Privacy Policy

1. Introduction

This Privacy Policy explains how linqEV (Pty) Ltd ("linqEV", "we", "us", or "our") obtains, uses, and discloses your personal information when you use our electric vehicle charging network, mobile applications (including the linqNRG app), website, and the Host a Linq partner programme (collectively, the "Services"). We process personal information in accordance with the Protection of Personal Information Act, 2013 ("POPIA") and other applicable South African data protection legislation.

By using our Services, you acknowledge that you have read and understood this Privacy Policy. We are committed to protecting your privacy and to handling your personal information lawfully, transparently, and only for the purposes set out below.

2. Definitions

In terms of POPIA, "personal information" means information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person. In the context of linqEV, this includes, but is not limited to:

• Names and contact details (email addresses, telephone numbers, physical and postal addresses)
• Vehicle details (make, model, registration number, battery capacity, connector type)
• Payment information (card details, billing address, transaction history)
• Charging session records (station ID, time, duration, kWh delivered, cost)
• Location data (when you search for nearby chargers or start a charging session)
• Device and technical identifiers (IP address, device model, operating system, app version, push-notification tokens)
• Host partner business information (company registration, VAT number, banking details for payouts, site address)
• Any other information defined as personal information under POPIA

"Processing" means any operation concerning personal information, including collection, storage, use, modification, dissemination, or destruction.

"Driver" means an end-user of the linqEV charging network and mobile app. "Host" means a business or property owner participating in the Host a Linq programme.

3. Who This Policy Applies To

This Privacy Policy applies to the personal information of the following categories of data subjects:

• Drivers — individuals who use the linqNRG app and the linqEV Network to locate chargers and initiate charging sessions;
• Hosts — individuals and businesses who host chargers on their property under the Host a Linq programme;
• Website visitors — anyone who visits linqev.co.za or any linqEV subdomain;
• Enquirers and applicants — anyone who contacts us through a contact form, support channel, or Host application.

This Policy does not apply to third-party websites or services linked to from our app or website. We encourage you to read the privacy policies of any third-party services you use.

4. Information We Collect

We collect personal information through the following channels:

• Account registration: When you sign up for a linqEV account, we collect your name, email address, phone number, password (stored as a one-way hash), and optionally your vehicle make, model, registration, and battery details.
• Wallet and payment: When you add funds to your linqEV wallet or add a payment method, we collect billing information and your selected payment method. Card details are tokenised and handled by our PCI-DSS compliant payment processors — linqEV does not store full card numbers on its own systems. We record your wallet balance and a history of top-ups and deductions.
• Charging sessions: Each time you start a charging session, we record the station, connector, start/end time, energy delivered (kWh), session cost, and the payment method used.
• App and website usage: We collect device identifiers, IP address, app version, operating system, push-notification tokens, crash diagnostics, and aggregated usage analytics to operate and improve the Services.
• Location data: When you use the map or initiate a charging session, we collect location data to find nearby chargers, verify session start at a station, and present accurate availability — see section 7 for detail.
• Contact forms and support: When you submit a contact form, fault report, or support enquiry, we collect your name, contact details, message content, and any photos or attachments you provide (for example, when reporting a damaged charger).
• Host a Linq applications: When you apply to host a linqEV charger, we collect business contact information, company registration and VAT numbers, banking details for revenue payouts, site address, photographs of the proposed installation site, and electrical/grid specifications.
• Communications: Records of correspondence between you and our support team, including emails, in-app chat, and call logs.
• Information from third parties: We may receive information about you from our payment processors, the Apple App Store and Google Play, messaging and analytics providers, and roaming or charging partners, where permitted by law.

Where possible, we will inform you what information is required and what is optional. Providing optional information helps us tailor the Service to you but is never a condition of using core charging functionality.

5. Lawful Grounds for Processing

POPIA requires that we have a lawful basis for processing your personal information. We rely on the following grounds, depending on the purpose:

Where we rely on consent, you may withdraw it at any time as described in section 19. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal, and does not apply to processing we carry out on another lawful basis.

6. How We Use Your Information

We use your personal information only for the purposes for which it was collected, on one of the lawful bases set out in section 5. This includes:

• Creating and managing your linqEV account and wallet balance
• Authorising, processing, and recording charging sessions and associated payments
• Displaying real-time charger availability, pricing, and station information in the app
• Sending session receipts, charging notifications (start, end, fault), and transactional communications
• Providing customer support and responding to enquiries, fault reports, and refund requests
• Calculating and disbursing revenue share to Host partners
• Conducting internal analytics to improve charger uptime, network coverage, app performance, and the customer experience
• Detecting and preventing fraud, abuse of the network, payment fraud, or other malpractice
• Sending you marketing communications about linqEV products, promotions, and partner offers — only where you have opted in (see section 17)
• Complying with applicable laws, tax obligations, regulatory requests, and legal proceedings
• Audit, record-keeping, and dispute resolution purposes

7. Location & Charging Session Data

The linqEV mobile app may request access to your device's location services. We collect location data only for the following purposes:

• Finding nearby chargers: When you open the map or perform a search, we use your approximate location to surface relevant stations. You can disable location access in your device settings; the map will still work, but you will need to search by address or town.
• Starting a session: When you tap to start a charging session at a station, we verify that your device is within proximity of the selected charger to prevent accidental or fraudulent activation.
• Service quality and coverage planning: Aggregated and de-identified location data may be used to identify network coverage gaps and to plan future charger deployments. This data cannot be linked back to you as an individual.

We do not track your location continuously in the background, sell location data to third parties, or use it for advertising. You may revoke location permissions at any time from your device settings.

Charging session records (station, time, kWh, cost) are retained as part of your account history and for billing, tax, and dispute-resolution purposes.

8. Payment Information

linqEV uses PCI-DSS compliant third-party payment processors to handle card payments and wallet top-ups. When you add a payment method:

• Card details are submitted directly to the payment processor and tokenised. linqEV stores only a token, the card brand, the last four digits, and the expiry month/year for display purposes.
• Full card numbers, CVV codes, and PIN data are never stored on linqEV systems.
• Refunds, chargebacks, and disputed transactions are handled jointly with the payment processor and may require additional information from you for verification.

For Hosts receiving revenue payouts, we collect bank account details and any tax registration information required for payments and reporting. This information is stored securely and disclosed only to the financial institutions involved in the payout, and to regulatory authorities where required by law.

9. Cookies, App Analytics & Tracking

Our website and mobile applications use cookies, software development kits ("SDKs"), and similar technologies to collect standard internet and app-usage information. These help us to:

• Keep you signed in across sessions
• Remember your preferences (language, units, default vehicle)
• Understand which features are used most and where users encounter difficulties
• Diagnose crashes and performance problems
• Measure the effectiveness of marketing campaigns (only with your consent where required)

Cookies fall into four categories on our website: essential cookies required for the site to function, functional cookies that remember your preferences, analytics cookies that show us how the site is used, and marketing cookies that measure campaign effectiveness. Only essential cookies are set without your consent.

You can manage your cookie preferences at any time through our cookie consent banner, which is displayed on your first visit and can be reopened from the link in the website footer, or through your browser settings. A full description of each category, the providers involved, and how to opt out is set out in our Cookie Policy.

Analytics and marketing consent in the app can be managed through the app's privacy settings. Declining non-essential cookies and analytics will not prevent you from using core charging functionality, but disabling essential cookies may affect how the website works.

You have the right to withdraw your consent to non-essential cookies at any time. Withdrawal does not affect the lawfulness of processing based on consent given before the withdrawal.

Change cookie preferences

The linqNRG app does not use browser cookies. The app uses session tokens and device identifiers for authentication and analytics, as described in section 4.

10. Disclosure of Information

We may disclose your personal information to the following parties. Where a third party processes personal information on our behalf, it does so as an operator under a written agreement that requires it to process the information only on our instructions, to keep it confidential, to maintain the security measures required by section 19 of POPIA, and to notify us immediately where there are reasonable grounds to believe the information has been accessed by an unauthorised person.

• Payment processors and financial institutions: To process charging payments, refunds, and Host payouts.
• Charging hardware operators & roaming partners: To authorise and meter charging sessions on chargers operated by linqEV or by interoperability partners on whose network you may roam.
• Hosts: Hosts receive aggregated, de-identified utilisation statistics for chargers on their sites. Personally identifying information about Drivers is not shared with Hosts unless required for a specific incident (e.g. fault at a host's premises).
• Cloud hosting, infrastructure, and SaaS providers: Including hosting, database, email, push-notification, customer-support, and analytics services that operate the platform on our behalf.
• Professional advisors: Auditors, legal counsel, and insurers as required.
• Regulatory and legal authorities: Where we have a duty or right to disclose in terms of law, regulation, court order, or to protect the safety of any person.
• Successor entities: In connection with a merger, acquisition, or sale of business assets, your information may be transferred subject to equivalent privacy protections.

Mobile telephone numbers and messaging opt-in consent records (whether for WhatsApp or SMS) are excluded from all of the disclosures listed above, other than to the subcontracted messaging service providers strictly necessary to deliver the messages you have consented to receive. These providers are contractually prohibited from using this information for any other purpose.

We will not sell, rent, or trade your personal information to third parties for their own marketing purposes.

11. Cross-Border Data Transfers

Some of the cloud and SaaS providers we use may store or process data outside the Republic of South Africa. Where this occurs, we ensure that the recipient is subject to laws, binding corporate rules, or contractual obligations that provide an adequate level of protection for your personal information consistent with POPIA.

Cross-border transfers are carried out in accordance with section 72 of POPIA, on the basis that the recipient is subject to a law, binding corporate rules, or a binding agreement providing an adequate level of protection; or that the transfer is necessary for the performance of a contract between you and linqEV (Pty) Ltd, or for the conclusion or performance of a contract concluded in your interest. Where none of these grounds applies, we will transfer your personal information across borders only with your consent.

12. Information Security

We are legally obliged to provide adequate protection for the personal information we hold and to prevent unauthorised access, use, or disclosure. We continuously review our security controls and related processes to safeguard your data.

Our security measures include:

• Encryption of data in transit (TLS) and at rest
• Password hashing using industry-standard one-way functions
• Tokenisation of payment card data via PCI-DSS compliant processors
• Role-based access controls and least-privilege principles for internal staff
• Multi-factor authentication for access to internal systems
• Logging, monitoring, and incident detection on our infrastructure
• Secure software development practices and regular security assessments and vulnerability scanning
• Contractual security obligations imposed on third-party service providers
• Documented incident response and data breach management procedures
• Secure retention and disposal procedures for personal information

While we strive to use commercially acceptable means to protect your personal information, no method of electronic storage or transmission is entirely secure, and we cannot guarantee absolute security. Where there are reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person, we will notify you and the Information Regulator as soon as reasonably possible in accordance with section 22 of POPIA.

You also play an important role in keeping your information secure. Please use a strong, unique password for your linqEV account, enable multi-factor authentication where available, and notify us immediately if you suspect unauthorised access to your account.

13. Data Retention

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, and to comply with our legal obligations. Our standard retention periods are set out below. We may retain information for longer than the period stated where the law requires it, or where it is needed for an ongoing dispute, complaint, investigation, or legal proceedings — and in those cases only for as long as that purpose requires.

When personal information is no longer required, it is securely deleted, anonymised, or aggregated in accordance with our data disposal procedures. Anonymised data, which can no longer be associated with you, may be retained indefinitely for analytical purposes.

14. Automated Decision-Making & Profiling

We use automated processes to detect fraudulent or abusive activity on your account, such as unusual charging patterns, payment anomalies, or suspected unauthorised use of a linked RFID card. These automated checks may result in a charging session not being authorised, or in your account being temporarily suspended pending manual review.

In terms of section 71 of POPIA, we do not make decisions about you that have legal consequences for you, or that affect you to a substantial degree, based solely on automated processing without human involvement. Where an automated check affects your account, you may request that a person reviews the decision, and you may make representations about it, by contacting us at support@linqev.co.za.

We also use aggregated and anonymised data to analyse usage trends, plan network coverage, and improve the Services. This analysis does not identify you individually.

15. Your Rights

Right to Access

You have the right to request a copy of the personal information we hold about you. To exercise this right, contact us using the details in section 21. We may require proof of identity before fulfilling your request, and access may be subject to a legally allowable fee.

Right to Correction or Deletion

You have the right to ask us to update, correct, or delete your personal information. Most account details can be updated directly in the linqNRG app or your account settings. We will require verification of your identity before making changes via our support team. Note that we may need to retain certain information for legal, tax, or fraud-prevention purposes even after a deletion request.

Right to Object

You have the right to object to the processing of your personal information where such processing is carried out on grounds other than consent or a legal obligation, and to opt out of direct marketing at any time. An objection may be lodged using the prescribed POPIA Form 1, available from the Information Regulator's website, or by contacting our Information Officer at privacy@linqev.co.za.

Right to Restrict Processing

In the circumstances set out in section 14(6) of POPIA — for example, where you dispute the accuracy of information, or where processing is unlawful but you ask us to restrict it rather than delete it — you may ask us to limit how we use your personal information. Where processing is restricted, we will retain the information but not otherwise use it without your consent, except as permitted by POPIA.

Right to a Copy of Your Data

You may request a copy of the personal information you have provided to us in a structured, commonly used electronic format. We will provide this where it is technically feasible to do so.

Right of Access under PAIA

In addition to your rights under POPIA, you may request access to records held by linqEV (Pty) Ltd in terms of the Promotion of Access to Information Act 2 of 2000. Our PAIA Manual, which explains what records we hold and how to request them, is available at linqev.co.za/paia-manual.

Right to Complain

If you believe we have not handled your personal information lawfully, you may lodge a complaint with the Information Regulator (South Africa). Complaints must be submitted in writing on the prescribed POPIA Form 5.

Information Regulator (South Africa)

We ask that you raise your concern with our Information Officer first, at privacy@linqev.co.za, so that we have an opportunity to resolve it directly.

16. Children's Privacy

The linqEV Services are not directed at, or intended for use by, children under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information without verifiable consent of a parent or guardian, please contact us and we will take steps to delete such information.

17. Marketing Communications

We will send you marketing communications about new linqEV features, promotions, network milestones, and partner offers only where you have opted in or where permitted by law. We do not use WhatsApp or SMS as marketing channels. Messages sent by linqEV on those channels are limited to one-time verification codes and transactional notifications about your own account, wallet, and charging sessions — see section 18.

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your notification preferences in the linqNRG app
• Contacting us at support@linqev.co.za

Opting out of marketing will not affect transactional communications such as session receipts, charger fault notifications, or other operational messages required to deliver the Services.

18. Mobile Messaging (WhatsApp & SMS)

Programme name: linqEV Alerts

linqEV (Pty) Ltd sends messages to Drivers who have provided a mobile number and given express consent during account registration in the linqNRG app or on our website. One-time verification codes are sent by WhatsApp or by SMS. Service notifications relating to your own account, wallet, and charging sessions are sent on WhatsApp. All of these messages are transactional; we do not send marketing or promotional messages on either channel.

Message frequency varies. Standard message and data rates charged by your mobile network or internet service provider may apply. You may opt out at any time by replying STOP to any message, by blocking the linqEV Alerts number in WhatsApp, or by disabling messaging notifications in the app. Reply HELP to any message for assistance, or contact support@linqev.co.za.

We use third-party messaging providers to deliver these messages on our behalf. Your mobile number is disclosed to those providers only to the extent necessary to deliver the messages you have consented to receive, and they are contractually prohibited from using it for any other purpose. WhatsApp messages are delivered over the WhatsApp Business Platform and are also subject to WhatsApp's own terms and privacy policy.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Consent to receive these messages is collected separately from your acceptance of these policies, is specific to linqEV messaging, and is not a condition of opening an account or using the charging network. Withdrawing messaging consent does not affect your ability to use the Services, although we may still need to send you one-time verification codes where these are necessary to authenticate you and secure your account.

linqEV (Pty) Ltd is bound by the WASPA Code of Conduct in respect of SMS messaging sent over South African mobile networks. Should we introduce direct marketing by SMS or WhatsApp in future, it will be sent only to Drivers who have given prior express consent for that purpose in terms of section 69 of POPIA. You may also register a pre-emptive block on direct marketing in terms of section 11 of the Consumer Protection Act 68 of 2008.

19. Consent & Withdrawal

By providing your personal information to us — through our website, the linqNRG app, contact forms, or any other channel — you consent to its processing in accordance with this Privacy Policy. Consent to receive WhatsApp and SMS messages is obtained separately and expressly at the point of registration, is not implied by your use of the Services, and may be withdrawn independently without affecting your ability to use the Services.

You may withdraw your consent at any time by contacting us. Upon withdrawal, we will cease processing your personal information for the relevant purpose, subject to any legal obligations that require us to retain certain data. Please note that withdrawal of consent may affect our ability to provide the Services to you (for example, you cannot use the charging network without an active account).

When we delete data following consent withdrawal, we follow a secure deletion process to ensure your information is safely and completely removed from systems where retention is no longer required.

20. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, Services, or applicable legislation. Where changes are material, we will notify you via the linqNRG app, our website, or by email to the address associated with your account at least 14 days before they take effect. We encourage you to review this policy periodically. Continued use of the Services after the effective date of any update constitutes acceptance of the revised Policy.

The current version of this Policy, with its effective date, is always available at linqev.co.za/privacy-policy. We keep an archive of previous versions, available on request from privacy@linqev.co.za.

21. Contact Us

If you have any queries about this Privacy Policy, wish to exercise your rights, withdraw consent, or access or correct your personal information, please contact us:

Responsible Party

Information Officer

Aadil Aboobaker — privacy@linqev.co.za

Deputy Information Officer

Azim Aboobaker — privacy@linqev.co.za

Registered with the Information Regulator (South Africa) in terms of section 55 of POPIA under registration number 2026-023870, dated 4 June 2026.

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