1. Who we are and how to talk to us
ClubeCharger is operated by CLUBE CHARGER LTDA., a legal entity registered with the CNPJ under nº 52.237.055/0001-13, with headquarters at Av. Jacob, nº 355, Sala A, Jardim Tropical, Imperatriz/MA, CEP 65.910-727.
For privacy, data protection, account deletion or questions about this Policy, use the official channels: email contato@clubecharger.com or telephone (99) 3198-0030.
2. Scope of this Policy
This Policy applies to drivers, station operators, operational team members, administrators, website visitors and people who interact with ClubeCharger support.
The platform acts as an intermediation, management and software licensing technology for charging infrastructure. The physical execution of the recharge is carried out by the owner or operator of the registered station.
3. Personal data we may collect
The data processed varies depending on the use of the platform. We can collect and process:
- Registration and account data: name, email, hash-protected password, telephone number, DDI/country, tax identifier, language, time zone, account status and consents.
- Authentication data: local credentials, login events, password recovery and, when using Google login, provider identifier, verified email, name, photo and metadata returned by Google.
- Financial and payment data: wallet balance, source of funds, financial movements, withdrawal requests, payment references, transaction status, receipts, card data entered for processing, PIX, Bitcoin or SWIFT data and information necessary for fraud prevention and reconciliation.
- Recharge data: station used, connector, session start/end, energy consumed, power, tariff, discounts, coupons, reports, OCPP transactions, reconciliations and technical-financial history of the session.
- Station and operation data: registered stations, address, coordinates, connectors, power, price, photos, comments, public status, OCPP identifier, station codes, technical events and operational commands.
- Location data: Approximate or precise location used for map, nearby stations, route to station, and trip planning when you trigger the function or grant permission.
- Camera data: image captured locally for reading the station's QR Code when you use the QR reader. The objective is to identify the station; Reading occurs in the app's flow and is not used for facial recognition or advertising.
- Voice and support data: messages, textual attachments, transcriptions, temporary audio during a call, service summary, support events and operational context of the logged in account.
- Technical data: IP address, user agent, session identifiers, security logs, essential browsing events, errors, availability metrics, PWA cache and data necessary to keep the service running.
- Content you submit: comments, ratings, station photos, form responses, support requests, staffing data, and operator business information.
4. How we collect data
We collect data when you create an account, log in, accept the Terms and this Policy, edit your profile, register a station, add credit, request a withdrawal, start or end recharge, use the map, plan a trip, read QR Code, chat with support, use Google login or interact with payment integrations.
We also automatically receive technical data from browsers, devices, servers, OCPP stations, payment processors and infrastructure providers when this is necessary to perform the service.
5. Purposes of treatment
We use personal data to:
- create, authenticate, secure and manage accounts;
- comply with the Terms of Service and perform top-ups, wallet, payments, withdrawals, reporting and support;
- display stations, map, routes, availability, prices and usage history;
- validate identity, telephone number, email, country, tax identifier and operational eligibility;
- process PIX, card, Bitcoin, SWIFT, cancellations, reconciliations, receipts and financial audit;
- monitor OCPP events, remote commands, connector status, technical failures and offline session reconciliation;
- prevent fraud, abuse, improper access, default, double credit and security incidents;
- provide text and voice support, including context of the logged in account and the stations you can access;
- comply with legal, regulatory, tax, accounting, consumer obligations and valid requests from authorities;
- improve the stability, security, usability, accessibility, internationalization and performance of the platform.
6. Legal bases
We process data based on the General Data Protection Law (Law No. 13,709/2018), as applicable: execution of a contract, compliance with legal or regulatory obligations, regular exercise of rights, legitimate interest, fraud prevention, credit protection and consent when required.
When we rely on consent, you can revoke it through official channels or through device settings, subject to processing that needs to continue due to legal obligation, auditing, security, fraud prevention or exercise of rights.
7. App Permissions and Sensitive Features
Location: used to show your position on the map, calculate distance to stations, suggest alternatives and plan trips. We do not use background location for advertising or ongoing tracking.
Camera: used to read station QR Codes when you choose to start charging via QR. You can use manual code entry when you do not want or cannot use the camera.
Microphone/Voice: Used only when you initiate a voice support call. The audio is processed for answering, transcription and operational summary of the call.
Storage/cache: the PWA can keep essential files in a local cache for the app to function and update. This cache does not replace the canonical records maintained on the servers.
8. Data Sharing
We do not sell personal data. We may share strictly necessary data with:
- station operators, when necessary to perform recharging, operational support, reports, station management and transfers;
- payment processors and partners, such as acquirers, PSPs, banks, payment arrangements, PIX, Bitcoin, SWIFT, anti-fraud and reconciliation;
- authentication providers, such as Google, when you choose to use Google login;
- infrastructure, hosting, database, email, messaging, support, voice, AI and security providers;
- map, route and geocoding services when you trigger external location, route or navigation functions;
- public authorities, regulatory bodies, courts or third parties when there is a legal obligation, valid order, defense of rights or investigation of abuse;
- potential successors in the event of corporate reorganization, merger, acquisition or similar operation, with compatible protection and notice when applicable.
We require that third parties who process data on our behalf adopt protection compatible with this Policy and use data only for contracted or legally permitted purposes.
9. International transfer
Some infrastructure, authentication, payment, support, voice, AI, email or security providers may operate outside Brazil. When there is an international transfer, we adopt reasonable contractual, technical and organizational measures to protect the data in accordance with the LGPD and applicable standards.
10. Security
We adopt security measures proportionate to the risk, including HTTPS/TLS, access control, segregation of environments and permissions, audit logs, session validations, criticality retention, credential protection, webhooks validation, financial idempotence and operational monitoring.
No system is absolutely immune to failure. If we identify a relevant incident involving personal data, we will take the appropriate measures in accordance with applicable legislation.
11. Retention and disposal
We keep data for as long as necessary to run the platform, comply with legal, tax, accounting and regulatory obligations, prevent fraud, resolve disputes, audit transactions and preserve operational security.
Financial records, top-ups, payments, withdrawals, consents, fiscal identifiers, security logs and technical events may be retained for longer periods when necessary for legal obligations, audits, conciliation or regular exercise of rights.
Routine OCPP logs may have lower operational retention than core events, according to current technical policy. Ancillary content, support messages and cache data may be deleted, anonymized or retained as required by operational and legal requirements.
12. Your rights and account deletion
You can request confirmation of treatment, access, correction, portability, anonymization, blocking, deletion, sharing information, review of automated decisions when applicable and revocation of consent.
You can also request account deletion by email at contato@clubecharger.com. Deletion may require identity validation and settlement or closure of pending issues, such as open recharges, pending charges, withdrawals, transfers, disputes, tax obligations or anti-fraud registrations.
When the deletion is complete, we will delete or anonymize data that does not need to be retained for legal obligation, audit, security, fraud prevention, financial reconciliation or regular exercise of rights.
13. Children and teenagers
The platform is not aimed at children. The use of financial resources, recharging and management of stations requires legal capacity to hire or authorization and monitoring by a legal guardian, in accordance with applicable legislation.
14. Cookies, sessions and similar technologies
We use cookies, local storage and similar technologies for authentication, security, language preference, PWA operation, asset caching, fraud prevention and session maintenance. You can set your browser to block cookies, but this may prevent login and essential functionality.
15. Declarations for application stores
For transparency purposes on Google Play and App Store, the platform may collect or process categories such as personal information, financial information, location, user-generated content, purchase/transaction history, identifiers, usage data, diagnostics, supporting audio and camera images for QR Code. Effective categories must be declared in a manner consistent with this Policy on store privacy forms.
We do not use sensitive personal data for behavioral advertising and we do not sell personal data.
16. Changes to this Policy
We may update this Policy to reflect changing legal, technical, operational, business or app store requirements. When the change is relevant, we may request new acceptance or communicate through appropriate channels.