Privacy Policy
Splash · Last updated 26 June 2026 · v2.0
1. Who we are
Splash Renewable Tech Limited ("Splash", "we", "us", "our") is the data controller for the personal data described in this policy.
- Registered company: Splash Renewable Tech Limited, company number 14350690 (England and Wales).
- Registered and contact address: 124 City Road, London, EC1V 2NX, United Kingdom.
- ICO registration number: ZC124492.
- Contact for all privacy and data requests: support@splashrenewable.co.uk, +44 204 538 7763.
We are not currently required to appoint a statutory Data Protection Officer. Our privacy contact above is responsible for data protection matters. When we begin offering the service to users in the EU or EEA, we will appoint a representative under Article 27 EU GDPR and add their details here.
2. Scope of this policy
This policy applies to everyone who uses the Platform, whether you are:
- a Host, who lists and shares an EV charger;
- a Guest, who books and uses a charger; or
- a visitor to our website, or someone who contacts us.
Where you joined Splash through a partner programme or trial, such as the Motability trial, some additional, programme-specific data handling applies (see Section 10).
3. The personal data we collect
3.1 Information you give us
- Account details: name, email address, phone number, password, profile photo (optional), and confirmation that you are aged 18 or over.
- Host charger details: charger make, model, and specifications, the location of the charger, availability and sharing schedule, and the price you set.
- Vehicle details (Guests): when you add your vehicle (the "My EV" feature), we collect its make, model, and registration number, so we can check charger compatibility and identify the vehicle for a session.
- Payment details: handled by our payment provider, Stripe (see 3.3 and Section 9). We do not store full card numbers on our own systems.
- Communications and content: messages exchanged between Hosts and Guests through the Platform, support enquiries, and the ratings, reviews, and feedback you submit.
- Partner enrolment data: the partner programme you signed up through, and any invite or reference code.
3.2 Information we collect automatically
- Location data: to show nearby chargers and operate bookings. This includes precise (GPS) location while you use the app and, where your device permission allows, location while the app runs in the background, to support session and charger features. You control this through your device settings.
- Device and technical data: device identifiers, IP address, device and operating system type, app version, and crash and diagnostic logs.
- Usage data: screens viewed, features used, bookings made, and session timings.
- Cookies and similar technologies on the website (see Section 8).
3.3 Information from third parties
- Charger and energy data through OCPP and our integration partner, Enode: when a Host connects a charger to Splash, we receive operational data such as charge status, kWh delivered, and session start and stop times. Connecting a charger passes charging control of that device to Splash, which is how OCPP works (see our Terms and Conditions).
- Stripe, our payment processor: confirmation of payments, payout status, and limited card metadata such as the last four digits and card type.
- Programme partners, such as Motability: where you join through a partner, we may receive eligibility and enrolment information from that partner.
We do not intentionally collect special category data, such as health, race, or religion, and we ask that you do not send us such information through messages or reviews. The list above reflects all the personal data we collect in normal use of the Platform.
4. How and why we use your data, and our legal bases
Under UK GDPR we must have a lawful basis for each use of your data. We rely on the bases set out below.
| What we do | Why | Lawful basis (UK GDPR Art. 6) |
|---|---|---|
| Create and manage your account, and keep accounts genuine and secure | To let you use Splash safely | Contract (Art. 6(1)(b)); Legitimate interests for fraud prevention and trust |
| Match Hosts and Guests, run bookings, and show nearby chargers (including location) | To deliver the core service you asked for | Contract (Art. 6(1)(b)); device location uses Consent through your device permission |
| Take payment, pay out Host earnings, and apply fees and kWh credits | To process transactions | Contract (Art. 6(1)(b)) |
| Receive and use charger and session data (OCPP and Enode) | To run charging sessions and bill accurately | Contract (Art. 6(1)(b)) |
| Customer support, dispute resolution, and refunds or adjustments | To handle issues fairly | Contract; Legitimate interests |
| Safety, security, fraud prevention, enforcing our Terms, and suspending or removing accounts | To protect users and the Platform | Legitimate interests (Art. 6(1)(f)); Legal obligation where applicable |
| Improve the Platform, analytics, and crash diagnostics | To make Splash better and more reliable | Legitimate interests; Consent for non-essential analytics cookies |
| Marketing emails and push notifications (newsletters, offers) | To keep you informed if you opt in | Consent (Art. 6(1)(a)) and PECR; soft opt-in for existing customers where permitted |
| Share data with a programme partner (such as Motability) | To administer your participation and report usage | Contract; Legitimate interests, under a written data-sharing agreement |
| Meet legal, tax, and accounting obligations, and respond to lawful requests | Compliance | Legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have balanced our interests against your rights, and you can object at any time (see Section 12). Where we rely on consent, you can withdraw it at any time, without affecting processing that has already taken place.
5. Information other users can see
To make peer-to-peer sharing work, some information is shared between Hosts and Guests. For example: first name and profile photo; charger location, shown to a confirmed Guest; the approximate area before booking; ratings and reviews; and in-app messages. We follow the principle of data minimisation and share only what a booking requires. Access to a charger is available only through a booking, which helps protect privacy and safety.
6. Automated decision-making
We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. If this changes, for example automated fraud scoring or pricing that significantly affects you, we will update this policy and give you the right to request human review.
7. Who we share your data with
- Other users: Hosts and Guests, as needed to complete bookings (see Section 5).
- Service providers (processors) acting on our instructions, under written contracts that meet UK GDPR Article 28:
| Provider | Purpose | Where |
|---|---|---|
| Google Cloud Platform | Hosting, database, storage | EU (europe-west) |
| Firebase (Google) | Authentication, backend, push notifications | EU and global edge |
| Stripe | Payment processing and payouts | EU and US |
| SendGrid (Twilio) | Transactional and service emails | EU and US |
| WhatsApp Business (Meta) | Customer support channel | Global |
| Sentry | Error and crash monitoring | US |
| Vercel | Website hosting | US |
| Enode | EV charger and energy integration (being onboarded) | EU |
- Programme partners, such as Motability: limited account, booking, and charging-activity data, under a written data-sharing agreement, only as needed to run the programme (see Section 10).
- Professional advisers, auditors, and insurers.
- Authorities and other parties, where required by law or regulation, to establish or defend legal claims, or to protect users.
- A successor business, if Splash is involved in a merger, acquisition, or asset sale, subject to this policy.
We do not sell your personal data.
8. Cookies and similar technologies
Our website uses cookies and similar technologies. Strictly necessary cookies are always on. Analytics and preference cookies are set only with your consent, which you give or refuse through our cookie banner on your first visit and can change at any time. This reflects the Privacy and Electronic Communications Regulations (PECR) and UK GDPR.
| Category | Purpose | Consent needed? |
|---|---|---|
| Strictly necessary | Security, load balancing, and remembering your cookie choices | No (always on) |
| Analytics and performance | Understand how the site is used so we can improve it | Yes |
| Preferences and functional | Remember your settings and choices | Yes |
We do not use third-party advertising or cross-site tracking cookies. You can also manage cookies through your browser settings.
9. Payments and VAT
Payments are handled by Stripe, a regulated third-party payment processor, under its own terms and privacy policy. We receive confirmation and limited metadata, not full card details. Host payouts are paid to the Host's nominated bank account through Stripe. Splash is not itself a payment institution.
Splash is VAT-registered. We charge VAT at the standard rate (currently 20%) on our own platform and service fees, and the prices shown to you include any VAT due. We do not add VAT to the Host's energy charge, which is a supply between the Host and the Guest. Our Terms and Conditions set out the full fee and VAT breakdown.
10. Partner programmes and trials
If you join Splash through a partner programme or trial:
- we share limited account, booking, and charging-activity data with that partner, so it can verify eligibility, administer your participation, and report on usage;
- the categories shared and the purpose are governed by a written data-sharing agreement between Splash and the partner;
- a separate, programme-specific trial privacy notice may also apply, and will be provided to you at sign-up; and
- both Splash and the partner are responsible for the data each controls.
11. How long we keep your data
We keep personal data only as long as necessary for the purposes above, and then delete or anonymise it.
| Data | Retention |
|---|---|
| Account and vehicle data | While your account is active, then deleted or anonymised within 12 months of closure |
| Booking and charging session records | 6 years (tax and accounting, and dispute resolution) |
| Payment and transaction records | 6 years (UK tax law) |
| Support communications | 24 months |
| Marketing consents and preferences | Until you withdraw consent, plus a record of the withdrawal |
| Cookies | From the length of a session up to 24 months, depending on the cookie |
12. Your rights under UK GDPR
You have the right to access your data; to rectify inaccurate data; to request erasure; to restrict processing; to data portability; to object to processing based on legitimate interests, and to object to direct marketing; to withdraw consent at any time; and not to be subject to solely automated decisions that have significant effects.
To exercise any right, contact support@splashrenewable.co.uk. We respond within one month, which may be extended by two months for complex requests. There is normally no charge.
If you have a concern, you can complain to the UK Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve it first.
13. International data transfers
We aim to store data in the UK and EEA. Some of our processors, such as Stripe, SendGrid, WhatsApp (Meta), Vercel, Sentry, and Google, process data outside the UK. Where they do, we rely on appropriate safeguards: UK adequacy regulations, the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses.
14. Security
We use appropriate technical and organisational measures to protect your data, including encryption in transit, access controls on a least-privilege basis, and secure, resilient infrastructure. No system is completely secure. We maintain a process to detect personal data breaches and, where legally required, to report them to the ICO within 72 hours and to the individuals affected.
15. Children
The Platform is for adults aged 18 and over. We do not knowingly collect data from children. If you believe a child has provided us with data, please contact us and we will delete it.
16. Third-party links and charger manufacturers
The Platform may link to third-party sites and apps, such as charger manufacturer apps and energy providers. Their privacy practices are their own, and we recommend you read their policies.
17. Changes to this policy
We may update this policy. We will notify you of material changes through the Platform or by email, and the "last updated" date will change. Continued use after a change takes effect means you accept the updated policy.
18. Contact us
- Privacy, your rights, and general enquiries: support@splashrenewable.co.uk, +44 204 538 7763.
- Post: Splash Renewable Tech Limited, 124 City Road, London, EC1V 2NX, United Kingdom.