PRIVACY POLICY

Data Policy Puma Social LTD

Effective Date: This policy last updated on 10^th February 2026.

DEFINITIONS

“the Company” means Puma Social LTD, Unit 3B Clane Business Park, Kilcock Rd, Clane, Co. Kildare, a company registered in Ireland under company number 525279

“the Site” means evhacs.com and carandus.com and pay.evhacs.com and the App

“the App” means the application made available publicly via an online store which better enhances use of the suite of products sold by the Company

“You” means you as the user of the Site

1. Acceptance of terms by You

Puma Social LTD strives to always protect your privacy. This document sets out our current privacy practices with regard to any information the Company collects when You or your computer joins the Site. By joining the Site, you acknowledge and fully understand this document and freely consent to the information collection and use practices described in it.

2. Who are we?

We are Puma Social LTD, trading as Evhacs.com, and Carandus.com, providing innovative, first class, technology solutions.

3. Do we collect your information and how do we use it?

By using the Site you do not have to register any of your Personal Information with us, in other words, we do not request your name, address, email or any other Personal Information as an obligatory requirement to use of the website. For the purposes of using pay.evhacs.com you may wish to enter your email address if you wish to be provided with a receipt for services. However this is not an obligatory requirement. For use of the App you will be required to enter a username and password when you first sign up to use the App. Upon registering you will be required to enter a model number and serial number of the relevant EVHACS product and your first name is used to identify you as the user each time you login. This is so as to help differentiate different users of the same EVHACS product. If you wish to receive further information from us, including marketing information, or, in order to keep up to date with our innovative technological solutions, you may choose to enter your Personal Information, where requested, so that we can send to you information in the future. This data, should you choose to enter it, will be processed by FluentCRM. We use FluentCRMas our data processor for the collection (e.g., via sign-up forms) and storage of your personal information (your name and email address) and the transfer of your Personal Information (your name and email address) to certain of FluentCRM’s sub-processors who perform some critical services, such as helping FluentCRM prevent abuse and providing support to their customers.

Other Personal Information we might collect includes your IP address.

In the case of Carandus.com, in order to have a Social Profile, you may choose to enter personal details, such as your profile name, or handle, and other details that you voluntarily enter, both on your social profile, and in messaging on the website. Important Warning: You should be aware that this information, when entered, is potentially publicly accessible. In no circumstances does Puma Social LTD advise you to enter personal details such as your real name, address, contact telephone number, employment, or, medical information, or card payment details, or bank information, as such may become publicly available. You are strongly advised to refrain from entering any such type of information on the Site. For the avoidance of doubt, Puma Social LTD accepts no liability whatsoever for any harm or loss of whatever kind incurred by You or any other party as a result of information You have posted on the Site. For more information on this You are referred to the section entitled Disclaimer of Warranties and Limitation of Liability on the Terms and Conditions page of the Site.

4. Use of Cookies

The Company may use cookies to personalize or enhance your user experience. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web Server in the domain that issued the cookie to you. Essential cookies are necessary for the basic functionality of the Site (such as session management and security) and cannot be disabled without affecting your ability to use the Site. Non-essential cookies (such as analytics and advertising cookies) are used to enhance your experience and may be declined without affecting core functionality.

One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Hence, this simplifies the process of delivering relevant content and eases site navigation by providing and saving your preferences and login information as well as providing personalized functionality.

The Company reserves the right to share aggregated site statistics with partner companies, but does not allow other companies to place cookies on our website unless there is a temporary, overriding customer value (such as merging into the Site another site that relies on third-party cookies).

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you reject cookies by changing your browser settings then be aware that this may disable some of the functionality on the Site.

The Site may, from time to time, use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies. For more information on how Google uses your data and how you can opt-out of Google Analytics please visit the following page from Google. Generally speaking we use Google to show us how visitors found and explored our site and how we can improve their experience, to provide us with information on visitor site behaviour, e.g. duration and average number of pages viewed, and how many visitors have visited the Site.

The Site also may use, from time to time, the Facebook Pixel. This is a tracking cookie which monitors your behaviour on the Site to allow for personalised advertising content on Facebook and Instagram platforms. To opt out of Facebook showing you targeted ads, open your Facebook page and click “settings,” and then “ads.” Then click on the “ads based on my use of websites and apps” setting and press the “choose setting” button and select “off”.

The Site may contain electronic images known as Web beacons – sometimes also called single-pixel gifs – that allow the Company to count users who have visited those pages and to deliver co-branded services.

By using the Site you consent to the use of cookies in accordance with this statement. You may wish to accept/refuse/delete cookies in your browser. The most popular browsers are Google Chrome, Opera, Safari, Firefox and Internet Explorer. Please review the links below which you may find helpful if you wish to manage the cookies directly in your browser:

• Google Chrome
• Opera
• Safari
• Mozilla Firefox
• Internet Explorer

Please be aware that if you block/disable cookies in your browser, you may see diminished function of our Site.

5. How We Use your information

We may use your personal information to: provide assistance and information to you for example to provide customer service or online technical support and troubleshooting in instances where critical information provided to you has changed; perform a contract between the Company and you; contact you to double-check information you have entered on the Site including Personal information; seek your views or comments on the services we provide; send to you service messages from time to time; send you communications which you have requested and which may be of interest to you; we may also use your Personal Information to assist with requests made to us from time to time by Law Enforcement Authorities (i.e. An Garda Síochána) who may require the information to assist them with matters of law enforcement where the processing is necessary for the performance of a task carried out in the public interest.

Your Personal Information may be processed, recorded and retained by us in electronic form. You agree, pursuant to the Electronic Commerce Act 2000, that the Company may communicate with you electronically in relation to the services you have purchased, and that it may rely on such electronic communications,  in any dealing with you.

In respect of the App you may be asked to consent to sharing your energy data with us or our energy partner, if relevant to your specific dwelling, Glenveigh Homes Block C, Maynooth Business Campus, Straffan Road, Maynooth, Co. Kildare, Ireland. The legal basis for this processing is your explicit consent under Article 6(1)(a) of the GDPR. This is for the purpose of understanding the energy usage in your premises and using that data to help gain better value and usage of your energy and potentially allow future flexible tariff models and for any related purpose. You will always be required to positively consent to this monitoring via an in-App consent mechanism before any energy data is shared with our energy partner, and you can withdraw your consent for this use at any time by contacting us at info@evhacs.com. Withdrawal of your consent for energy monitoring will result in your energy data becoming anonymized and the energy performance of your specific premises will no longer be identifiable. We may continue to use the anonymized data to gain a better understanding of energy usage across a wider dataset – for example while measuring energy usage across Ireland as a whole. Consequently this anonymized residual use of energy data falls under the statistical exemption in the GDPR.

6. Who has access to your information?

We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:

• To fulfill your service requests for services.
• To protect ourselves from liability,
• To respond to legal process or comply with law, or
• In connection with a merger, acquisition, or liquidation of the Company

For the avoidance of doubt we reiterate that should you choose to enter Personal Information into the site, for the purpose of fulfilling your marketing request of us, you are consenting to the data being processed by FluentCRM who operate as the processor of your Personal Information for the purposes of marketing the products and services of the Company. We are satisfied that FluentCRM operates to the highest standards with respect to data security and integrity of your data. To reiterate, we use FluentCRM as our data processor for the collection (e.g., via sign-up forms) and storage of your personal information (your name and email address) and the transfer of your personal information (your name and email address) to certain of FluentCRM’s sub-processors who perform some critical services, such as helping FluentCRM prevent abuse and providing support to their customers. Where FluentCRM’s sub-processors are located outside the EEA, appropriate safeguards such as Standard Contractual Clauses are in place to ensure your data remains protected in accordance with GDPR requirements.

7. How long do we retain your information? 

We retain your personal information on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise in respect of the services.

8. Payment Processing

We do process payments on pay.evhacs.com and so we will request payment details for the purposes of your request to avail of any services we provide via that portal. Payment details are stored end-to-end encrypted and are secure. (See section below). 

9. How we Protect your Data

The Company takes great measures to protect your personal data. The Company operates from an environment that is physically secure and limited to personnel on a strictly “need-to-access” basis. The Company never stores complete financial details such as your bank card number. Where partial payment details are stored (e.g. for the purposes delivering refunds) they are always end-to-end encrypted. All Personal data transmitted to and from this environment is delivered over encrypted channels. Firewalls protect this environment from any unauthorised access and our systems are permanently monitored for any kind of attempted data breach by nefarious actors.

1. Web Server Logs

When you visit the Site, the Company may track information to administer the site and analyse its usage. Examples of information we may track include:

• Your Internet protocol address.
• The kind of browser or computer you use.
• Number of links you click within the Site.
• The location from which you accessed the Site.
• Date and time of your visit.
• Name of your Internet service provider.
• Web page you linked to the Site from.
• Pages you viewed on the Site.

10. Right of Access and Correction

In accordance with the Data Protection Acts 1988 to 2018 (“DPA”) and the General Data Protection Regulation (“GDPR”) you have the right, subject to certain exemptions and conditions, to receive a copy of all your personal information held by the Company and to have any inaccuracies in your personal information corrected, your data removed, or object to processing of your personal information. You also may have a right to have your personal information provided to you in a structured, commonly used and machine-readable format (“data portability”) and a right to transmit that information to another data controller where this is technically feasible.

Personal information primarily relates to the following categories of information: your name, and/or your email. If you would like a copy of the personal information to which you are entitled which is held by us, a written request is required (See Making a Request below). You may be required to provide us with sufficient information in order that we can verify your identity and locate your information. If you inform us of any inaccuracy in your personal information, we will promptly correct the inaccuracy upon verification.

Making a Request

Under the Data Protection Acts and/or the General Data Protection Regulation you may receive a copy of your personal information held by Puma Social Ltd on request.

In order to respond to your request we require you to:

1. Make a request in writing by emailing gdpr@evhacs.comor writing a letter to Puma Social Ltd, Unit 3B, Clane Business Park, Kilcock Road, Clane, Co. Kildare. The Data Protection Commission suggests a standard email request might appear like this:

Dear…

I wish to make an access request under Article 15 of the General Data Protection Regulation (GDPR) for a copy of any information you keep about me, on computer or in manual form in relation to…

2. You should be as specific as possible about the information you wish to access;
3. You may be asked to provide further clarifying information if necessary on the exact scope of the data requested if the request is extremely broad;
4. You may also be required to provide evidence of proof of identity where it is deemed necessary and there is a risk of disclosure of personal data to a third party.

Please note the following important requirement:

We reserve the right not to process an access request where a request is manifestly unfounded or excessive.

Responding to your Access Request

Once we have received your fully completed request we have one month to fulfil the request although we aim to do so without undue delay.

If you are not satisfied with the outcome of your access request you are entitled to make a complaint to the Data Protection Commissioner who may investigate the matter for you. The Data Protection Commissioner’s website contains useful information on access requests and other data protection issues at www.dataprotection.ie; webform: https://forms.dataprotection.ie/ contact telephone: +353 578 684 800 and +353 761 104 800

11. Participating Merchant Policies

Related services and offerings with links from this website, including third party sites, have their own privacy statements that can be viewed by clicking on the corresponding links within each respective website. Online merchants and others who participate in the Company’s services are encouraged to participate in industry privacy initiatives and to take a responsible attitude towards consumer privacy. However, since we do not have direct control over the policies or practices of participating merchants and other third parties, we are not responsible for the privacy practices or contents of those sites. We recommend and encourage that you always review the privacy policies of merchants and other third parties before you provide any personal information or complete any transaction with such parties.

12. Changes to this Statement

The Company has the discretion to occasionally update this document. When we do, we will also revise the “updated” date at the top of this Privacy page. We encourage you to periodically review this document to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy statement and any updates.

13. Contacting Us

If you have questions regarding our Privacy Statement, its implementation, failure to adhere to this Privacy Statement and/or our general practices, please contact us info@evhacs.com.