GENERAL INFORMATION
UAB “Elinta Charge”, Partizanu st. 63M, Kaunas, Lithuania (hereinafter referred to as the “Data Processor”) provides services using the Stuart software under the Elinta Charge app name. The personal data collected through the app and related services is controlled by STUART Energy, UAB, legal entity code 305556655, Saulėtekio al. 15-1, Vilnius, Lithuania (hereinafter referred to as the “Data Controller”). This Privacy Policy (hereinafter – the Privacy Policy) sets out the conditions for processing personal data in the company controlled by the Data Controller, in the mobile app Elinta Charge, and using the website https:/stuart.energy (hereinafter – the Website). The terms of the Privacy Policy apply every time you visit the Website, regardless of which device (computer, mobile phone, tablet, TV, etc.) you use.
As a Data Processor, Elinta Charge processes personal data solely on behalf of and under the instructions of Stuart Energy in compliance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and other applicable laws.
You must read the Privacy Policy carefully, because every time you use the STUART software and visit the Data Controller’s website and/or mobile app, you agree to the terms described in this Privacy Policy.
By providing your data (including data provided directly or indirectly by visiting the Website and using the STUART software or other services), the Data Subject agrees and does not object to the Data Controller’s management and processing of this data under this Privacy Policy, the Data Subject’s consent, and the law.
Purposes and procedures
Individuals under 16 may not provide personal data through the STUART Software or the Data Controller’s Website. If you are a person under 16, you must obtain the consent of your parents or other legal guardians before providing personal information.
- Personal data – any information about an identified or identifiable natural person (Data Subject); “identifiable natural person” means a person who can be identified, directly or indirectly, in particular by an identifier such as name, personal identification number, location and internet identifier or by one or more physical identifiers of that natural person, signs of physiological, genetic, mental, economic, cultural or social identity.
- Representative – a person representing users, data controller partners, and service providers, both natural and legal persons.
- Applicant – a person interested in the STUART software administered by the Data Controller or wishing to contact the Data Controller for other issues.
- The Data Subject in this Privacy Policy is the Representative, the Applicant, the User, the Candidate, the Partner, the Service Provider, the Telephone Callers, or any other natural person whose personal data is processed by the Data Controller.
- Consent of the data subject shall mean any free, specific, and unambiguous expression of the will of a duly informed Data Subject in the form of a statement or unequivocal act by which he or she consents to the processing of personal data concerning him or her.
- STUART software – means a cloud-based STUART solution that allows Users to reserve, connect to, and charge electric car charging stations and pay for services, according to the software functionality, and for individual Electric car charging station administrators to connect to specific Electric vehicle charging stations and manage them according to the OCPP protocol.
- STUART Software User – means a natural or legal person with a User Account in the STUART Software, who can reserve, connect to, and charge Electric Car Charging Stations and charge for the provided services, according to the functionality of the Software.
- Electric Vehicle Charging Station – This is the location of the electric vehicle charging equipment, which allows users with a user account in the Elinta Charge mobile app to connect, charge their electric vehicle, and pay for charging.
- Electric Vehicle Charging Station Administrator – means the Electric Vehicle Station Manager who has agreed with the Data Controller, who has the right to activate and deactivate a specific Electric Vehicle Charging Station, reload and perform other actions enabled by the provided functionality.
- Candidate – a person who participates or intends to participate in selecting personnel by the Data Controller.
- Partner – a natural or legal person who cooperates with the Data Controller or has entered into a cooperation agreement with the Data Controller (eg, for developing an IT tool).
- Service Provider – a natural or legal person who can offer goods, services, or works to the Data Controller and who cooperates with them or has concluded an agreement with the Data Controller on the sale of goods, services, or works.
- Cellphone caller – a person who calls by a publicly announced contact telephone regarding the use (purchase) and/or other issues of the STUART software administered by the Data Controller.
Direct marketing is offering goods and services to individuals and/or seeking their opinion on the goods or services provided by post, telephone, or other means. “Processing of personal data” means any operation or sequence of operations carried out by automated or non-automated means on personal data or sets of personal data, such as collection, recording, sorting, systematisation, storage, editing or modification, retrieval, access, use, disclosure, transmission, distribution or otherwise making them available, as well as collating or merging with other data, restricting, deleting or destroying them. The data controller will collect personal data by the requirements of the applicable legal acts of the European Union and the Republic of Lithuania and the instructions of the controlling authorities. All reasonable technical and administrative measures shall be taken to protect the data collected on Data Subjects from loss, unauthorized use, and alteration.
This Privacy Policy is based on Regulation (EU) 2016/679 of the European Parliament and of the Council on protecting individuals regarding the processing of personal data and the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation). The Law on Legal Protection of Data, other legal acts of the European Union, and the Republic of Lithuania. The terms used in the Privacy Policy shall be understood as they are defined in the General Data Protection Regulation and the Law on the Legal Protection of Personal Data of the Republic of Lithuania.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
- Information provided directly by you.
- Information on how you use our website. If you visit our Website, we also collect information that reveals the features of your use of our services or automatically generates visit statistics. Read more about “Cookie Policy”.
- Information from third-party sources. We may obtain information about you from public and commercial sources (to the extent permitted by applicable law) and link it to other information we receive from you or about you. We may also obtain information about you from third-party social networking services when you connect to them, for example, through accounts on Facebook.
- Other information we collect. We may also collect other information about you, your device, or your use of the content on our site with your consent and/or through our mobile application. You may choose not to provide us with certain information, in which case you may not be permitted to use our service.
PROCESSING OF PERSONAL DATA TO USE THE STUART SOFTWARE AND PROVIDE ITS SERVICES
Processing of personal data of STUART software users (their Representatives). The Data Controller processes the following personal data of the STUART Software Users (their Representatives):
- Name;
- Surname;
- Represented person (relationship with the represented person);
- Workplace (Representatives only);
- Telephone number;
- Email address;
- GPS data about the location of the user’s device;
- Other information related to software use and maintenance services.
The Data is obtained directly from the Users, performing the agreement with the User, and/or from other third parties who have relations with the Data Subject. We undertake not to transfer your data to any unrelated third parties, except in the following cases:
- If there is the Client’s consent to the disclosure of personal data;
- In the legitimate interests of the Data Controller (eg, in the case of debt recovery);
- Authorized institutions by the procedure provided for by the legal acts of the Republic of Lithuania (eg, STI, Police).
Collection and use of user device location data
User device location data is collected only if the User enables this feature. This functionality uses your location data only when the software is enabled and active. Your location is not stored or transferred.
The following data will be used:
- Real-time location detection. Your location will be visible on the map in real time.
- You will be shown the nearest Electric Car charging stations, the distances to them, their availability, and booking options.
Only the device owner activates this feature, and the user explicitly agrees that their device location data will be collected.
The Data Controller may provide the personal data of Users and other Data Subjects to Data Processors not specified in this Policy who offer services (perform works) to the Data Controller and process the personal data of Users and Data Subjects on behalf of the Data Controller (eg, companies providing accounting services). Data controllers have the right to process personal data only by the instructions of the Data Controller and only to the extent necessary for the proper performance of the obligations set out in the contract. With the help of data controllers, the Data Controller shall take all measures required to ensure that the Data Processors have implemented appropriate organizational and technical security measures and maintain the confidentiality of personal data.
Personal data are processed based on the data subject’s consent to the provision of his or her data and/or the performance of a contract with the data subject (Article 6 (1) (a) and (b) of the General Data Protection Regulation).
PROCESSING OF PERSONAL DATA FOR THE PURPOSES OF CONSULTATION, REQUEST EXECUTION
Processing personal data of persons contacting the Data Controller, including Callers, for consultation, inquiry, and/or other matters.
The Data Controller processes the following personal data of Callers, including:
- Name;
- Surname;
- Telephone number;
- Email address;
- Position;
- Workplace.
The personal data of the applicants is not transferred to third parties. Personal data are processed for consultation and request, based on consent expressed in the provision of your data (Article 6 (1) (a) of the General Data Protection Regulation).
PROCESSING OF PERSONAL DATA TO PERFORM CONTRACTS WITH PARTNERS, SERVICE PROVIDERS
The Data Controller, in cooperation with the Partners and Service Providers, processes the following personal data of natural persons or Representatives:
- Name;
- Surname;
- Personal code;
- Address;
- Data of the document substantiating the activity (number of the individual activity certificate, date of issue, etc.);
- In case of e-commerce, payment order data;
- Power of attorney;
- Authorization period;
- Represented person (relationship with the represented person);
- Position;
- Workplace;
- Telephone number;
- Email address;
- Other information is provided in the course of cooperation or performance of the contract.
- Data is obtained directly from Data Subjects, Representatives, and/or represented persons.
- We undertake not to transfer your data to any unrelated third parties, except in the following cases:
- If there is the Data Subject’s consent to the disclosure of personal data;
- In fulfillment of its obligations as Data Controller, eg, data may be transferred to delivery (courier), logistics, archiving, audit, legal, financial services companies, Service Providers, and/or countries related to national, European, and international payment systems such as SWIFT.;
- In the legitimate interests of the Data Controller (eg, in the case of debt recovery);
- Authorized institutions are governed by the procedure provided by the legal acts of the Republic of Lithuania (e.g., STI, SODRA).
The Data Controller may provide the personal data of Data Subjects, Representatives to Data Processors not specified in this Privacy Policy, who offer services (perform works) to the Data Controller and process personal data of Data Subjects, Representatives on behalf of the Data Controller (e.g, to accounting companies). Personal data are processed for the performance of contracts with Service Providers and Suppliers based on the performance of the contract and/or the legitimate interest of the Data Controller (Article 6 (1) (b) and (f) of the General Data Protection Regulation).
PROCESSING OF PERSONAL DATA FOR THE PURPOSE OF DIRECT MARKETING
The data controller seeks to share only current news and other helpful information with the recipients of the newsletters. It does so by this Privacy Policy. The following personal data of Customers and other Data Subjects may be processed for direct marketing:
- Name;
- Surname;
- Email address.
After sending the newsletter, the Data Controller may collect statistics on the data subject’s behavior regarding the use and content of the newsletter (for example, whether the newsletter has been read or which links the Data Subject has opened).
Data subject email and email address can serve ads through Facebook, Google, and other advertising platforms, tailoring the ad to a target audience.
Personal data is obtained directly from the Data Subjects. The Data Controller may only transfer personal Data to third parties providing specialized services to send e-mails.
Emails tailored to the nature of the advertising are ordered through the advertising platforms. The personal data of customers and other Data Subjects are processed based on consent expressed by submitting their data and agreeing to process personal data for direct marketing purposes or the legitimate interest of the Data Controller (Article 6 (1) (a) and (f) of the General Data Protection Regulation) when personal data is processed based on a legal interest of the Data Controller.
We inform you that the Data Subject has the right to object or revoke their consent to process their data for direct marketing purposes without stating the reasons for the objection by writing an email. By email at support@STUART.com or by calling +370 698 07938.
Withdrawal of consent shall not affect the lawfulness of data processing carried out before the withdrawal of consent.
WHAT DO WE DO TO PROTECT YOUR INFORMATION?
Personal data is protected from loss, unauthorized use, and alteration. We have put organizational and technical measures in place to protect all information we collect to provide our services. While we take reasonable steps to protect your information, no website, online transaction, computer system, or wireless connection is completely secure.
The Data Controller applies different terms of personal data storage by legal acts, considering the purposes of personal data processing.
Terms of personal data storage:
Elinta Charge does not own or control the data. All personal data remains under Stuart Energy’s ownership.
Purpose of processing of personal data and holding term
- Purpose – processing of personal data of data subjects for consultation, execution of a request. Holding term – 1 year from the consultation date, fulfillment of the request. Except when the Data Subject applies for the provision of the Services of the Data Controller. The general term of 10 years then applies.
- Purpose – processing of customers’ data. Holding term – during the contract term and for 10 years after the end of the contract.
- Purpose – Personal data of STUART software users insofar as they are related to the use of STUART software, except for GPS data. Holding term – during user account activity. After that, the data is depersonalized.
- Purpose – Processing of personal data of natural persons, Representatives to execute agreements with Partners, and Service Providers. Holding term – during the contract term and for 10 years after the end of the contract.
- Purpose – Processing of personal data of data subjects for direct marketing. Holding term – 5 years from the date of receipt of the consent, unless the Data Subject so wishes to extend this period When the Data Subject’s data are processed for direct marketing based on consent or the legitimate interest of the Data Controller, the Data Controller shall no longer process the Data Subject’s data for direct marketing (immediately destroy) as soon as the Data Subject objects.
Exceptions to the retention periods may be provided to the extent that they do not infringe the rights of Data Subjects and comply with legal requirements.
At the end of the deadlines, if they have not been extended, the data will be destroyed so that it cannot be reproduced.
YOUR RIGHTS
The data subject whose data is processed in the activities of the Data Controller has the following rights:
- The right to know (be informed) about the processing of your data;
- The right of access to your data and how it is processed;
- The right to rectify or, depending on the purposes of the processing of personal data, to supplement incomplete personal data;
- The right to destroy personal data and be “forgotten”, i.e.. suspend your data processing activities (except storage);
- The right to restrict the processing of personal data for one of the legitimate reasons.
- The right to transfer data when the Data Subject has provided his or her data to the Data Controller in a structured, commonly used, and computer-readable format;
- The right to object to the processing of personal data when such data are processed or are intended to be processed for direct marketing, including profiling in so far as it relates to such direct marketing;
- The right to submit a complaint to the State Data Protection Inspectorate of the Republic of Lithuania.
The Data Subject has the right to submit any request or instruction related to the processing of personal data to the Data Controller in writing in one of the following ways: by direct delivery to the address: UAB “STUART Energy”, Saulėtekio al. 15-1, Vilnius; Email: UAB “STUART Energy”, Saulėtekio al. 15-1, Vilnius; Email: support@STUART.com.
Upon receipt of such a request or instruction, the data controller shall, no later than within one month from the date of the request, provide a response and perform or refuse to perform the actions specified in the request. This period may be extended by two months, depending on the complexity and number of applications. In this case, within one month from receipt of the request, the Data Controller shall inform the Data Subject of such extension and the reasons for the delay.
The Data Controller may not enable data subjects to exercise the above rights, except for refusing to process personal data through direct marketing, where the prevention, investigation and detection of criminal offenses, breaches of official or professional ethics and the rights and obligations of the data subject or others are required by law protection of civil liberties.
THIRD-PARTY SITES, SERVICES, AND PRODUCTS ON OUR SITE
The Data Controller’s Website may contain third-party billboards, links to their websites and services over which the Data Controller has no control, such as a link to the Data Controller’s Facebook profile. The controller is not responsible for the security and privacy of information collected by third parties. You must read the privacy statements that apply to the third-party websites and services you use.
If you have provided information about yourself with the help of Facebook, Google, Apple Play, we understand that you agree to provide it by phone and e-mail. We can contact you by email and submit service offers.
FINAL PROVISIONS
Additions or changes to the Privacy Policy take effect from the date of their publication on the Website.
When the Data Subject uses the Website and/or the services provided by the Data Controller after the addition or change of the Privacy Policy, it is considered that the Data Subject does not object to such additions and/or changes.
CONTACT US
If you have any questions about the information in this Privacy Policy, please get in touch with us in any way convenient for you:
Phone: +370 620 77835
Email: info@elintacharge.com
By post: UAB “Elinta Charge”, Partizanu Street. 63M, Kaunas, Lithuania.
Updated 2025-03-18