Effective Date: July 1, 2025

Smart EV Systems Inc. ("we," "our," or "us") is committed to protecting the privacy and security of your personal information. With headquarters in both Toronto, Ontario, Canada, and Miami, Florida, USA, this Privacy Policy outlines our practices concerning the collection, use, and disclosure of your personal information when you interact with our website, products, and services in both countries. We strive to comply with applicable privacy laws in both jurisdictions, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada and relevant federal and state laws in the United States.

1. Information We Collect

We may collect the following categories of personal information:

• Contact Information: Your full name, postal address, phone number, and email address.
• Payment Information: Credit card details and billing addresses for processing payments for our services.
• Vehicle Information: Details about your electric vehicle that are necessary to facilitate our charging services.
• Technical Information/Online Identifiers: Your IP address, browser type, operating system, device information, and usage data when you visit our website.
• Communications Data: Records of your communications with us.

2. How We Collect Your Information

We collect personal information through the following means:

• Direct Interactions: When you register for our services, create an account, fill out forms, or contact us directly.
• Automated Technologies: We use cookies and similar tracking technologies to collect technical information automatically as you navigate our website. Please refer to our Cookie Policy below for more details.
• Third-Party Sources: We may receive personal information from partners and service providers who assist us in delivering our services.

3. Use of Your Information

We may use your personal information for the following purposes:

• Providing, operating, and maintaining our electric vehicle charging services.
• Processing payments and sending related transaction information.
• Communicating with you, including responding to inquiries, providing support, sending service updates, and with your consent where required, promotional materials.
• Improving our website, services, and customer experience.
• Ensuring the security of our services and preventing fraud.
• Complying with applicable legal and regulatory obligations in Canada and the United States.

4. Sharing Your Information

We do not sell or rent your personal information to third parties. However, we may share your information in the following limited circumstances:

• Service Providers: We may share your personal information with third-party service providers who perform services on our behalf, under contractual terms that require them to protect your information.
• Business Transactions: In the event of a business transaction such as a merger or acquisition, your personal information may be transferred.
• Legal Obligations: We may disclose your personal information if required by law or legal process.

5. Data Security

We implement reasonable technical, physical, and administrative safeguards to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include data encryption, secure server storage, and access controls.

6. Your Rights

Depending on your jurisdiction, you have rights regarding your personal information.

For Canadian Residents (Under PIPEDA):

• Right to Access: You may request access to your personal information.
• Right to Correction: You may request corrections to inaccurate information.
• Right to Withdraw Consent: You may withdraw your consent to the processing of your personal information, where consent has been obtained.
• Right to Object (in limited circumstances): You may have the right to object to certain processing.
• Right to Lodge a Complaint: You may lodge a complaint with the Office of the Privacy Commissioner of Canada.

For Residents of Certain U.S. States:

You may have rights including:

• The right to know what personal information is collected about you.
• The right to request deletion of your personal information.
• The right to opt-out of the sale or sharing of your personal information for certain purposes.
• The right to correct inaccurate personal information.
• The right to limit the use and disclosure of sensitive personal information.
• The right not to be discriminated against for exercising your privacy rights.

Exercising Your Rights:

To exercise your rights, please contact us using the information provided below for the relevant jurisdiction. We may require you to verify your identity. We will respond to your request within the timeframes required by applicable law.

7. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for legal and regulatory compliance.

8. Children's Privacy

Our services are not intended for children under the age of 18. We do not knowingly collect personal information from children without verifiable parental consent.

9. Cross-Border Data Transfers

As a company with headquarters in both Canada and the United States, your personal information may be transferred between our Canadian and U.S. offices and to service providers in other jurisdictions. We will take reasonable steps to ensure your information is protected in accordance with applicable laws during such transfers.

10. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated policy on our website with a revised "Effective Date."

11. Contact Us

For privacy inquiries related to your interactions in Canada, please contact:

Smart EV Systems Inc. (Canadian Office)
245 Yorkland Boulevard, Suite 100
Toronto, Ontario, Canada, M2J 4W9

• Email: tasso@smartEVsystems.com
• Phone: Toll-Free: 1.833.776.3838

For privacy inquiries related to your interactions in the United States, please contact:

Smart EV Systems USA Inc. (U.S. Office)
601 Brickell Key Drive, Suite 700
Miami, FL 33131, USA

• Email: tasso@smartEVsystems.com
• Phone: Toll-Free: 1.833.776.3838

Cookie Policy

This Cookie Policy explains how Smart EV Systems Inc. ("we," "our," or "us") uses cookies and similar tracking technologies when you visit our website. This policy should be read in conjunction with our Privacy Policy.

What are Cookies?

Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

How We Use Cookies

We use cookies and similar tracking technologies for the following purposes:

• Essential Cookies: These cookies are necessary for the operation of our website and enable you to use its essential features.
• Analytics/Performance Cookies: These cookies help us understand how visitors use our website so we can improve it.
• Functionality Cookies: These cookies are used to recognize you when you return to our website and personalize your experience.
• Targeting/Advertising Cookies: These cookies may be used to deliver advertising relevant to your interests.

Types of Cookies We Use

The specific types of cookies we may use on our website include:
These cookies are essential for website functionality and improving user experience.

Managing Your Cookie Preferences

You can control and manage cookies in several ways:

• Browser Settings: Most web browsers allow you to manage cookies through their settings.
• Website Cookie Banner/Management Tool: Our website may provide a tool to manage your cookie preferences.

Consent for Cookies

For cookies that are not strictly necessary, we will obtain your consent before placing them on your device, where required by applicable law.

Changes to this Cookie Policy

We may update this Cookie Policy from time to time.

Contact Us

If you have any questions about our use of cookies, please contact us using the information provided in our Privacy Policy.