Privacy Policy for Elli Charging (Elli App)

Status: October 2025

Thank you for using our Elli Charging mobile application (“app”). This information applies to the following services and functions, provided they are available in a country, an app version and depending on the mobile device and vehicle model.

Please find below information about the controllers and their responsibilities (Section A), about how your data is collected, processed, and utilized in connection with the use of the app for information purposes (Section B) and in connection with the use of Elli Charging (Sections C–G), as well as about your rights and contact persons (Sections H–K).

A. Controller

The app is made available to you by Volkswagen Group Charging GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, Germany, e-mail: info@elli.eco, entered in the Commercial Register of the District Court of Charlottenburg under HRB 208967 B ("Elli"), which processes your personal data.

With regard to the use of public charging services, please refer to the privacy policy of Elli Mobility GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, Germany, which is responsible for the provision of this service. You can find the privacy policy here: https://prod.documents.elli.eco/documents/privacyPolicyElliMobility/DE/1.0/privacyPolicyElliMobility_de.pdf

B. General information on using the app

I. General information

Unless you register or otherwise provide us with information, we collect the data described below, which is technically necessary for us to offer you the functions of the App and to ensure the stability and security of the App:

We process this information to enable a technically functional app (e.g. by adapting the app to the needs of your device type). In addition, this information is processed to optimize the Elli-App and to guarantee the stability and security of the app and our information technology systems. The automatically collected data is not personal related and does not allow any inference to you, it is stored for 30 days and then properly deleted, unless longer storage is required or justified by law.

II. Search and find charging stations and share with Google/Apple maps

If you wish to use the search and find function for charging stations, the map service of Google Maps (a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) is integrated on your device. This map service allows you to view charging stations. If you use this service, once enabled, your location is sent to the map service at the time of your query. Please note that this map service is provided to you by Google under its own responsibility. We are not responsible for data processing by Google. Privacy information for the Google Maps service may be found at https://policies.google.com/privacy?hl=de.

You can also share the charging stations described above on your device with the map service that is available or installed on your device (e.g., Apple Maps, Google Maps, etc.). If you use this function, the relevant map service will process your location at the time of sharing as well as shared destinations (e.g., an available charging station including its address). Please note that the map services are provided under the responsibility of the respective provider. We are not responsible for data processing. You can find information on data protection with regard to the map service in the privacy policy of the respective provider; this information is available, for example, at https://www.apple.com/legal/internet-services/maps/terms-de.html for Apple Maps.

If you use one of the two aforementioned services, we will store the corresponding data for technical reasons only temporarily. The legal basis for this data processing is your use of the corresponding services (Article 6, paragraph 1, letter b, GDPR). As soon as you log off, your personal data is deleted. After one year of non-use at the latest, they are deregistered for security reasons and have to register again. In this case too, the temporarily stored data will be deleted.

III. Tracking Tools

Volkswagen Group Charging GmbH uses Google Firebase (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to collect anonymous data on the use of the software for the purpose of improving the software, the components configured with it, and the services. The following information is logged: the frequency of use of the software, individual functions, software malfunctions, the componet model and version, information of the status of the component, as well as the model, operating system, language, and country of the device. No personal data will be transmitted to Volkswagen Group Charging GmbH.

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights.

IV. Attribution tools

Volkswagen Group Charging GmbH uses the Adjust analytics platform for app attribution, to improve the user experience, and to optimize the scaling of the app. We collect and process the following data for this purpose:

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights.

For this purpose, we use the processor Adjust GmbH ("Adjust") based at Saarbrücker Str. 37a, 10405 Berlin.

V. Analytics tools

Volkswagen Group Charging GmbH uses the Amplitude analytics platform for app analytics to gain insights into the use of the app and its features. This allows us to improve your experience by implementing updates or new features tailored to your needs.

The analytics platform is provided by Amplitude, Inc. (“Amplitude”), located at 201 3rd Street, Suite 200, San Francisco, CA 94103, U.S., whose services we employ as our processor.

We collect and process the following data for this purpose:

Amplitude is not able to establish the identity of an individual user. We do not receive any data on individual users from Amplitude, only statistics and analyses in an overall context, which are made available to us in aggregated form via the user interface provided by Amplitude. We make no attempt to identity or track the behavior of individual users.

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge.

Go to “Your rights” in this Privacy Policy for further information on exercising your rights. We will also delete your personal data after three (3) years at the latest or when the purpose no longer exists. Data is transferred to the USA when data is processed by Amplitude Amplitude is certified under the EU-U.S. Data Privacy Framework, which serves as an adequacy decision of the EU as a guarantee for third-country transfers. Beyond that, we have also concluded standard contractual clauses with Amplitude. You can request information on the content of these clauses from the contacts listed in this Privacy Policy.

VI. Feature management with LaunchDarkly

We use the LaunchDarkly feature management platform in order to use feature flags in the app. This enables us to selectively enable and test various features in the app and thereby improve your experience and the quality of the app.

We collect and process the following data for this purpose:

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. We will also delete your personal data after three (3) years at the latest or when the purpose no longer exists.

For this service, we use the platform of Catamorphic Co. dba LaunchDarkly, who provides the service (“LaunchDarkly”), located at 1999 Harrison St., Suite 1100, Oakland, CA 94612 U.S., whose services we employ as our processor. Your data will be transferred to the U.S. for this purpose. To this end, we have concluded EU standard contractual clauses with the service provider, which act as a guarantee for this transfer of data. You can request information on the content of these standard contractual clauses at any time from the contacts listed in Section K.

VII. Remote logging

We log your use of the app by means of the remote logging function provided as a Google Cloud service. Along with that, we also log other problems beyond crashes, bugs, or residual currents. This allows us to investigate potential problems across all devices and troubleshoot them more quickly. Our aim in using remote logging is to ensure that you can use the app free of error at all times and that all content is made available to you free of any problems. We use the Google service for this purpose, which is why the following personal data is transmitted to Google:

The client ID is randomly generated when the app is downloaded and saved on the backend. If you delete the app and download it again, a new client ID will be generated.

Processing is carried out on the basis of our legitimate interest in the functionality of our service and our app environment (Art. 6(1)(f) GDPR). Your data will be deleted once the purpose ceases to apply. You can read about your right to object and how to assert it in Sections J and K.

For this service, we employ the services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S. (“Google LLC”) as a sub-processor. This means that data may be transferred to the USA. For more information on this, please read Google’s privacy policy: https://cloud.google.com/terms/cloud-privacy-notice?hl=en. The EU standard contractual clauses used by Google can be viewed under the following link: https://cloud.google.com/terms/eu-model-contract-clause

C. Processing of Your Data Upon Conclusion of the Agreement

I. Elli user account

To use our service via the app, you need an Elli user account. You can register directly in the Elli app in order to create and manage a profile.

When you use our services, we process the information from your user account (your personal contact and identification data, such as your name, mailing address, and e-mail address) for purposes of fulfilling the agreement (Art. 6(1)(b) GDPR) and store this data until you request that your account be deleted or for up to five (5) years after the last time you log in.

We use Auth0 (10800 NE 8th Street, Suite 700, Bellevue, WA 98004, U.S.) to provide your account and login with your ELLI ID, whereby your data is processed in the USA. Use includes the storage of personal contact and identification data, such as name, postal address, and e-mail address.

To this end, we have concluded EU standard contractual clauses with the service provider, which act as a guarantee for this transfer of data. You can request information on the content of these standard contractual clauses at any time from the contacts listed in Section K.

II. Charging service (public charging)

The public charging service is provided to you by Elli Mobility GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, Germany. Information concerning the processing of your personal data can be found at: https://prod.documents.elli.eco/documents/privacyPolicyElliMobility/DE/1.0/privacyPolicyElliMobility_de.pdf

III. Charge at Home (only available for chargers with connectivity features)

Please note that the use of Charge at Home services and associated online services (e.g., optimized charging at home charging stations on the basis of: power generated by solar panels based on real-time data; power generated by solar panels based on forecast data; European Power Exchange prices; flexible electricity tariffs) requires that the electrical installation, configuration, and connection of a charger be carried out in advance and, depending on the services used, other devices equipped with connectivity features.

a. Linking the charger

We process the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that your charger is up-to-date and able to communicate, including the Wi-Fi connection or LTE mobile communications standard (so-called connectivity features), as part of the electrical installation and configuration process:

If you want to use optional online services, you will need to authorize your charger and link it to your existing user account via a pairing code. You can then access charging statistics and information on your charging history at any time, manage and remotely control your charger (e.g., manage access options), and manage RFID charging cards (e.g., enable or disable them for use at the charger). Within the scope of using optional online services, we process the following personal and other technical data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to Section I for further information on the retention obligations for your data and to Section J for more information on exercising your rights.

b. Linking the vehicle

We process the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that it is possible to communication with your vehicle during the electrical installation and configuration process:

If you want to use optional online services, you will need to authorize your vehicle and link it to your existing Elli user account by way of a user account with the manufacturer of your vehicle. You can then access charging settings and information on the state of the charge at any time as well as manage and remotely control your vehicles (e.g., manage access options). You also have the option of redirecting the Elli app to your user account with the manufacturer of your vehicle, logging in with this account, and registering the link with your Elli user account in this account. To create and manage a profile in order to use the optional online services, you will need a user account with the relevant manufacturer of your vehicle. Please note the detailed privacy policy that applies for your vehicle manufacturer. This can be viewed on the website of your vehicle manufacturer, in the information and directions on use, or on other media provided by your vehicle manufacturer as the responsible service provider. We process the data from your user account with the manufacturer of your vehicle (your personal contact and identification data, such as your name, address, and e-mail address) for the purpose of fulfilling the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above.

Within the scope of using optional online services, we therefore process the following personal data in order to provide and render the service described above: customer and user ID (data shared from your user account and e-mail addresses of the users you optionally unlocked). In addition, we also receive the following categories of data from your vehicle manufacturer (e.g., Volkswagen AG) for the same purpose in conjunction with the vehicle identification number (VIN) and your customer ID number:

Please note the relevant privacy policy that applies for your vehicle manufacturer. This can be viewed on the website of your vehicle manufacturer, in the information and directions on use, or on other media provided by your vehicle manufacturer.

If you want to use optional online services for intelligent charging functions (e.g., Elli Smart Charging services), your current charging settings may result in the optional online services not running optimally caused by certain vehicle modes and entries you made on the HMI vehicle control panel (charging configurations). If this is the case, we will need to carry out initial changes to the charging configuration of your vehicle. At the same time, you have the option of changing the charging configuration of your vehicle at any time to fit your requirements. If you made changes that once again affect your further use of the optional online services, we will notify you of this in the app. Please note that the optional online services may then only be used to a limited extent or they may no longer be used at all.

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

c. Linking other devices (with connectivity features if applicable)

We process, for example, the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that other devices (e.g., Modbus energy meters, smart meters/intelligent metering systems, home energy management systems) are able to communicate and are up to date as part of the electrical installation and configuration process:

If you want to use optional online services, you will need to authorize your other devices and link them to your existing Elli user account by way of device-specific firmware/a device-specific web configuration. You can then access information about power generation/consumption (e.g., power consumed from solar panels/from the grid) at any time, remotely control your devices (e.g., manage access options, prioritize/deprioritize the supply of power to devices), as well as manage them (e.g., enable or disable electrical meters/measuring systems for use with the charger).

Within the scope of using optional online services, we process the following personal data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

D. Link to Power Supply Contract

If you want to use optional online services that are directly linked to a power supply contract, you will need to link your electricity supplier with your existing Elli user account in the relevant customer portal of the electricity supplier using your registration data.

Within the scope of using optional online services, we process, for example, the following personal data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

E. Contact and Customer Support

You have the possibility to contact us and send us a request. In the event that you do so, we process the information and data you provide (including personal data) in a ticket in order to contact you and process your request (Art. 6(1)(b) GDPR).

We employ the services of processors in order to process your personal data, in particular with reference to customer inquiries and support and for our CRM system. We have concluded corresponding data processing agreements with our service providers. If your data is transferred to a third country, the transfer of said data is secured by means of suitable guarantees given by third countries, such as by way of an adequacy decision or standard contractual clauses adopted by the EU Commission. We would be happy to provide you with further information on this. To do so, use the contact options listed in Section K.

In addition, you have the opportunity to provide feedback on the processing of data by us by e-mail or phone once we have completed our inquiries. If you contact us in writing, you will receive a request to complete the feedback form by e-mail; if you contact us by phone, you can leave your feedback at the end of the call.

The request to provide feedback is solicited on the basis of our legitimate interest (Art. 6(1)(f) GDPR) in improving our customer service.

We process your responses on the basis of your consent, which you give by providing feedback (Art. 6(1)(a) GDPR). We will pseudonymize and analyze your responses in order to be able to make changes to our customer service on the basis of your feedback. After this, your data will then be deleted.

We will delete your data as soon as we have responded to your request to your satisfaction, provided there are no other retention periods (e.g., retention periods under tax law) to the contrary.

F. Data Processing for Purposes of Analysis

We use cloud service providers as our processors for the following processing operations. We have concluded corresponding data processing agreements. If your personal data is transferred to a third country, the transfer of said data is secured by means of suitable guarantees given by third countries, such as by way of an adequacy decision or standard contractual clauses adopted by the EU Commission. We would be happy to provide you with further information on this at any time. To request more information, use the contact options listed in Section K.

I. Product development and business planning

Purpose of processing:

Categories of personal data for this purpose:

The data is processed under joint responsibility in cooperation with Elli Mobility GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, Germany, for the purposes of joint, cross-company product development and cross-company business planning as set out above. Elli Mobility and Volkswagen Group Charging GmbH have concluded an agreement on joint responsibility in accordance with Art. 26 GDPR.

The data is processed exclusively pseudonymously for this purpose. Pseudonymization involves the removal of all direct personal identifiers (e.g., name, e-mail address, telephone number). Indirectly traceable identifiers (pseudonyms) are retained. Data is not analyzed in the analytics systems of Elli until it has been pseudonymized. At no time is a direct reference to a specific person re-established. The results of the analysis (in particular, metrics and KPIs) are fully anonymous. The processing of pseudonymous data is necessary because there are interactions between the user account and the relevant services. In such cases, the use of the pseudonym is absolutely necessary in order to link the data from the user account and the linked services on which the analysis is based. The data processed for purposes of analysis will be deleted after thirty-six (36) months (three (3) years). This processing serves the legitimate interest of Elli to meet high customer demands in terms of the existing products and services and to be able to fulfill future requirements of our customers by means of new products and services that have yet to be developed (Art. 6(1)(f) GDPR).

II. Processing of your data for purposes of fraud prevention

Purpose of processing:

Direct and indirect personal data is analyzed in order to detect cases of fraud and abuse at an early time.

Fields containing personally identifiable information for this purpose

Fields containing personally identifiable information in the form of pseudonyms for this purpose:

The personal data that can be directly or indirectly attributed to a specific person indicated above is analyzed after registration or after concluding a subscription in order to check that the information is complete and valid. The purpose of this processing is to prevent cases of fraud and abuse.

This processing serves the legitimate interest of Elli to prevent cases of fraud and abuse that cause major financial harm resulting from the use of invalid customer data (Art. 6(1)(f) GDPR).

G. Data Processing by Service Providers

In addition to the processors and service providers described separately in the processing operations, we also use other could service providers to deliver our services. The cloud service providers we employ are:

In particular, your information from your user profile concerning your charging contracts and sessions, invoices, charger information, and billing transactions is stored in the cloud services.

You can request further information at any time using the contact details found in Section K.

H. Information on the EU Data Act

The Data Act (Regulation (EU) 2023/2854) is an EU-wide regulation that defines new rules governing access to and the use of data generated by connected products (e.g. ,chargers, vehicles) and associated services (e.g., apps). The aim of the regulation is to create a fair, transparent, and pro-innovation legal framework for the use of both personal and non-personal data within the European Union. Click the following link to learn more about the Data Act: [https://eur-lex.europa.eu/eli/reg/2023/2854/oj]

Please note that use of products of Volkswagen Group Charging GmbH (VWGC GmbH) may give rise to rights of access under the Data Act. Volkswagen Group Info Services AG ("VW GIS AG") operates a central customer portal ("EU Data Act Portal") in order for us to fulfill the requirements of the Data Act. You can use this portal to view and retrieve your data and learn about your rights in connection with the Data Act. Access to the Data Act Portal and further information can be found on our Data Act landing page by clicking the following link: [https://www.elli.eco/en/eudataact]

Please note that the provision and processing of data under the Data Act may also involve personal data. In such cases, processing is carried out in accordance with the provisions of the General Data Protection Regulation (GDPR).
VWGC GmbH is responsible for the processing of personal data in connection with the products and services concerned (Art. 4(7) GDPR). VW GIS AG serves as our processor in this context (Art. 4(8) GDPR).

We have concluded a data processing agreement with VW GIS AG in accordance with Art. 28 GDPR to ensure compliance with data protection requirements in the context of our partnership with VW GIS AG.

You can find our privacy policy concerning the Data Act by clicking the following link:

[https://eu-data-act.drivesomethinggreater.com/ie/en/service/brands-privacy-notice.html]

I. Retention Obligations

We process your personal data for as long as is necessary for the aforementioned purposes. This is required for invoicing and settlement of accounts up to three (3) months after the agreement ends. In the event that you object to processing based on our legitimate interests, we will erase your personal data unless further processing is permitted under the relevant statutory provisions. We also delete personal data if we are obliged to do so for other legal reasons. Applying these general principles, we delete personal data immediately after the legal basis ceases to apply if it is no longer required for the stated purposes or the stated purposes cease to apply and provided that no other legal basis exists (e.g., retention periods under commercial and tax law); otherwise, the data will be deleted after the other legal basis ceases to apply.

J. Your rights

You can assert the following rights vis-à-vis Volkswagen Group Charging GmbH at any time at no charge.

Right to information: You have the right to receive information from us (Art. 15 of the GDPR) regarding the processing of your personal data.

Right to rectification: You have the right to obtain from us the rectification (Art. 16 of the GDPR) of inaccurate or incomplete personal data concerning you.

Right to erasure: You have the right to obtain the erasure of your data if the conditions set out in Art. 17 of the GDPR are satisfied. You can then, for example, obtain the deletion of your data if it is no longer necessary in relation to the purposes for which it was collected. You can also obtain erasure if we process your data on the basis of your consent and you withdraw this consent.

Right to restriction of processing: You have the right to obtain the restriction of the processing of your data if the requirements of Art. 18 of the GDPR are satisfied. This would be the case, for example, if you were to contest the accuracy of your data. You can then obtain the restriction of processing for a period enabling the controller to verify the accuracy of the data.

Right to object: If the processing is based on an overriding legitimate interest, you have the right to object to the processing of your data. You also have the right to object if the processing is either in the public interest or on the basis of a legitimate interest of Volkswagen Group Charging GmbH or a third party. In the event that you object to data processing, we ask that you inform us of the reasons for your objection. You also have the right to object to data processing for direct marketing purposes. This also applies to profiling to the extent that it is related to such direct marketing.

Right to data portability: If the processing of data is based on consent or on a contract and is also carried out by automated means, you have the right to receive your data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

Right to withdraw consent: If the processing of data is based on consent, you have the right to withdraw your consent at any time at no charge with future effect.

Right to lodge a complaint: You also have the right to lodge a complaint with respect to our processing of your data with a supervisory authority (for example, the Commissioner for Data Protection and Freedom of Information of the State of Berlin).

K. Your contact persons

Who to contact to exercise your rights

If you have any questions regarding the processing of your personal data or wish to exercise your rights under data protection law, you can contact our data protection team:

info-datenschutz@elli.eco.

You can reach our data protection officer at:

PROLIANCE GmbH

www.datenschutzexperte.de
Leopoldstr. 21

80802 München

datenschutzbeauftragter@datenschutzexperte.de

When contacting the data protection officer, please specify Volkswagen Group Charging GmbH as the company to which your request refers. Please refrain from including sensitive information such as a copy of your ID with your request.