Ellam Electric – Privacy Policy / Privacy Notice

1. Who We Are

Ellam Electric is an EV charging discovery, booking and payments facilitation platform owned and operated by Tamil Nadu Green Energy Corporation Limited (TNGECL).

Technology services (development, hosting/operations support) are provided by Kazam India Ltd. under contract with TNGECL.

2. Scope of this Privacy Policy

This Privacy Policy explains how we collect, use, share, store and protect your personal data when you use the Ellam Electric mobile application and related services (the "App/Platform").

This document should be read together with the Terms of Use and the Refund & Booking Policy.

3. Types of Data We Collect

Depending on the features you use, we may collect the following categories of data:

• Account & identity data: mobile number, OTP verification status, name/email (if provided), user account identifiers.
• Vehicle & preference data (optional): EV model, connector type preference, trip planner and TCO inputs you provide.
• Charging, booking & roaming data: station/charger selection, booking slot, session timestamps, energy delivered (kWh), session status and error codes, roaming network identifiers (as available through integrations).
• Location data (with permission): precise/approximate location to show nearby chargers, navigation, booking and fraud prevention.
• Payments & wallet data: payment method type (UPI/Credit or Debit card/ Payment wallet), transaction references, amounts, status; wallet top-ups and wallet ledger entries.
• KYC data (only if required for wallet/limits): KYC details may be collected/processed through Razorpay and/or its regulated partners, as applicable.
• Device & technical data: IP address, app version, device identifiers (where permitted), diagnostics/crash logs.
• User content: reviews, ratings, comments and station photos (if uploaded).
• Support & grievance data: complaint tickets, emails/chats, transaction references and evidence you submit for dispute resolution.

4. What We Do NOT Collect / Store

We do not store your UPI PIN, card CVV, or full card number on our servers. Such sensitive authentication data is handled by authorised payment networks and payment service providers.

5. Purposes of Processing

We use your data only for purposes that are necessary to provide and improve the Platform, including:

• Creating and managing your account and authentication.
• Providing charger discovery, navigation, trip planning and TCO tools.
• Enabling bookings/reservations and related communications.
• Enabling charging sessions and roaming/interoperability across multiple CPO networks (where supported).
• Processing payments through Razorpay and partner networks, and supporting reconciliation and dispute handling.
• Facilitating refund coordination and complaint routing to the relevant Charging Point Operator (CPO) (refund initiation is by the CPO).
• Customer support, grievance redressal and service communications.
• Security, fraud prevention, misuse detection and platform integrity.
• Analytics and service improvement (preferably aggregated/de-identified where feasible).
• Compliance with applicable laws, audits, and responding to lawful requests.

6. Legal Bases

We process personal data based on one or more of the following, as applicable: (a) your consent (for example, location permissions and optional preferences), (b) performance of services requested by you (charging facilitation, booking, wallet and support), and (c) compliance with law and protection of the Platform (security and fraud prevention) with appropriate safeguards.

7. Sharing of Data

We do not sell your personal data. We may share data on a need-to-know basis with:

• Charging Point Operators (CPOs) and roaming/interoperability partners for enabling booking and charging sessions.
• Razorpay and associated payment service providers/banks for processing UPI/card/wallet payments and refunds.
• Service providers (hosting, maps, messaging/SMS/email, analytics, security monitoring, customer support tools) under contracts and access controls.
• Government/Regulators/Law enforcement when required under applicable law or valid legal process.

8. Cross-border Processing

If any of our service providers process data outside India (for example, certain cloud or analytics services), we will implement controls to ensure such transfers comply with applicable Indian law and government-notified requirements.

9. Data Retention & Deletion

We retain personal data only for as long as necessary for the purposes stated above, including dispute resolution, fraud prevention and legal compliance.

When you request deletion or withdraw consent (where applicable), we will erase or anonymize data unless retention is required by law or necessary to establish, exercise or defend legal claims.

10. Security Safeguards

We implement reasonable technical and organisational measures to protect personal data, such as access controls, encryption where appropriate, logging/monitoring, secure development practices and incident response procedures.

11. Personal Data Breach

If a personal data breach occurs, we will take steps to contain and remediate and will notify affected users and the competent authority as required by applicable law.

12. Your Rights & Choices

Subject to applicable law, you may request access, correction, updating, deletion/erasure (where applicable) and withdrawal of consent for consent-based processing.

You can control app permissions (location/notifications) in your device settings.

13. Contact for Privacy Requests

Authorised Contact (Privacy / Rights Requests):

• Designation: Superintending Engineer / Solar
• Email: sesolar[at]tnebnet[dot]org
• Phone (alternate contact): +91 9445448815
• Postal Address: Tamil Nadu Green Energy Corporation Limited, 10th Floor, NPKRR Maaligai, 144, Anna Salai, Chennai, Tamil Nadu – 600002
• Customer Care (8 AM to 8 PM): ev.charging[at]tnebnet[dot]org | +91 8925872398

14. In-App Consent & Permissions – Standard Text

The following text is intended for display inside the App at the point of collection/permission requests (Just-In-Time notices).

15. Language

This Privacy Policy is published in English. TNGECL may also publish a Tamil version for user convenience. In case of conflict, the English version shall prevail unless required otherwise by applicable law.

16. Effective Use

By using the App, you acknowledge that you have read and understood this Privacy Policy.