Shell Recharge : Privacy Notice

What does this Privacy Notice cover?

This Privacy Notice provides you with information on the processing of your personal data when visiting the Shell Recharge website, using the Shell Recharge Asia App and/or using EV services and/or purchasing EV products in Malaysia, from Shell Malaysia Trading Sdn Bhd (hereafter “Shell”) and Zeco Systems Pte. Ltd Inc., its subsidiaries and affiliates (hereafter “Shell Recharge Solutions”) which market and trade under the Shell Recharge brand in various countries. Please note that when using Shell Recharge products and services you are entering into a relationship with Shell Malaysia Trading Sdn. Bhd., Shell Singapore Pte Ltd. and Shell Recharge Solutions, which are members of the Shell Group of companies.

This Privacy Notice explains what personal data are processed about you; why we are processing your personal data and for which purposes; for how long we hold your personal data for; how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

Special Notice – if you are under 18 years old. Processing children’s personal data

If personal data of children is gathered this requires consent of the parent or guardian.

We do not intentionally collect personal data of individuals of those who are under 18 years old. Except in those cases where we organise educational events specifically designed for those under 18 years old or in Government Related Programmes where children of 16 or older are lawfully eligible or able to participate. If you are under 18 years old (or a different age to reflect local legal requirement for minors) please do not send us your personal data.

Given that our products and services relate to driving, we assume you are over 18 years old. If you wish to contact us in a way which requires you to submit your personal data (such as for educational or innovation events) please appoint your parent or guardian to act for you, to consent on your behalf to the processing (including disclosure and transfer) of your personal data in accordance with this Privacy Notice.

What personal data do we process about you? The categories of personal data we process.

We collect personal data about you, as a Shell Recharge customer, user of our app and/or visitor to our website and social media pages. Please find the type of interaction you have with use to learn more about what personal data we process. For your convenience we have divided the interactions across 3 types: Charge Point users, website and app users and direct interactions.

1. Charge point users:

• Charging via the Shell Recharge Asia App: before you can start using a charge point via the Shell Recharge Asia App, we request you to register on the Shell Recharge Asia App. We will collect your name, email address, phone number and payment method details.
• Ad hoc charging as Guest User: when you scan a QR code displayed on a charge point to enable you to access ad hoc charging, two options will be presented to you. The first option allows you to charge your vehicle with direct payment, in which case we only request you to provide us with (i) your email address for purposes of sending a receipt for the charge session (if you wish to receive a receipt for the charging session ); however, your email address will not be stored in our customer database; and (ii) your credit card details, of which we will only store the last four digits of your credit card number, the expiry date of the credit card, and the security code. Please note that a 3rd party payment provider will process your payment. The second option is to download an app and create an account. The data collected will be the same as mentioned at Registration and all personal data is securely stored in an encrypted manner.

2. Website/App Users:

• General: if you use our applications for mobile devices, we may, with your consent, collect your location data to enable features such as navigation, receiving charging notifications or enabling you to notify us about faults. Besides this your mobile device will automatically share certain data with us because the device interacts with the app. When you use the app, you create an account for which we collect the data specified under “charge point user”.
• Exchanges by device: when you visit our websites, data is automatically collected by the technology platforms providing the experience. For example, your web browser or mobile device may share certain data with us because those devices interact with our website. This data includes device ID, network access, storage information and battery information, cookies, IP-addresses, referrer headers, data identifying your web browser and version and web beacons and tags.
• Other applications: We are continuously striving to offer the best and smartest charging solutions. To avoid an ongoing update of this privacy policy we also use application specific privacy policies. You will be informed on these privacy policies before said applications collect your personal data. As mentioned in the application specific privacy policies this privacy policy will form an integral part of the application specific privacy policies.

3. Direct Interactions:

• Newsletter and publications: if subscribed, we will collect your name and contact information and you can unsubscribe at any time.
• Communications concerning our own products or services: we may send communications concerning our own products and services to our customers. You can unsubscribe from such communications at any time.
• Campaign or competition: if you choose to participate in a campaign or competition, we ask for the necessary personal data required. This is to ensure we can operate it, announce winner(s) and to gauge the response to any marketing and to provide you with ongoing marketing offers if you have agreed to receive these as part of your participation.
• Surveys: if you participate in our surveys, we will collect your personal data as part of customer satisfaction research related to the products and services offered to you.
• Other: if you contact us by phone or email, we will collect the data you provide to us.

Shell’s view of the customer

With the aim of ensuring you have a seamless experience with the Shell Group of companies, and depending upon the nature of your engagement with us, we may combine information gathered from the sources referred to above to create a personal profile of you. This enables you to interact with different Shell companies more easily and ensures we have the most up to date information about you in order to better develop services and products and to tailor offers relevant to your specific interests.

Please note however, you have the ability to control how Shell uses this information. You can opt out of having your personal data combined in this way.

Why do we process your personal data?

The personal data covered by this Privacy Notice are only processed:

• with your explicit consent;
• where it is necessary to conclude a transaction with you (such as payment information);
• where it is necessary for the purposes of the legitimate interests pursued by the relevant Shell company/companies, except where such interests are overridden by your interests or fundamental rights and freedoms; or
• where it is necessary for Shell to comply with a legal obligation.

Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

What are the consequences of not providing your personal data?

Where you choose not to provide us with information set out above for the purposes of using the Shell Recharge Asia App or providing EV related services or interacting with Shell Recharge, it will affect our ability to communicate with you or provide services to you and/or affect your ability to fully interact with the Shell Recharge Asia App.

Who is responsible for any personal data collected in Malaysia?

Shell Malaysia Trading Sdn Bhd
Menara Shell, 211 Jalan Tun, Sambanthan
50470 Kuala Lumpur, Malaysia

For EV charging session data:

Zeco Systems Pte. Ltd.
9 North Buona Vista Drive
The Metropolis Tower 1, #02-01
Singapore 138588
support.asia@shellrecharge.com

For what purposes do we process your personal data?

We process your personal data for the purposes of:

• providing our products and delivering our services to you;
• managing your account, relationships and marketing such as maintaining and promoting contact with you;
• payment processing and financial account management;
• account management including account verification (that is, ensuring that only you or someone you have authorised can access your account and information);
• customer service and development of our products and services;
• performance of and analysis of market surveys and marketing strategies;
• promotions and contests offered to our customers, including offering you digital rewards to recognise you as a valued customer; or
• detecting or preventing fraud if you use a mobile payment function to purchase our products and services (if available in your market).

We will only process your personal data where we have a lawful basis to do so:

• only the personal data included in this privacy notice is processed;
• in order to take steps at the request of an individual prior to entering a contract;
• where it is necessary to comply with a legal or regulatory obligation to which we are subject to;
• where it is necessary for the purposes of the legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual/s;
• (only if legally required) with the explicit consent of the individual;
• in those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent;

OR for a secondary purpose where it is closely related, such as:

• storing, deleting or anonymising your personal data;
• audits, investigations, dispute resolution or insurance purposes, litigation or defence of claims;
• statistical, historical or scientific research; or
• legal and/or regulatory compliance

Screening

In addition, in order to comply with legal and regulatory obligations, to protect our assets and employees/contractors and specifically to ensure that we can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business customers, Suppliers and Business Partners.

This screening takes place against publicly available or government issued sanctions lists and media sources. The screening does not involve profiling or automated decision making in relation to the counterparties or potential counterparties.

Communication and marketing – your choices

If you have consented to receive communications from us (or if you have previously purchased goods/and or services from us), you may receive offers that are tailored towards your preferences based on the information gathered about you from the various sources described above in order to provide you with better products and increasingly tailored services.

We may send you service updates and notifications without your advance consent only where such updates and/or notifications are necessary for the proper functioning of the Shell Recharge Asia App or other services that you use.

You may receive pertinent offers and communications by different channels and you may update your subscription preferences via your personal profile settings anytime or use the unsubscribe functionality for the different digital channels.

Transaction security and preventing, detecting and investigating fraud

When you use a mobile payment application to purchase our products and/or services (if available in your market), you may be asked to provide additional personal details to complete the transaction. We may use the personal data you provide to prevent, detect and investigate fraud and to enforce the terms and conditions of the mobile payment application.

We may share some information with the service providers involved in mobile payments, including but not limited to your IP address, device ID or unique identifier, loyalty card number for the purposes detailed above as well as for the purposes of collecting points, device type, geo-location information, connection information (for e.g. wi-fi) and mobile network information.

Your rights in relation to your personal data

We aim to keep our information as accurate as possible. You can request:

• access to your personal data;
• correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction);
• that you no longer receive marketing communications;
• that the processing of your personal data is restricted;
• combining of your personal data from different sources to create a personal profile no longer takes place; and/or
• that you receive personal data that you have provided to us, in a structured, digital form to be transmitted to another party, if this is technically feasible.

To make any of these requests please go to your account profile or please contact us at

support.asia@shellrecharge.com

Who can you contact if you have a query, concern or complaint about your personal data?

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us at: support.asia@shellrecharge.com

You may also contact our Shell Malaysia Data Protection Officer at Shell Business Operations Sdn. Bhd., Wisma Shell 3450, Jalan Teknokrat 3, 63000, Cyberjaya, Selangor at MALAYTR-Data-Privacy-Office@shell.com

For Shell Group Chief Privacy Office

You may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands – Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, at privacy-office-SI@shell.com.

If you are unsatisfied with the handling of your personal data by us, then you have the right to lodge a complaint to the Personal Data Protection Commissioner Malaysia, Level 6, Kompleks Kementerian Komunikasi dan Multimedia, Lot 4G9, Persiaran Perdana, Presint 4 Pusat Pentadbiran Kerajaan Persekutuan, 62100 Putrajaya, Malaysia or the Dutch Data Protection Authority whose address is Autoriteit Persoonsgegevens PO Box 93374 2509 AJ The Hague, The Netherlands. Please visit https://www.pdp.gov.my/jpdpv2/hubungi-kami/maklumat-umum/lokasi/ or https://autoriteitpersoonsgegevens.nl/en for more information.

Cookies and similar technologies

Shell and Shell Recharge Solutions uses cookies and similar technologies that collect and store information when you visit a Shell or Shell Recharge Website or use the Shell Recharge Asia App. This is to enable us to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the Shell cookies preference tool on Shell Websites – for more information, please refer to the Shell Cookie Policy at https://www.shell.com.my/cookie-policy.html or the Shell Recharge’s Cookie Policy at https://shellrecharge.com/en-us/solutions/cookie-policy.

Security of your personal data

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification process for access to our services and we regularly test, assess and evaluate the effectiveness of our security measures.

When you enter your credit card details, please be informed that a 3rd party payment provider will process your payment. We will only store the last four digits of your credit card number, the expiry data and the security code.

Who will we share your personal data with?

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

• Other companies within our group of companies, including to those which may be located outside of your location;
• With your consent, authorised third party companies in co-operation with Shell that may supply products and/or services to you as our customer;
• Our authorised service providers involved in mobile payments;
• Our authorised agents, licensees, service providers, external auditors and/or subcontractors of Shell;
• A competent public authority, government, regulatory, supervisory, investigative or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Shell company/companies is subject to or as permitted by applicable law; or
• Any person to whom Shell proposes to transfer any of its rights and/or duties.

Transfers of your personal data to other countries

Personal data collected from residents in Malaysia will be stored in servers based in Singapore and India.

Notwithstanding the above, your personal data may be transferred to countries with servers located outside of Singapore or India. Where your personal data has been transferred to companies within the Shell group and/or to authorised third parties located outside of your country we take organisational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules (BCR) for transfers among the Shell group and for Shell companies in the European Union (provided that such Shell entities or companies are BCR signed off), European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at https://www.shell.com.my/privacy.html or by contacting privacy-office-SI@shell.com

How long do we hold your personal data for?

Personal data processed by us in line with this Privacy Notice will be deleted or rendered anonymous (such that it will no longer be possible to identify you);

1. every five (5) years where you remain a customer during this period;
2. without undue delay upon you requesting that your account profile is deleted or to discontinue your participation as a customer in any of our or our group’s loyalty programmes; or
3. after (3) years for all subscribed services from our last interaction with you (that is where you have not used our services for 3 years).

In relation to financial transactions (including those made through the Shell Recharge Asia App), your personal data will be held for 10 years from the transaction.

In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.

Changes to this Privacy Notice

This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes.

This Privacy Notice is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between this English version and the corresponding Bahasa Malaysia version of this Privacy Notice, the English version shall prevail.

This Privacy Notice was last updated on 25 September 2025.