Below we provide information about the processing of personal data when using the SWIO Charge App, which is available in the App Store and Google Play Store.

1. Data Controller

The controller responsible for processing your personal data is:

SWIO Energy Solutions S.à r.l. 
40, Allée Louis Ackermann 
L-1897 Kockelscheuer

2. What data is processed?

When using the app, the following personal data is processed:

Master data (surname, first name, address)

Contact data (email address, telephone number)

Payment data (for the execution and billing of charging sessions)

Location data

GPS position, provided that you enable location services on your device

Approximate location derived from your IP address (if GPS is not enabled)

Technical identifiers (device IDs, IP addresses)

Diagnostic and usage data (logs, error and performance data, app usage information to ensure and improve functionality)

3. Why is this data processed?

We process your personal data to the extent necessary to provide the agreed services. Data processing is therefore carried out for the performance of the contract concluded with you and on the basis of Article 6(1)(b) GDPR. Failure to provide this data may result in you being unable to use our service and, where applicable, the contract being unable to be fulfilled.

The use of the app may include the following purposes:

Charging sessions and billing: Data processing for the execution and billing of charging sessions for electric vehicles.

Support and hotline: Processing of your contact details to provide support and hotline services and, where applicable, repair services.

Where required by law, we process your data to comply with legal obligations pursuant to Article 6(1)(c) GDPR. This includes, for example, the retention of invoice data for tax and accounting purposes.

Furthermore, we process certain data on the basis of legitimate interests (Article 6(1)(f) GDPR) in order to further develop the app technically and functionally and to ensure secure operation. This includes, in particular, the following purposes:

System stability and forecasting: Collection of data to ensure system stability and to analyse consumption and utilisation profiles.

Access logging: Collection of log data to track access to systems (including via the administration interface).

App optimisation: Processing of usage data to ensure uninterrupted operation and to improve app functionality.

4. Who receives your data?

Your personal data is only shared with service providers that are necessary for the provision of our services, for example for billing, support or technical maintenance. These service providers act on our behalf and are subject to strict data protection requirements.

Payment data is transmitted directly to the payment service provider selected by you. Information about the processing of data by that provider can be obtained directly from the respective service provider.

5. Data processing in third countries

Your personal data is generally processed within the European Union (EU) or the European Economic Area (EEA). Should personal data exceptionally be transferred to recipients in countries outside the EU or EEA, such transfers will only take place where a legal basis pursuant to Articles 44 et seq. GDPR exists, in particular on the basis of an adequacy decision of the European Commission, appropriate safeguards pursuant to Article 46 GDPR (e.g. through the conclusion of Standard Contractual Clauses), or your explicit consent to such transfer pursuant to Article 49(1)(a) GDPR.

6. Data Subject Rights

You have the following rights regarding your personal data:

Right of access: 
You may obtain information about the personal data we store about you.

Right to rectification and erasure: 
You may request the correction of inaccurate data and, where the legal requirements are met, the deletion of your data.

Restriction of processing: 
You may request that we restrict the processing of your data where the legal requirements are met.

Data portability: 
If you have provided data to us on the basis of a contract or your consent, you may request that it be transferred in a commonly used format or transmitted to another controller, provided that the legal requirements are met.

Right to object to processing: 
You have the right to object to processing based on legitimate interests on grounds relating to your particular situation. If you object, we will continue processing your data only where compelling legitimate grounds exist.

Right to object to direct marketing: 
Where we process your personal data for direct marketing purposes, you have the right to object at any time to such processing. If you exercise this right, we will stop processing your data for that purpose.

Withdrawal of consent: 
Where you have given consent to the processing of your personal data, you may withdraw that consent at any time with effect for the future. The lawfulness of processing carried out prior to withdrawal remains unaffected.

Right to lodge a complaint with a supervisory authority: 
You may also lodge a complaint with the competent supervisory authority if you believe that the processing of your data violates applicable law. You may contact the supervisory authority responsible for your place of residence or country, or the supervisory authority responsible for us.

Contact us and exercising your rights: 
If you have any questions regarding the processing of your personal data or your data subject rights, you may contact us free of charge at any time. You can contact us via info@swio.lu or by post at the address listed above. Please ensure that we are able to clearly identify you. If you withdraw your consent, you may alternatively use the same communication channel that you used when providing your consent.

7. Version

The current version of the SWIO Charge App Privacy Notice shall apply.

Version: 01.07.2026

We reserve the right to amend or modify this Privacy Notice in order to reflect changes in legislation, developments in case law, or economic and technical changes. However, such amendments will not affect the essential provisions of the service.