applicable law will govern to the extent of the conflict.

107. Severability

If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions will remain in effect to the fullest extent permitted by law.

108. Effective Date

This Privacy Policy is effective as of:

September 01, 2026

BubbleCharge Inc.

Privacy Email: privacy@bubblecharge.com

General Support: support@bubblecharge.com

Website: BubbleCharge.com