December 10, 2025

Privacy Notice – Evesta mobile app for iOS and Android (and the related services)


SpotNRG Oy ("SpotNRG") recognizes and respects your privacy. This Privacy Notice applies to the use of any product and service provided by or on behalf of SpotNRG within the Evesta platform ("Platform") and to information processed in connection with such use. However, this Privacy Notice does not apply to any third-party website or other service that may be linked to SpotNRG or that may be accessed through the Platform. Please refer to the respective privacy notices provided by these individual websites for information about the information they may collect and how that information may be used.
By downloading, installing, or making any use of any application associated with the Platform, you acknowledge and agree with the terms and conditions expressed in this Privacy Notice.
Our legal basis for processing your information is consent and the performance of our contract. We will obtain user consent for the processing of personal data where required. Where you have given consent to any data processing, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Collected Information

Personal data is in most cases collected directly from you or generated as part of the use of the Platform. We automatically collect and process data regarding the operation and performance of our products and services. To provide you with the services of the Platform ("Purpose"), we will collect and process personal data about you as follows:

1. The Platform will collect and process the following personal data:
    
    a. User Profile/Account Information such as user type, profile/account name, password, and geographical location
    
    b. User Contact Information such as first and last name and e-mail address
    
    c. Device Identification Information such as serial number, IP address, and MAC address

2. We use your information to deliver the basic functionality of the services of the Platform; carry out the contract between us; provide certain features that you choose to use; provide technical support; allow you to create, modify and view your account information; and comply with legal, regulatory and corporate governance obligations and good practice.

3. All data will be treated as confidential information and will only be used for the Purpose.

4. We may retain your personal data for as long as you hold a User Profile/Account on the Platform and for a maximum of six (6) months thereafter.

5. Your personal data will be stored by our platform in a third-party service provider location in Europe and may be accessed by SpotNRG and our platform provider on a need-to-know basis. Furthermore, your personal data may be processed by our service providers, such as the developer of the Platform in Europe. Your personal data will not be transferred outside of the EU.

6. SpotNRG complies with the Finnish Data Protection Act (1050/2018, as amended) and the European General Data Protection Regulation (EU 2016/679, "GDPR") when processing personal data. We usually act as either a controller or a joint controller (as defined in the GDPR) for your personal data.

7. To the extent you have not used the system for 24 months, SpotNRG will have right to delete your User Profile/Account.

8. You have the right to access your data and you can obtain a copy of your personal data which the Platform stores and processes about you by contacting info@evesta-home.com. Further, you may object to your personal data being processed or request a restriction of processing or that your personal data is rectified. If you wish to object to your personal data being processed or to request a restriction of processing, or to have your data rectified, please contact info@evesta-home.com with this message. You may also lodge a complaint with the supervisory authority in Finland, the Office of the Data Protection Ombudsman (tietosuoja@om.fi).

9. When you change or delete your information or account, we may maintain a copy of the original information in our records for no longer than is necessary to fulfil the purposes outlined in this Privacy Notice. Additionally, we may use any anonymized or aggregated data that is derived from your personal information after you update or delete it. Once the data is anonymized or aggregated it is not possible to identify you personally from such data.

Regulations

To the extent we are required to do so by law, we reserve the right to disclose information about you that we have collected. For example, we may be required to disclose information collected about you in response to a subpoena, court order, or other legal process, or in order to defend our rights against legal liability. We also reserve the right to disclose your personal information where it is necessary to do so in order to investigate, prevent, or take action to prohibit suspected illegal activities.

Security

We will take appropriate technical and organizational security measures, including the use of firewalls and anti-virus software, amongst others, to prevent unauthorized and unlawful processing or the loss, misuse, or alteration of your personal information. Unfortunately, such security measures cannot prevent all unauthorized and unlawful processing or loss, misuse, or alteration of your personal information. Therefore, we cannot ensure or warrant the security of any such information, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the event of a data breach, we will notify you and relevant authorities without undue delay. The notification will include the nature of the breach, the likely consequences, and the measures taken or proposed to address the breach.

Your Choices Regarding Your Personal Information

You may choose what, if any, personal information you provide to us. However, if you choose not to provide certain information your experiences with our product and services may be affected.

Changes to Our Notice

We reserve the right at our sole discretion to the extent not in conflict with applicable law to revise, supplement, replace, and/or otherwise modify the terms of this Privacy Notice and/or impose new or additional rules, policies, terms, or conditions on you from time to time and at any time without specific notice to you. Such updates, revisions, supplements, replacements, modifications, and additional rules, policies, terms, and conditions will be effective immediately upon SpotNRG posting them on its website or otherwise making them available to you (as the case may be). To assist you, an effective date is set out at the end of this Privacy Notice. Please review this Privacy Notice periodically. Your continued use of the Platform means that you accept and agree to the updated or modified terms and conditions set out in this Privacy Notice.


SpotNRG Oy
Mustionkatu 8
FI-20750 TURKU
FINLAND
E-mail: info@evesta-home.com


Effective Date: December 10, 2025.