We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the UK).
2 About us
You can contact us by email at firstname.lastname@example.org, or in writing at Engenie, Piccadilly Suite, Portland House, Bressenden Place, London SW1E 5RS
3 Personal information we collect about you
We may collect and use the following personal information about you:
– your name and contact information, including email address and telephone number and details about your occupation (when provided by you)
– information to enable us to check and verify your identity, e.g. your date of birth
– your car make, model and registration plate (when provided by you)
– your billing information, transaction and payment card information albeit this is encrypted via our payment services provider
– your personalinterests
– your contact history, purchase history and saved items, and location data relevant to which chargers you have used and when (via your phone app)
– information from accounts you link to us, e.g. Instagram or Twitter
– information about how you use our website and apps and how you interact with email marketing campaigns
– your responses to surveys, competitions and promotions
– information from any enquiry you make to us
This personal information is required to help navigate our site and also use of charging stations. If you do not provide personal information we ask for, it may delay or prevent us from providing charging services to you.
4 How your personal information is collected
We collect most of this personal information directly from you – in person, by telephone, text or emailand via our websiteand apps. However, we may also collect information:
– from publicly accessible sources, e.g. any public social media account information
5 How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
– for the performance of our contract with you or to take steps at your request before entering into a contract (which includes providing you with charging services;
– to comply with our legal and regulatory obligations;
– for our legitimate interests or those of a third party; or
– where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The list below explains what we use your personal information for and our legal basis for doing so:
– we use personal information in order to provide you with the services you have requested from us and to respond to any enquiries or complaints you may make to us. This is necessary for performing our contract with you;
– we may use personal information to send direct marketing communications to you about new services, products, promotions, news and events. We will not send marketing communications to you unless you have consented to this. Further information about marketing is set out in ‘Promotional Communications’ below;
– we may use personal information as required for our legitimate interests. For example, it is in our interests to run competitions and prize draws to promote our services and related products and this may involve processing the personal information of competition entrants. We may also use your data to run incentive programmes for use of our services. Specific details of these programmes will be provided before enrolment; and
– we also have business interests in understanding how users use our services and respond to different parts of our website and apps in order to identify areas for improvement and analyse how effective the location of our chargers are and how effective our website and apps are. To do this we analyse the information about how you use our chargers, our website and apps.
6 Promotional communications
We may use your personal information to send you updates (by email, text message, in-app / push notifications, telephone or post) about our services and products, including exclusive offers, promotions or new services and products.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sellor share it with other organisations outside the group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
– contacting us at email@example.com
– using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services and productsin the future, or if there are changes in the law, regulation, or the structure of our business.
7 Who we share your personal information with
We routinely share personal information with:
– companies within our group;
– partners who provide space for our charging stations (however any data they receive from us is anonymised or metadata which does not identify you directly);
– third parties we use to help deliver our products and services to you, e.g. payment service providers;
– other third parties we use to help us run our business, e.g. marketing agencies or website hosts; or
– third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. For example, we may share information about suspected fraudulent activity on your account with the Police.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
8 Where your personal information is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
9 How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
– to respond to any questions, complaints or claims made by you or on your behalf;
– to show that we treated you fairly; and/or
– to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
10 Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
– with our offices outside the EEA;
– with your and our service providers located outside the EEA;
– if you are based outside the EEA;
– where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law, because non-EEA countries do not have the same data protection laws as the UK and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information please contact us.
11 Your Privacy Rights
Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact us in writing, with details allowing us to confirm your identity.
– Access: you may request access to a copy of your personal information.
– Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.
– Rectification: you may ask us to rectify any inaccurate information we hold about you.
– Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.
– Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.
– Object: you may object to our processing of your personal information.
– Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
If you are not happy with the way in which we process your personal information, or the way in which we handle any request by you to exercise your privacy rights, you may make a compliant to the ICO by visiting their website at https://ico.org.uk/concerns/or on 0303 123 1113
12 Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
This privacy notice was last updated on 7 June 2018.
We may change this privacy notice from time to time—when we make any substantial or material changes, we will announce this on our main website homepage.
14 Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘About us’ above).