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ChargeWise Personal Data Protection Policy

The Premium Platform for eMobility Growth

Last updated: January 6, 2026

At "ChargeWise", a limited liability company organized under the laws of the Republic of Bulgaria, we are committed to safeguarding the security and privacy of the data entrusted to us through the ChargeWise platform, a User Engagement and Loyalty Programs Management Platform for eMobility Service Providers. We take your personal data and our legal obligations seriously. This privacy policy sets out how we collect, use, manage, and protect data that identifies you as an individual (Personal Data) in compliance with the Personal Data Protection Act 2012 of Singapore (PDPA).

1. Data Protection Officer

We have designated Lyubomir Hristev, Co-founder and Managing Director at ChargeWise LTD., as our Data Protection Officer (DPO) responsible for PDPA compliance and handling data protection matters.

Contact our DPO:
Email: dpo@chargewise.global
Address: 22 Madren str., Housing Complex Slatina, Blok 22, Entrance G, fl.6, Apt.# 119,

Sofia, 1574, Bulgaria
Phone: +359 896 99 15 66

2. Collection of Personal Data

2.1 Personal Information We Collect

For All Users:

  • Identity Data: First name, middle name, last name, date of birth, photograph.
  • Contact Data: Email address, residential address, phone number.

For B2B Clients (Additional Data):

  • Company name and business information.
  • Billing address and payment information.
  • Organization details and service requirements.
  • Program configuration preferences.

For End Users (Additional Data):

  • Points balance.
  • Reward preferences and redemption history.
  • Program participation metrics.

2.2 Technical Information We Collect Automatically

Usage Data:

  • Device information (hardware model, operating system, browser type and version).
  • IP addresses and approximate location data.
  • Log data (access times, pages visited, referring URLs).
  • Platform interaction data and navigation patterns.

Platform Performance Data:

  • System diagnostics and error logs.
  • Feature usage analytics.
  • Performance metrics and optimization data.

2.3 Charging and Loyalty Program Data

When end users participate in loyalty programs created by our B2B clients, we may collect:

  • Charging session details (timestamp, duration, energy consumed in kWh).
  • Charging location information.
  • Point earning calculations and redemption activities.
  • Program engagement metrics.
  • Reward fulfillment data.

2.4 Information from Third Parties

  • Charging session data (when participating in loyalty programs).
  • Transaction history.
  • B2B clients about their customer programs and configurations.
  • Payment processors and financial service providers.
  • Reward partners and voucher providers.
  • Analytics and service providers.

3. How We Collect Your Data

3.1 Service Provision and Platform Operation

We use your information to:

  • Provide and maintain the ChargeWise platform.
  • Enable loyalty program creation and management.
  • Process point calculations and reward redemptions.
  • Facilitate communication between B2B clients and end users.
  • Manage user accounts and provide authentication.

3.2 Platform Improvement and Analytics

We use aggregated and anonymized data to:

  • Analyze platform usage patterns and performance.
  • Develop new features and enhance existing functionality.
  • Conduct research on user engagement and loyalty program effectiveness.
  • Optimize platform performance and user experience.
  • Generate industry insights and benchmarking data.

3.3 Communication and Support

We may use your contact information to:

  • Send service-related notifications and platform updates.
  • Provide customer support and technical assistance.
  • Share loyalty program updates and reward notifications.
  • Communicate important security or policy changes.
  • Send marketing communications (with your explicit consent).

3.4 Legal and Security Purposes

We may process your information to:

  • Comply with legal obligations and regulatory requirements.
  • Investigate and prevent fraud, security threats, or platform misuse.
  • Protect the rights, property, and safety of ChargeWise, our users, and the public.
  • Enforce our Terms & Conditions and platform policies.

4. Use of Personal Data

We collect, use, and disclose your Personal Data for the following purposes:

4.1 Service Provision:

  • Process registrations and create accounts.
  • Provide products and services you have requested.
  • Provide customer support and respond to inquiries.

4.2 Business Operations:

  • Administer, maintain, and protect our business and systems.
  • Manage our relationship with you.
  • Conduct internal audits and business planning.

4.3 Legal Compliance:

  • Comply with laws, regulations, and legal obligations.
  • Conduct KYC and due diligence procedures.
  • Respond to government authorities and legal processes.
  • Prevent fraud and ensure security.

4.4 Technology Management:

  • Operate and improve our website and digital platforms.
  • Troubleshoot technical issues and maintain security.
  • Conduct system maintenance and data analysis.

4.5 Marketing (with your consent):

  • Send marketing materials and promotional offers.
  • Invite you to events and webinars.
  • Deliver newsletters and industry updates.
  • Conduct market research and surveys.

4.6 Other Purposes:

  • Any purpose for which we notify you and obtain consent.
  • Any purpose required or permitted by law.

If you provide Personal Data of third parties, you warrant that you have obtained the necessary consents and authority to disclose their information to us.

5. Disclosure of Personal Data

We may share your Personal Data with:

Service Providers: Cloud hosting, IT services, payment processors, professional advisors, marketing agencies, customer support providers.

Affiliates: Our parent company, subsidiaries, and group entities for integrated service delivery.

Professional Counterparties: Other advisors, counterparties, and their representatives in business transactions.

Authorities: Government agencies, regulators, law enforcement, and courts, when required by law.

Business Transfers: Prospective buyers or acquirers in mergers, acquisitions, or asset sales.

Protection of Rights: When necessary to detect fraud, protect rights and safety, or enforce our terms.

With Your Consent: Other parties, when you have provided explicit consent

We require all third parties to respect your Personal Data's security, treat it in accordance with the PDPA, and use it only for specified purposes. We do not share your Personal Data with unaffiliated third parties for their independent use without your express consent.

6. Cookies and Tracking

We use cookies to provide a personalized experience, improve our website, and conduct analytics. Cookies help us:

  • Enable core website functionality and security.
  • Remember your preferences and settings.
  • Understand website usage and performance.
  • Deliver relevant marketing and advertisements.

You can control cookies through your browser settings. However, disabling certain cookies may limit website functionality. You can delete cookies from your browser at any time.

We use third-party services, including Google Analytics, social media platforms (LinkedIn, Facebook), and advertising networks that may place cookies on your device.

7. Retention of Personal Data

We retain your Personal Data only as long as necessary for the purposes collected or as required by law. After relationships end:

  • Customer Data: 5 years after account closure.
  • Transaction Records: 5 years for tax and accounting compliance.
  • Marketing Data: Until consent is withdrawn.
  • Legal Records: As required by specific laws (typically 5-7 years).

We may retain data longer when required by legal obligations, ongoing proceedings, or legitimate business interests. When no longer needed, we securely dispose of Personal Data through permanent deletion, shredding, or anonymization.

8. International Transfers

Your Personal Data may be transferred outside Singapore where our service providers, affiliates, or partners operate. We ensure appropriate protection through:

  • Adequacy decisions by Singapore authorities.
  • Standard contractual clauses with overseas recipients.
  • APEC Cross-Border Privacy Rules certification.
  • Organizational certifications (ISO 27001, SOC 2).
  • Your explicit consent (where required).

All overseas recipients are contractually required to protect Personal Data using PDPA-comparable standards.

9. Security

9.1 Data Protection:

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, and data anonymisation, up-to-date antivirus protection, regular patching or operating systems and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one-time password(OTP/2 factor authentication (2fa)/multi-factor authentication (ma) to secure access, and security review and testing performed regularly.

9.2 We implement comprehensive security measures to protect your Personal Data:

Physical: Restricted access, secure storage, CCTV surveillance, controlled document handling

Technical: Encryption (in transit and at rest), firewalls, multi-factor authentication, anti-virus protection, regular security updates, secure backups. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our Information security measures.

Administrative: Security policies, access controls, confidentiality agreements, staff training, regular audits, incident response procedures

While we use commercially reasonable security practices and regularly review our measures, no system is 100% secure. You can help protect your data by keeping passwords confidential, being cautious of phishing attempts, and reporting suspicious activity immediately.

If you discover security vulnerabilities or unauthorized access, contact us at security@chargewise.global.

10. Children’s Privacy

We do not knowingly collect Personal Data from children under 13 years of age. If you are under 13, please do not provide any Personal Data to us.

If you are a parent or guardian and believe your child has provided us with Personal Data, contact us immediately at security@chargewise.global. We will promptly delete such information from our records.

11. Your Rights

Under the PDPA, you have the right to:

Access: Request access to your Personal Data and information about how it was used or disclosed within the past year. If you wish to make an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, you may submit your request in writing via email to our Data Protection Officer at the contact details provided below.

Correction: Request correction of inaccurate or incomplete Personal Data. A correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing via email to our Data Protection Officer at the contact details provided below.

Withdraw Consent: The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time as it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that, depending on the nature and scope of your request, we may not be in a position to continue providing our goods and services to you, and we shall, in such circumstances, notify you before completing the process of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.

Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

Data Portability: Request transmission of your data to another organization (when regulations take effect).

Lodge Complaint: File complaints with us or the Personal Data Protection Commission (PDPC).

12. How to Exercise Your Rights

Contact our Data Protection Officer:

Provide proof of identity and specific details about your request. We will:

  • Acknowledge within 3 business days.
  • Fulfill access requests within 30 days.
  • Complete corrections as soon as practicable (typically 10-30 days).

Fees: First access request per year is free. Reasonable fees may apply for subsequent requests.

13. Third-party Links

Our website may contain links to third-party sites not covered by this policy. We are not responsible for their privacy practices or content. Please review their privacy policies before providing Personal Data.

14. Changes to This Policy

We may update this policy to reflect changes in practices, laws, or business operations. We will notify you of material changes by:

  • Posting updates on our website with a new "Last Updated" date.
  • Emailing registered users for significant changes.
  • Providing advance notice (typically 30 days).

Your continued use after changes take effect constitutes acceptance. If you disagree, you may discontinue services or close your account.

Contact Us

For questions, concerns, or complaints about this policy or our data practices:

ChargeWise Data Protection Officer
Email: dpo@chargewise.global
Address: 22 Madren str., Housing Complex Slatina, Blok 22, Entrance G, fl.6, Apt.# 119,

Sofia, 1574, Bulgaria
Phone: +359 896 99 15 66

ChargeWise General Inquiries:
Email: info@chargewise.global

Personal Data Protection Commission (PDPC):
Website:https://www.pdpc.gov.sg
Email: info@pdpc.gov.sg
Phone: +65 6377 3131

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