Legal

Privacy Policy

Last updated: 3 September 2026

This Privacy Policy explains how LLM Family Investments Pty Ltd (ACN 610 504 482) as trustee for the LLM Family Trust (ABN 27 213 698 865), trading as Guest Charge (“Guest Charge”, “we”, “us”, “our”) collects, uses, discloses and protects personal information when you use the Guest Charge platform, websites and related services (the “Service”). Guest Charge is an EV-charging management platform used by accommodation hosts (hotels and short-stay/Airbnb hosts) to let their guests charge electric vehicles.

We are based in Australia and our systems are hosted in Australia. We handle personal information in accordance with the Australian Privacy Act 1988 (Cth) and, where they apply, the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable privacy laws.

1. Who this policy covers

This policy applies to two groups:

• Hosts — the individuals or businesses who create a Guest Charge account to register and manage chargers.
• Guests — people who charge a vehicle at a host’s location. Guests usually do not create an account; they access charging through a personal link or a QR code provided by their host.

2. Information we collect

2.1 Information hosts provide

• Account and contact details: name, email address, phone number, company name and business address.
• Login credentials: a password (stored only as a secure one-way hash) and, if you enable two-factor authentication, an encrypted authentication secret and recovery codes.
• Property and charger details: property names and addresses, geographic coordinates, time zone, property type, check-in/out times, and any notes or guest instructions you enter.
• Billing and payout details: your Stripe customer, subscription and Connect account identifiers, and payout settings. Payment card and bank details are handled by Stripe, not stored by us (see section 6).
• Preferences: notification and email preferences, reporting settings (such as your electricity rate and financial-year setting).

2.2 Information about guests

• Contact details you or your host provide: guest name, and (optionally) email address and/or mobile number used to send charge summaries and receipts. A guest can choose whether summaries are sent by email or SMS.
• Charging data: energy delivered, meter readings, charging start/stop times and per-charge history for each session.
• Payment data: where a host requires payment, the billing details and payment identifiers created by Stripe for that session (card details themselves are held by Stripe, not us).
• Guests imported automatically from a host’s connected Airbnb/iCal calendar are created as anonymous placeholders (for example, “Airbnb guest #3”) and contain no personal information unless the host adds it.

2.3 Information we collect automatically

• Security and device information: IP address, browser type and device information recorded when you sign in or perform sensitive actions, and for active login sessions.
• Service logs: technical logs of requests and system events, used to operate, secure and troubleshoot the Service.
• Local storage and one functional cookie — see section 5.

3. How we use information

• To provide and operate the Service — creating accounts, managing chargers and locations, running charging sessions and calculating energy use.
• To process payments, calculate fees and tax, issue receipts and statements, and make payouts to hosts.
• To send transactional communications — email address verification, password resets, security alerts, charger online/offline alerts, charge summaries, receipts and host statements.
• To provide customer support and respond to support tickets.
• To keep the Service secure — authentication, fraud prevention, rate limiting and audit logging of administrative actions.
• To comply with our legal obligations and to establish, exercise or defend legal claims.
• With your consent, to send marketing communications (you can opt out at any time). We do not currently send marketing email, but may in future if you have opted in.

3.1 Legal bases (for EU/UK users)

Where the GDPR or UK GDPR applies, we rely on: performance of a contract (to provide the Service and process charging and payments); legitimate interests (to secure the Service, prevent fraud, and communicate about your account); consent (for non-essential cookies and any marketing); and legal obligation (for tax, accounting and compliance records).

4. When we share information

We share personal information only with the service providers needed to run the Service, and only as needed. Our key sub-processors are:

We also import calendar data from your connected Airbnb/iCal feeds where you enable that feature (information flows to us, not from us).

We may also disclose information: to professional advisers; to comply with law, legal process or a lawful request; to protect the rights, property or safety of Guest Charge, our users or others; and in connection with a business sale, merger or restructure (subject to this policy).

5. Cookies and local storage

Our application does not use advertising or analytics cookies. We use:

• One functional cookie (“gc_auth”) — a simple flag that records whether you are signed in, so our website can show the right navigation. It contains no login token and no personal information.
• Browser local/session storage — strictly necessary items to keep you signed in and remember interface preferences (such as map view settings and onboarding progress). These stay on your device.
• Google Maps may set its own cookies or storage when maps or address lookup are shown on host-facing pages, under Google’s own policies.

Our public marketing website (guest-charge.com) presents a cookie notice on your first visit where required, so that you can accept or decline non-essential cookies. You can also control cookies through your browser settings; blocking strictly necessary items may stop parts of the Service working.

6. Payments

Payments are processed by Stripe. When a guest pays or saves a card, the card details are collected and stored by Stripe under Stripe’s own security and privacy terms — full card numbers never reach Guest Charge’s servers. We store only the identifiers Stripe returns (for example, a customer or payment reference) and the amount, currency and tax for the charge. Guests are charged in the host’s currency; any currency conversion is performed by the guest’s own bank. See Stripe’s Privacy Policy.

7. International data transfers

We store and process personal information in Australia. If you access the Service from the EU, the UK or elsewhere, your information will be transferred to and handled in Australia and by the sub-processors listed above (which may process data in other countries). Where required, we put appropriate safeguards in place for these transfers, such as standard contractual clauses. By using the Service you understand that your information will be handled as described here.

8. How long we keep information

We keep personal information for as long as needed to provide the Service, to meet legal, tax and accounting obligations, and to resolve disputes and enforce our agreements. Account and charging records are generally retained while an account is active and for a period afterwards. Authentication tokens expire automatically. If you would like your information deleted, contact us using the details below and we will action your request subject to our legal obligations.

9. How we protect information

• Encryption of data in transit (TLS/HTTPS) and at rest.
• Authentication with role-based access control and optional two-factor authentication.
• Secrets and credentials held in a managed secrets vault; passwords stored only as hashes.
• Rate limiting, security headers, network firewalling and audit logging of administrative actions.

No system is perfectly secure, but we work to protect your information and to respond promptly to any security incident, including any notification we are legally required to make.

10. Your privacy rights

Depending on where you live, you may have rights to: access the personal information we hold about you; correct inaccurate information; request deletion; object to or restrict certain processing; request portability of information you gave us; and withdraw consent (for example, to marketing) at any time. Because guests usually do not have an account, guests can exercise these rights by contacting us (or their host) using the details below.

To make a request, email [email protected]. We may need to verify your identity. You also have the right to complain to a regulator — in Australia, the Office of the Australian Information Commissioner (OAIC); in the EU, your local data protection authority; in the UK, the Information Commissioner’s Office (ICO).

11. Children

The Service is intended for adults and is not directed at children. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. We will post the updated version here and change the “Last updated” date. Material changes will be notified where appropriate.

13. Contact us

LLM Family Investments Pty Ltd as trustee for the LLM Family Trust, trading as Guest Charge
PO Box 599, Mitchell ACT 2911, Australia
Privacy enquiries: [email protected]