Privacy Policy – FCU | Rolling Energy Resources

PRIVACY POLICY

Revision 11 September 2024

Rolling Energy Resources Inc. was acquired by EV DOT ENERGY LIMITED, a company registered in England and Wales whose registered address is at 86-90 Paul St, London EC2A 4NE, United Kingdom.

EV DOT ENERGY LIMITED will continue to use the Rolling Energy Resources Inc. brand references throughout or other references such as “RER,” “us,” “we,” or “our”. We have prepared this Privacy Policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) our online and offline practices regarding the personal information that RER collects, uses, and shares on behalf of end users (“Users”) of our online platform (the “Platform”) accessed through the website located at https://rollingenergyresources.com/ and any other websites operated by RER (each, a “Site”) or using mobile applications provided by and on behalf of RER (each, an “Application,” and each Site and Application treated as a part of the “Platform” for purposes of this Privacy Policy) and of our service offered through the Platform (the “Services”).

In some cases, we may act as an agent of the energy service provider with which you have a customer relationship (the “Utility Provider”). In such a situation, the Utility Provider has engaged RER to provide Services. This Privacy Policy does not apply to the non-personal information described below that is collected by, used by, disclosed by, or disclosed to your Utility Provider. This Privacy Policy only applies to RER’s collection, use, and disclosure of personal information. For more information about your Utility Provider’s privacy practices please contact your Utility Provider directly.

You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

COLLECTION OF PERSONAL INFORMATION

1.1. Personal Information. The following are categories (with non-exhaustive examples) of personal information we may collect about you and for each category the purpose for which it may be used:

Categories	Examples
A. Individual Identifiers and Demographic Information	A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
B. Geolocation Data	Precise physical location while charging.
C. Energy Usage Information	Energy usage information from your vehicle.

Personal information does not include:

Publicly Available Data – Publicly available information from government records.
Deidentified or Aggregate Information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which RER has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.
Excluded Information – Certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. Such laws include health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or clinical trial data; the Gramm-Leach-Bliley Act (GLBA); Fair Credit Reporting Act (FCRA); and the Driver’s Privacy Protection Act of 1994.

1.2. Sources of Personal Information. We obtain the categories of personal information listed above on or through our Platform from the following categories of sources:

Personal Information You Provide. RER collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from you when you create an account; edit registration information; sign up to receive promotional communications; use or access a Service or content available through the Platform; participate in one of our promotional sweepstakes, contests, or surveys; post a review; submit a request to our customer service team; interact with our social media pages; or otherwise interact with us or other Users through the Platform.
Automatically Collected Personal Information. In addition to personal information that we may receive directly from you, RER indirectly collects other information from you automatically through the Platform. For example, we receive personal information from Users when a User visits and navigates our Platform on any device; installs and uses the Application; enables location-based features on the Application. We may also collect personal information about Users over time and across different websites, apps, and devices when a User accesses the Platform. Third parties also collect personal information this way on our Platform. RER collects some personal information automatically using cookies or other online tracking technologies.
Personal Information from Your Vehicle: We may receive and store information directly from your vehicle, including vehicle make and model, battery charge, location, and odometer readings. For example, we may calculate your cost per mile driven by collecting charge times, battery percent, and odometer readings.
Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, RER may receive personal information about you from other third party sources. For example, we receive personal information from your Utility Provider, our business partners, social media sites, or companies that provide personal information to supplement what we already know about Users.. We may merge or combine such personal information with the personal information we collect from you directly or automatically.

USE OF PERSONAL INFORMATION

RER’s primary purpose in collecting personal information is to provide the Services that you request on the Platform. RER may also use personal information for various purposes, including without limitation to:

To Provide Our Services. We use your vehicle’s charging data to provide monthly reports to help you understand your charging patterns, and to understand infrastructure needs to support charging. If you opt-in to a time of use assistance program or demand response program with your utility, we may use your vehicles charging data to delay charging. We use your vehicles miles calculate how many miles you need per day, as well as fuel costs per mile.
To Improve Our Services and Platform for the Fort Collins Utilities Program. We use personal information to understand and analyze the usage trends and preferences of our Users to make our Platform, Services, and Content better, diagnose technical issues, prevent fraud, and develop new features and functionality.
To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
To Determine Your Eligibility and Set Up Your Account. We use your personal information to verify your identity or determine your eligibility for some of our Services, and promotions. For example, this may include verifying your age, and utility provider. If you set up an account on the Platform, we will use the registration information you provide in relation to that account creation to create, maintain, customize, and secure your account.
To Secure the Platform. We use personal information to maintain the safety, security, and integrity of our Platform and Services, databases and other technology assets, business, and other Users.
To Communicate with You. We may communicate with you about your account or our relationship. We may also contact you about this Privacy Policy or the Terms of Service.
As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

We may create non-personal Deidentified Information or Aggregate Information from the information we collect, as permitted by law. We may use that data for our own purposes or disclose it in a non-personally identifiable manner to:

Organizations and government entities that conduct research into energy usage or smart-grid technologies;
Other Users of the Services for purposes of comparing energy usage to the broader community.

SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, RER may share your personal information in the following circumstances:

3.1. Utility Providers. We disclose personal information to your Utility Provider for their own purposes and subject to their privacy policy and practices.

3.2. Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us).

3.3. Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.

3.4. Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.

3.5. Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, marketing, or any other use set out in this Privacy Policy. Access to your personal information by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function. We require our service providers to keep the personal information that they are provided with confidential and to comply with all applicable laws.

SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, including encrypting your passwords, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

YOUR CHOICES

You can make the following choices regarding your personal information:

5.1. Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.

5.2. Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal information, please contact us as described below.

5.3. Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.

OPTING OUT

You can make the following choices to opt out of certain activities regarding your personal information:

Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.

EXERCISING YOUR PRIVACY RIGHTS

When exercising the rights or options described in this Privacy Policy, the following guidelines apply:

8.1. No Fee Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights).

8.2. What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.3. Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

8.4. No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain Services. These responses are not discrimination and our reasons for declining your request or ceasing Services will be provided at that time.

8.5. Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s identification information, and the authorized agent’s identification information.

END

COOKIE POLICY

INTRODUCTION

Rolling Energy Resources Inc. ( “RER” or “we” or “us” or “our”) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website rollingenergyresources.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) to help customize the Site and improve your experience. This Policy also applies to the Personal Information RER receives when customers (“Customers”) use the Site in connection with RER’s web analytics services (the “Service”). As used herein, the terms “You” or “your” shall apply to individual users of the Site, or in connection with your use of the Service. If You have any questions or comments regarding this Policy, please contact us at privacy@rollingenergyresources.com.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Site after the date such revised Cookie Policy is posted.

USE OF COOKIES

To help operate the Site and Service, enhance your experience, and collect information about online activity, RER places small data files on your device known as “cookies”, or other similar technologies (e.g., pixel tags, web beacons, local shared objects). Cookies and similar technologies enable RER to personalize the Site, help make the Site load faster (through “load balancing” technology) and enable Customers to collect useful data with the Service. These technologies may allow RER and its Customers to store and manage your preferences and settings; measure and analyze how You use the Site and Services and effectiveness of RER communications; offer targeted products, programs, and services; and help RER improve its products, services, and security.

The table below explains the types of cookies RER uses on its websites and why they are used. Also provided are examples of the cookies set by RER, with explanations of their purpose. Please note that this is not an exhaustive list, but rather aims to be a representative summary.

Cookie	Description
Essential and Strictly Necessary	These cookies are essential for the website and services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” on for e-commerce functionality.
Functionality	These cookies are used to store preferences set by users such as account name, language, and location.
Security	RER use these cookies to help identify and prevent potential security risks.
Analytics and Performance	Performance cookies collect information on how visitors interact with RER websites, including what pages are visited most, as well as other analytical data. RER uses these details to improve how the websites function and to understand how visitors interact with them.

You may wish to restrict the use of cookies or completely prevent them from being set. If You disable cookies though, please be aware that some of the features of the RER Site or Service may not function correctly. Most modern browsers allow You to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or You can use the help option in your browser for more details:

To find out more on how to manage and delete cookies, visit https://aboutcookies.org/. For more details on your choices regarding use of your web browsing activity for interest-based advertising You may visit the following sites:

On a mobile device, You may also be to adjust your settings to limit ad tracking.

You may see a “cookie banner” on our websites. If You are visiting one of the RER Customer’s sites from the EU, then RER does not set, or allow its ad partners to set, cookies that are used to show You targeted ads before You click to accept. When You consent in this manner, RER and its advertising partners may set advertising cookies on the site You are visiting and on other of our websites, dashboards, and services. RER will display the banner to You periodically, just in case You change your mind.

OTHER TRACKING TECHNOLOGIES

In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customize the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.