Privacy Policy

I.   Privacy Notice (Website)

II.  Privacy Notice (Kiosks)

III. Privacy Notice for California Residents (Kiosks)

I.   Privacy Notice (Website)

Last Updated: May 2020

What Information Does ChargeItSpot Collect?
How We Use Information
Sharing of Information
Data Security

ChargeItSpot designs mobile phone charging kiosks that allow consumers to charge their phones when they are on the go. We respect the privacy of our users and are committed to using best practices to ensure that the safety, security and confidentiality of our customer’s personal information is protected. This Privacy Policy applies to information collected from our kiosks, the ChargeItSpot website, and our mobile application for Android and Apple phones.

What Information Does ChargeItSpot Collect?

We collect information from you when you use a ChargeItSpot kiosk to charge your phone, respond to a survey, fill out a form or download our mobile app. When registering or entering a contest on our kiosk, as appropriate, you may be asked to enter your name, e-mail address, mailing address or mobile phone number. For security purposes, ChargeItSpot captures your mobile phone number, picture and related user data at the time of kiosk use.

When you visit our website, we collect industry standard data about your visit such as your browser type, operating system, the URL of the page that referred you, the pages you visit, and your IP address. We use this information to provide you with information that is relevant to your location and to make sure that our website is working properly. We also collect data from cookies which most web browsers are set to accept by default. If you prefer, you can typically set your browser to remove or reject cookies. If you choose to remove or reject cookies, this could affect certain features of our services.

How We Use Information

ChargeItSpot uses the information we collect to make continuous improvements to our service, security and user experience. For example, we may use information about you to:

• Enable you safely and securely lock up your phone for charging and retrieve your phone;
• Monitor and analyze trends or usage in connection with our service;
• Personalize your experience using our service;
• Provide customer service or technical support;
• Send you information pertaining to our service such as alerts, updates, confirmations, surveys, or other communication;
• Detect, investigate and prevent fraudulent transactions to protect the privacy and security of ChargeItSpot’s customers;

Sharing of Information

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. We may share aggregated or de-identified information, which cannot reasonably be used to identify you.

Data Security

ChargeItSpot takes the security of your phone and related data very seriously. While your phone is charging, we provide one-way directional power to your device. We NEVER sync with your phone, download anything onto your phone, or access the data on your phone.

By using this website, you agree to this Privacy Policy, including any international users, who agree to be bound by U.S. law. This is our entire and exclusive Privacy Policy, and it supersedes any earlier version. We reserve the right to modify this policy at any time without advance notice.

II. Privacy Notice (Kiosks)

Last Updated: May 2020

Personal Information We Obtain and How We Use It
Messaging and Communications
How We Protect the Personal Information We Collect
Sharing of Personal Information
Children’s Privacy
Updates to this Privacy Policy
Contact Us

This privacy policy describes the types of personal information ChargeItSpot LLC (“ChargeItSpot” or “we” or “us” or “our”) collects about users (“User”, “you”, or “your”) of this Kiosk (“Kiosk”), how we use the information, and with whom we may share it. We also describe the measures we take to protect the security of the information and how Users can contact Us about our privacy practices. This Kiosk privacy policy does not apply to information collected through our website, www.chargeitspot.com.

Personal Information We Obtain and How We Use It

ChargeItSpot is committed to protecting your privacy when you use a ChargeItSpot Kiosk. When you use our Kiosk, you provide a 10-digit mobile phone number and select a security identifier or image. In some instances, instead of a mobile phone number, you may provide a loyalty card number, a customer number, barcode or QR code, or other identification number. This information is primarily used by ChargeItSpot to secure your mobile device (“Device”), but may also be provided to the “Merchant” and/or “Sponsor” in accordance with the “Sharing of Personal Information” below. In addition, a camera in the Kiosk takes photos of you for customer service and security purposes, to protect against criminal activity, and to protect ChargeItSpot from potential civil and criminal liability. ChargeItSpot uses your photo solely for the purposes of security and customer service. In no event will ChargeItSpot use your photos for facial recognition or similar profiling purposes. You may also be asked to enter other personal information, including but not limited to, your email address, loyalty number, and survey responses, which may be shared the “Merchant” and/or “Sponsor” in accordance with the “Sharing of Personal Information” below. We do not collect information from, download information onto, access data on, or otherwise sync with your Device while your Device is connected to the Kiosk for charging.

Messaging and Communications

In some cases, your use of the Kiosk is contingent upon you agreeing to receive text/SMS and/or email messages related to your use of the Kiosk and for other purposes described in this policy. These conditions will be clearly stated on the page where you enter your mobile number or email address. Unless you opt-out in accordance with this policy, we and/or the “Merchant” and/or “Sponsor” may use your personal information to send you text/SMS and email messages, including advertising messages. While your agreement to receive certain text/SMS and email messages may be a condition for the continued use of the Kiosk, you may opt-out of certain other communications we send you, for example, by clicking on the “unsubscribe” link in marketing emails or texting “STOP” in response to text/SMS messages. Please be aware that there may be a brief period before we are able to process your opt-out, but we will always respect your legal rights to opt-out of receiving unwanted messages. In other instances, however, your agreement to receive certain types of communications is based on your express acceptance (or opt-in) to receive such communications.

How We Protect the Personal Information We Collect

We implement reasonable administrative, technical, and physical safeguards that are designed to protect the personal information you provide from unauthorized access, use, or disclosure.

Sharing of Personal Information

We do not sell, trade, or otherwise disclose the personal information we collect about you, except as described herein. We may share your information with:

• Service providers who perform services on our behalf, such as text/SMS message services. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
• The owner or operator of the location where this Kiosk is located (together, with any agents acting on its behalf, “Merchant”) and/or the person or company leasing the Kiosk (together, with its affiliates, “Sponsor”) so that they can, on their own behalf, (a) prepare marketing and business analyses, (b) send you marketing or other messages, including by email and text/SMS, and/or (c) develop customer profile data. This information is shared with the Merchant and/or Sponsor as part of an arrangement to provide you with the free use of a charging station. Any personal information received by the Merchant and/or Sponsor will be subject to the Merchant’s and/or Sponsor’s applicable privacy policies.

Additionally, we may disclose anonymous, aggregated information about our Users, including you, to third parties for any purpose if we deem such disclosure to have sound business reasons or justifications.

We may also disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, or (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity or to otherwise enforce our legal rights. We also reserve the right to transfer information we have about you in the event that we sell or transfer all or a portion of our business or assets (including in the event of a merger, reorganization, dissolution, or liquidation).

California residents: for more information about how we share your data, please contact us at privacy@chargeitspot.com.

Children’s Privacy

This Kiosk is not intended for use by persons under the age of eighteen (18), and we do not knowingly collect personal information from children under the age of thirteen (13).

Updates to this Privacy Policy

This privacy policy may be updated periodically on the Kiosk and/or our website (www.chargeitspot.com) and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the privacy policy when it was most recently updated. To view this privacy policy online, please visit
www.chargeitspot.com/privacy-terms/kiosk/.

Contact Us

If you have any questions about this privacy policy, or would like to receive an electronic copy, contact ChargeItSpot’s Privacy Officer at:

111 S. Independence Mall East, Suite 920
Philadelphia, PA 19106
privacy@chargeitspot.com
www.chargeitspot.com

III. Privacy Notice for California Residents (Kiosks)/h3>

Last Updated: May 2020

Information ChargeItSpot Collects
Sources from Which Personal Information Is Collected
Business or Commercial Purposes for Which Personal Information is Collected
Sharing and Selling Personal Information
Disclosure of Personal Information for a Business Purpose
Sales of Personal Information
Exercising Your California Access, Deletion and Do Not Sell Rights
Your Access Rights
Your Deletion Request Rights
Deletion Rights Exceptions Verifying Requests
Authorized Representative Response Timing
Personal Information Sales Opt-Out and Opt-In Rights
To exercise the right to opt-out, you (or your authorized representative) may
Users Younger Than 16
Non-Discrimination
Other California Privacy Rights
Changes to Our Privacy Policy
Contact Information

This Privacy Policy for California Residents supplements the information contained in ChargeItSpot LLC’s (“ChargeItSpot” or “we” or “us” or “our”) general Kiosk Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this Policy.

This policy provides information about the categories of information that we collect from California residents generally, the sources of the information, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes and to whom we sell Personal Information as defined by CCPA. It also includes information on how to opt-out.

Information ChargeItSpot Collects

When you use a ChargeItSpot Kiosk, we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). The following are the categories of Personal Information that we have collected from consumers who have used our Kiosk over the last twelve (12) months, and examples and the types of information those include.

Sources from Which Personal Information Is Collected

• Directly from you. For example, you may enter your mobile number, email address and/or answer survey questions when you use the service.
• Indirectly from you. For example, a camera in the Kiosk takes photos of you for customer service and security purposes.

Note: We do not collect information from, download information onto, access data on, or otherwise sync with your mobile device while your device is connected to the Kiosk for charging.

Business or Commercial Purposes for Which Personal Information is Collected

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, to secure your mobile device.
• To create, maintain, customize, and secure your account with us.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To protect ChargeItSpot from potential civil and criminal liability.
• To personalize your Kiosk experience.
• For testing, research, analysis, and product development, including to develop and improve our services.
• To use your information to provide market insights to the Sponsor of this kiosk.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Kiosk consumers is among the assets transferred

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you policy.

Sharing and Selling Personal Information

We may disclose your Personal Information to a third party for a business purpose or sell your Personal Information subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights).

Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed your Personal Information with the following categories of third parties:

• Service providers, such as those that deliver our communications
• Identifiers, Personal Information (mobile number), Commercial Information, Biometric Information, and Inferences Drawn from Personal Information
• The Merchant and/or Sponsor of this Kiosk
• Identifiers, Personal Information (mobile number), Commercial Information, and Inferences Drawn from Personal Information

Sales of Personal Information

In the preceding twelve (12) months, Company has sold your Personal Information to the following categories of third parties:

• The Merchant and/or Sponsor of this Kiosk
• Identifiers, Personal Information (mobile number), Commercial Information, and Inferences Drawn from Personal Information

Exercising Your California Access, Deletion and Do Not Sell Rights

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information.

Your Access Rights

Upon request and subject to our verification, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• The Personal Information that we sold or disclosed for a business purpose, including:
  • For a sale, the categories of Personal Information a recipient purchased; and
  • For a disclosure, the categories of Personal Information that each category of recipient obtained.

We will provide the requested information free of charge up to two (2) times in a 12-month period, but please note that where we receive unfounded, excessive or repetitive requests, we may elect to decline the request. As discussed below, ChargeItSpot will only disclose the requested information to the extent permitted by law once we receive and confirm your verifiable consumer request.

Your Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Upon request and subject to our verification we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception (described below) applies.

Deletion Rights Exceptions

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Comply with a legal obligation.
• Debug products to identify and repair errors that impair existing intended functionality.
• Complete the transaction for which we collected the Personal Information, provide our services, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it. To exercise the access and deletion rights described above, you may submit a request by contacting us via any of the methods below. Note, you must use your mobile phone or web browser for the website or email option.

Verifying Requests

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. In order to verify your identity, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of the requestor, which may include:

• Mobile number used at a ChargeItSpot Kiosk
• Email address used at a ChargeItSpot Kiosk
• Date of last transaction at a ChargeItSpot Kiosk
• Location of your last transaction at a ChargeItSpot Kiosk

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided to verify the requestor’s identity or authority to make the request.

Authorized Representative

If you would like to authorize an agent to act on your behalf in submitting a request to know, request to delete, or request to opt-out of the sale of your Personal Information, you may do so by submitting a signed Declaration of Designated Agent at www.chargeitspot.com/privacy-terms/ccpa or to privacy@chargeitspot.com. Please keep in mind that if we do not receive adequate proof that the request agent is authorized to act on your behalf, we may deny the request.

Response Timing

When you submit a verifiable request to (a) access the Personal Information we have collected, sold, disclosed, or (b) delete your Personal Information, we will (1) confirm receipt within ten (10) business days and (2) make every attempt to respond to the request within forty-five (45) days of receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may

submit a request by contacting us via any of the methods below. Note, you must use your mobile phone or web browser for the website or email option.

We will only use Personal Information provided in an opt-out request to review and comply with the request. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. Should you use our kiosk again, you rescind your opt-out of sale request and reauthorize us to sell your Personal Information.

Users Younger Than 16

ChargeItSpot does not target users younger than age 18 and, therefore, does not knowingly collect or sell Personal Information of minors younger than 16 years of age.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Kiosk that are California residents to request certain Information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@chargeitspot.com, or write us at: 111 S. Independence Mall E., Suite 920, Philadelphia, PA 19106.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated policy on the Website and update the policy’s effective date. Your continued use of our Kiosk following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this policy, the ways in which ChargeItSpot collects and uses your Information described here and in the general Kiosk Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, you may submit a request by contacting us via any of the methods below. Note, you must use your mobile phone or web browser for the website or email option.