Privacy Policy

VANTAGE CHARGE

PRIVACY POLICY

Operated by SOMOCO GHANA LIMITED

Effective Date: 15 October 2026

1. Introduction

SOMOCO GHANA LIMITED ("SOMOCO", "Company", "we", "us" or "our"), operating under the brand name Vantage Charge, is committed to respecting and protecting the privacy and personal data of individuals who use our electric vehicle charging services.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you access or use the Vantage Charge mobile application, website, EV charging stations, customer support channels and related services (collectively, the "Services").

We process personal data in accordance with the applicable laws of the Republic of Ghana, including the Data Protection Act, 2012 (Act 843), as well as other applicable legal and regulatory obligations.

By using our Services, you acknowledge that you have been provided with this Privacy Policy. Where consent is required by applicable law, we will request it separately.

2. Information We Collect

We may collect and process the following categories of personal data where necessary for our Services:

a. Personal identification and account information

• Full name;
• Telephone number and email address;
• Account login credentials and authentication information;
• Other information voluntarily provided during account registration or customer support interactions.

b. Vehicle and charging information

• Vehicle make, model and relevant identifiers where provided;
• Preferred charging locations;
• Charging station identification numbers;
• Charging session start and end times;
• Energy consumed in kilowatt-hours (kWh);
• Charging duration, session status and transaction history;
• Technical information required to diagnose charging faults.

c. Payment and billing information

• Payment transaction references;
• Payment amount, date and status;
• Payment method and limited payment identifiers supplied by our authorised payment service providers;
• Refund and billing dispute information.

Payments may be processed through Hubtel or other payment service providers authorised by SOMOCO.

We do not intend to store full payment card numbers, security codes or mobile money PINs in Vantage Charge systems. Where payments are processed through third-party platforms, the relevant provider may process payment credentials under its own applicable terms and privacy arrangements.

d. Location and device information

• Device location where you grant the relevant permission;
• Charging station searches, navigation selections and associated usage information;
• Device type, operating system, application version and technical identifiers;
• Internet Protocol (IP) address and diagnostic information.

Location permissions may be disabled through your device settings, although certain location-based functions may consequently be unavailable.

e. Customer support and communications

• Complaints, enquiries and feedback;
• Support correspondence and technical reports;
• Relevant records of interactions with our customer service team.

3. Purposes of Processing Personal Data

We process personal data for the following purposes:

1. Creating, authenticating and managing customer accounts.
2. Identifying available charging stations and facilitating navigation.
3. Initiating, monitoring, managing and completing charging sessions.
4. Processing payments, issuing transaction confirmations and administering refunds.
5. Maintaining charging history and transaction records.
6. Providing customer support and resolving technical or billing complaints.
7. Identifying and preventing unauthorised access, fraud, misuse and other security incidents.
8. Monitoring equipment functionality and improving service reliability.
9. Analysing service utilisation, charging demand and operational performance.
10. Complying with applicable legal, taxation, accounting, regulatory and reporting requirements.
11. Communicating service interruptions, safety information, changes to terms and other operational notices.
12. Sending promotional communications where permitted by law and applicable consent or opt-out requirements.

We will not use personal data for purposes incompatible with those disclosed at the time of collection unless otherwise permitted by law.

4. Basis for Processing

Depending on the nature of the information and applicable legal requirements, personal data may be processed:

• With your valid consent;
• To provide a service or perform a contract with you;
• To comply with legal or regulatory obligations;
• For legitimate and lawful operational purposes consistent with the Data Protection Act;
• To protect the safety, security and lawful rights of customers, employees and other persons.

Where consent is the appropriate basis, you may withdraw it in accordance with applicable law. Withdrawal will not invalidate processing lawfully undertaken before withdrawal.

5. Sharing and Disclosure of Information

SOMOCO may disclose relevant personal data, where lawfully permitted and reasonably necessary, to:

a. Technology providers: Third parties supporting the mobile application, cloud hosting, charger-management platform, telecommunications infrastructure and technical maintenance, including GCSS Technology Limited where applicable.

b. Payment service providers: Hubtel, participating financial institutions, mobile money operators and other authorised payment processors necessary to facilitate transactions, reconciliation and refunds.

c. Operational service providers: Contractors, charging station maintenance partners, customer support providers and professional advisers requiring information for an authorised business purpose.

d. Regulatory and legal authorities: Government departments, law enforcement agencies, courts, regulators and other competent authorities where disclosure is required or permitted by law.

e. Group companies: Affiliates of SOMOCO where disclosure is lawfully justified, necessary for an identified purpose and subject to suitable safeguards.

We do not sell customers' personal data to third parties.

Service providers receiving personal data on our behalf shall be required, where applicable, to maintain appropriate confidentiality, security and data protection arrangements.

6. International Transfer of Personal Data

Certain technology providers, technical support teams or cloud infrastructure used by Vantage Charge may be located outside Ghana.

Where personal data is transferred internationally, SOMOCO will take appropriate steps to ensure that such transfers comply with applicable Ghanaian data protection requirements, including suitable contractual, organisational and technical safeguards.

International transfers will be limited to lawful and identified purposes.

7. Data Security

We implement reasonable technical, administrative and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, destruction and loss.

These measures may include, as appropriate:

• Access controls and authentication mechanisms;
• Encryption and secure transmission protocols;
• Restrictions on staff and contractor access;
• Security monitoring and incident management;
• Periodic review of relevant security controls;
• Confidentiality obligations for authorised personnel and service providers.

Although we take reasonable security precautions, no electronic system or internet transmission can be guaranteed to be completely secure.

SOMOCO will investigate and respond to suspected personal data incidents in accordance with applicable law.

8. Data Retention

We will retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, subject to legal, regulatory, accounting, tax, security and dispute-resolution requirements.

Retention periods may differ by data category.

For example, account and profile information may ordinarily be retained while an account remains active, while payment and transaction records may need to be retained after account deletion to satisfy applicable legal obligations.

At the end of the applicable retention period, personal data will be securely deleted, anonymised or otherwise disposed of in accordance with our retention procedures.

9. Your Data Protection Rights

Subject to applicable law, you may have the right to:

1. Request information about the processing of your personal data.
2. Request access to personal data held about you.
3. Request the correction or updating of inaccurate personal data.
4. Object to certain processing of your personal data.
5. Withdraw consent where processing is based on consent.
6. Request the deletion or restriction of personal data where permitted by law.
7. Raise concerns about the handling of your personal information.

Requests may be submitted using the contact details in Section 14.

We may take reasonable steps to verify your identity before processing a request.

Where a request cannot be fully accommodated due to legal obligations or other lawful grounds, we will explain the applicable limitation.

You may also raise a complaint with Ghana's Data Protection Commission.

10. Cookies and Application Analytics

The Vantage Charge website or application may use cookies, software development kits, application diagnostics or similar technologies to support security, performance measurement, user preferences and service improvement.

Where analytics or optional tracking technologies are used, appropriate notices and user choices will be provided as required by applicable law.

Users may be able to restrict certain technologies through browser, device or application settings.

11. Marketing Communications

Where permitted by applicable law, we may communicate information about Vantage Charge products, charging promotions, service developments and related offerings.

You may request to stop receiving optional marketing communications through available unsubscribe mechanisms, application preferences or our customer service channels.

Opting out of marketing will not prevent us from sending necessary operational, security, payment or account-related communications.

12. Third-Party Services and Websites

The Services may contain links to third-party websites, payment platforms, navigation applications or other external services.

Such third parties may operate under their own terms and privacy policies.

We encourage you to review the applicable privacy policies before providing information directly to third-party services.

13. Changes to this Privacy Policy

We may revise this Privacy Policy periodically to reflect changes in law, operational arrangements, technology or the Services.

The latest version will be made available through the Vantage Charge application or official website.

Where material changes require additional notice or consent under applicable law, we will take the necessary steps before implementing the relevant processing.

14. Contact Information

For privacy enquiries, complaints and requests concerning personal data, please contact: info@vantageev.com

SOMOCO GHANA LIMITED
Trading as Vantage Charge