Privacy Policy
Last updated: 6/24/2023
Overview
DejaNetworks believes that everyone has the right to privacy and should be able to control how their personal information is used by our organization. In support of this belief, DejaNetworks’ goal is to meet the requirements of the jurisdiction-specific privacy legislation for individuals and to offer a common set of rights which exceeds these requirements to everyone.
Scope
This policy applies to the entire DejaNetworks organization, and all of our products and services. There are no exceptions.
‘DejaNetworks’ refers to the legal entity, DejaNetworks, Inc (“us”, “we”, or “DejaNetworks”), headquartered at 1482 East Valley Road, Ste 329, Santa Barbara, California, 93108. ‘Products and Services’ are defined as any application developed by DejaNetworks for use by our customers, and drivers who interact with DejaNetworks chargers.
DejaNetworks’ Role
DejaNetworks collects personally identifiable information directly from you, for example, when you register for an account on the DejaNetworks mobile application. This role is often referred to as a ‘data collector’.
Legal basis for collection of personally identifiable information
DejaNetworks collects personally identifiable information only where it has a legal basis to do so. Typically, this is because you have expressed an interest in using a DejaNetworks product or service and the information is needed to deliver the product or service to you and to provide support for said product or service.
DejaNetworks will not intentionally gather information from children under the age of 13.
Types of personally identifiable information collected
DejaNetworks may collect the following types of personally identifiable information:
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General personal information, such as full name, email address, mailing and billing addresses.
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Credit card information (which is sent to our PCI-DSS compliant payment card processor).
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Technical identifiers such as IP addresses, and mobile device ID.
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Location data (identify user location, find nearby chargers, and have chargers communicate with the App while in the background).
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Browser identifiers, such as user agent strings.
How DejaNetworks uses personally identifiable information
There are four ways DejaNetworks uses the information collected:
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To provide information about the service or product that you have signed up for.
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To send you important information about your account, charging sessions, and billing.
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To provide additional information about our company, including new and upcoming products that may be of interest to you.
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To improve our existing products and services.
In all cases above, the information is used directly by DejaNetworks, and is not shared with, or made accessible to any third parties.
How DejaNetworks collects personally identifiable information
There are three ways in which DejaNetworks may collect personally identifiable information:
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Directly, and voluntarily, from you as a consumer of our products and services. For example, when you register to use our mobile application.
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Directly, and autonomously, from your browser or device through visits to DejaNetworks web properties. For example, through automated website analytics.
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Indirectly, through third party entities who provide data to DejaNetworks during the course of normal business operations. For example, a third-party service provider DejaNetworks has contracted to deliver a specific function, such as a payment service provider.
Disclosure of personal information
DejaNetworks does not ‘sell’ personally identifiable data for direct financial benefit. DejaNetworks may share personally identifiable information with its chosen service providers in support of our principal business operations, but all such relationships are governed by contractual relationships with those service providers and are routinely vetted to ensure that they meet our strict security and privacy requirements.
Responding to legal requests for information
DejaNetworks may disclose personally identifiable information as is necessary:
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To comply with a subpoena or court order.
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To cooperate with law enforcement or other government agencies.
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To establish or exercise our legal rights.
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To protect the property or safety of our company and employees, contractors, vendors, suppliers, and customers.
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To defend against legal claims.
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To help with internal and external investigations.
Security of personally identifiable information
DejaNetworks works to ensure that appropriate safeguards and controls are applied to any data collected by DejaNetworks. This effort extends to all aspects of DejaNetworks’ operations, including the development of hardware and software products, as well as setting company-wide policies and performing operational security monitoring.
When collecting personal information over the Internet via our websites, all transmissions occur via connections encrypted with Transport Layer Security (TLS).
The DejaNetworks application and supporting services are hosted in a leading Infrastructure-as-a-Service environment, which is routinely audited against a variety of data security and compliance standards, including SOC II, and ISO 27001.
Payment card data is processed by a third-party service provider that has been audited against the Payment Card Industry Data Security Standard (PCI-DSS).
Storage and transfer of personally identifiable information
All personally identifiable information collected by DejaNetworks is processed and stored in the United States.
Retention of information
Retention of certain financial and transactional records associated with DejaNetworks generally happens for financial reporting reasons, or to allow us to identify the owner of a given product to provide support. In these cases, such records are retained for 7 years.
Your rights in regard to personally identifiable information
DejaNetworks extends a common set of rights to everyone in regard to how we leverage personally identifiable information. These rights are as follows:
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Right to access - you can request a copy of your personally identifiable information held by DejaNetworks. Upon appropriately validating your identity, DejaNetworks will submit a copy, in a legible format, of all personally identifiable data collected in the preceding 12-month period within 30 days of receiving the request.
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Right to rectification - in addition to being able to update your DejaNetworks user account directly, you can make a written request to DejaNetworks to update personally identifiable information held about you.
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Right to erasure (or right to be forgotten) - you can request that DejaNetworks erase (‘delete’) personally identifiable elements of data from our systems, and we will do so with consideration for any overriding local, state or federal laws. DejaNetworks retains the right to remember that we’ve been asked to forget you.
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Right to restrict processing - You have the right to request that DejaNetworks restrict the processing of your personally identifiable information under certain conditions.
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Right to object to processing - You have the right to object to DejaNetworks processing your information, under certain conditions.
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Right to data portability - you have the right to request that DejaNetworks transfer your data directly to you, or to another entity. DejaNetworks will do so providing we can do so securely.
Exercising privacy rights
In order to make a request to exercise any of the rights listed above, you must contact DejaNetworks via email to privacy@DejaNetworks.com.
DejaNetworks will respond to any privacy requests received here within 30 calendar days. DejaNetworks will not disclose, update, or otherwise alter personally identifiable information, unless we can satisfactorily authenticate and identify the subject making the request.
Notice regarding use of Cookies
DejaNetworks, like many other organizations, will store session information (often called “Cookies”) in your browser that will help DejaNetworks to identify information such as browsing activity, IP addresses and page view order. You do have the option to not use these Cookies; the majority of browsers will have a “help” tool that will help you to prevent Cookies if you want to, but DejaNetworks recommends you keep Cookies active as it will provide a better user experience on DejaNetworks’ websites.
Notice to California residents
DejaNetworks operates in accordance with the California Consumer Privacy Act (CCPA), and as such, this policy has been designed to incorporate the specific requirements laid out within the CCPA.
We’re committed to protecting the rights of California residents who uses the DejaNetworks platform and encourage California residents to contact us to exercise those rights as described in the ‘making a privacy request’ section above.
DejaNetworks will not discriminate against individuals who exercise their rights under the CCPA.
Categories of personal information collected
DejaNetworks collects the following categories of information, as defined under the CCPA:
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Identifiers
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Commercial Information
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Geolocation data
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Inferences about personal preferences and attributes drawn from profiling
Do not sell my information
Since DejaNetworks is not involved in the sale of personal information to third parties for financial gain, we do not maintain a separate opt-out page, in accordance with the CCPA.
Authorized Agents
A California customer may use an authorized agent to make a CCPA privacy request on the customer’s behalf. To make a request on behalf of a DejaNetworks customer, the authorized agent must first provide a copy of either (a) a letter signed by the customer authorizing the agent to submit a CCPA request on their behalf, or (b) a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465. An authorized agent must email one of these documents to privacy@DejaNetworksenergy.com and include a phone number where the agent may be reached during regular business hours.
Information disclosed for business purposes
Over the preceding 12 months, DejaNetworks has disclosed personally identifiable information to its service providers to support the following business activities:
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Auditing
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Auditing legal and regulatory compliance
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Security
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Debugging
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Identifying and fixing technical errors
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Short-term uses
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Performing services
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Account maintenance
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Customer service
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Processing transactions
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Marketing
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Notice to Nevada Residents
We do not sell your personal information as defined under Nevada law. Please contact us if you have any questions or comments in this regard.
Nevada law requires us to disclose that you may request to be placed on DejaNetworks’ internal “do not call” list at any time by calling or emailing DejaNetworks, and that we are providing this notice to you pursuant to state law, and that you may obtain further information by contacting the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone 702-486-3132;
email BCPINFO@ag.state.nv.us.
Notice to Vermont Residents
In accordance with Vermont Laws, we will not share information we collect about Vermont residents with companies who are not affiliates, except as permitted by law. We will not share information about your creditworthiness with our affiliates without your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates without your consent.
Notice to European Union and United Kingdom Residents
DejaNetworks currently provides services to customers located solely in North America, and the Site and Services are not directed at an audience outside North America. We envision offering products or Services to citizens or visitors of the Member States of the European Union in the future, but we do not currently monitor their behavior as contemplated in the General Data Protection Regulation (GDPR) and guidance provided by the European Data Protection Board at this time.
We make no representation that any of the materials or the services to which you have been given access are available or appropriate for use in other locations. Your use of or access to the Site should not be construed as DejaNetworks purposefully availing itself of the benefits or privilege of doing business in any jurisdiction other than North America.
Updates to this policy
DejaNetworks may update this privacy policy from time to time. Please refer to the ‘last updated’ date at the beginning of this policy to ensure you are viewing the latest version of this document.