Scope and Purpose
This policy concerns the Processing of Personal Data of customers by the Controller, Raiden Charging UK Ltd (hereinafter referred to as “ChargeGuru” or “we” or “our”). This policy is intended to provide our current, former and potential customers (hereafter jointly referred to as "customers" or "you") with a general understanding of:
- Circumstances in which we collect and process your Personal Data
- Types of Personal Data we collect
- Why we collect your Personal Data
- How we process your Personal Data
- Contact details for contacting us to obtain information about your rights and assert them in relation to the Processing of your Personal Data
ChargeGuru uses the definitions listed below in this policy:
- “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly, determines the purposes and means of the Processing of Personal Data;
- "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific factors the physical, psychological, genetic, mental, economic, cultural or social identity of said natural person;
- "Processing" means an operation or set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, restriction, erasure or destruction;
Principles of Data Processing
The Processing of your Personal Data forms an important part of our provision of products and services to you. We appreciate the trust you place in us when you entrust us with your Personal Data and we consider your Personal Data to be an essential part of the services we offer. In order to protect your Personal Data while increasing customer value and providing better and safer driving experiences, we adhere to the following general principals.
ChargeGuru will only process our customers' Personal Data if it is appropriate, relevant and necessary for the purposes for which it was collected, as set out in this policy. We aim to make your Personal Data anonymous when a function or service can be obtained with anonymous data. If we associate anonymous or non-Personal Data with your Personal Data, it will be treated as Personal Data as long as it remains associated.
It is ChargeGuru’s policy to comply with applicable laws, rules and regulations governing privacy and data protection in all countries in which we operate. Where necessary, we will adapt our Processing of your Personal Data as described in this policy to ensure legal compliance.
The Personal Data we Collect
You may provide us with Personal Data about you when you use ChargeGuru services, for example via our websites or customer centres (in this context, please note that telephone calls may be recorded, with your consent, to quality assurance purposes). This Personal Data may include:
- Your contact details (name, address, telephone number, e-mail address, etc.);
- Demographic information (civil status, etc.);
- Vehicle information (Model, VIN number (vehicle identification number) or vehicle serial number, etc.);
- Data relating to your purchase and use of our products and services (customer preferences and settings, purchase history, etc.).
Note that we may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.
Purposes of Processing
The Personal Data that ChargeGuru collects about you will be used:
- To provide you with products and services, including to verify your eligibility for certain purchases and services, as well as to provide you with extended offers and experiences;
- To notify you of updates or changes to our products and services, including, without limitation, changes to our terms and conditions and policies;
- To notify you of new products, services and events;
- To provide charging device support and services (warranty service, recall information, etc.);
- To assess and improve our customer offerings and communication with customers;
- To comply with legal requirements or lawful requests to authorities;
- To inform you about our products and services and determine which ones may be of interest to you;
- To carry out market research; and
- For the purposes of analytics and customer profiling (including online and social media and entertainment) carried out by us and our chosen suppliers.
Legal Basis for Processing
Performance of a contract: We process Personal Data where necessary for the performance of our contractual obligations to you, for example, to provide our websites and our services and products to you.
Compliance with legal obligations: We process Personal Data where necessary to comply with the legal obligations to which we are subject, for example, to cooperate with public and government authorities, courts or regulators in accordance with our legal obligations, to the extent this requires the processing or disclosure of Personal Data to protect our rights.
Legitimate Interests: We process your Personal Data where necessary to serve our legitimate business interests, for example, to tailor the content and information we may send or display to you, to improve our websites and our services and products, and for business administration purposes. When we use Personal Data to meet our legitimate interests, we take steps to ensure that your rights are not infringed.
Consent: Where reasonably possible or where required by applicable law, we will obtain your consent before collecting or using your Personal Data. The request for consent will be clear and specific and will provide a reasonable basis on which to make your decision. We will never take your consent for granted. On the contrary, we will ensure that your consent is granted in a transparent and informed manner. If you do not give your consent, it will not be possible to use the Services or parts of the Services.
To the extent we obtain your consent to process your Personal Data, you have the right to withdraw your consent. To exercise this right, please contact us using the details at the end of this policy.
You have certain rights regarding your Personal Data, subject to local law. These include the following rights to:
- Access your Personal Data
- Rectify the Personal Data we hold about you
- Erase your Personal Data
- Restrict our use of your Personal Data
- Object to our use of your Personal Data
- Receive your Personal Data in a usable electronic format and transmit it to a third party (right to data portability)
If you would like to discuss or exercise such rights, please contact us using the details at the end of this policy.
We will contact you if we need additional information from you in order to honour your requests.
We encourage you to contact us to update or correct your Personal Data if it changes or if the Personal Data we hold about you is inaccurate. When we process your Personal Data, we make every effort to ensure that it is correct and up to date. We will attempt to delete or rectify incorrect or incomplete Personal Data.
If applicable law provides for administrative costs to respond to your request(s), these costs may be invoiced by ChargeGuru.
We will only retain your Personal Data for as long as necessary to fulfil the purposes set out in this policy or other purposes disclosed to you. This means that we will retain your data for the duration of our business relationship (and, where applicable, until the expiry of the warranty period).
ChargeGuru has implemented appropriate technical and organisational measures that aim to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and all other unlawful forms of Processing. Please be aware that despite our efforts, no data security measures can guarantee security.
Disclosure to Third Parties
ChargeGuru may share your Personal Data:
- with Zeplug (a French legal entity whose registration number is 80788643700027);
- in application of the law, for example in connection with a request from the authorities, a litigation or any other legal proceeding or request;
- if we believe, in good faith, that disclosure is necessary to protect your rights, such as to investigate possible breaches of our terms and conditions or to detect, prevent or disclose fraud or other security issues;
- with providers of products and services who work on our behalf, for example electrical contractors, credit card Processing companies or providers of systems that are necessary to process, store or handle credit card information credit or financial information; and
- with emergency service providers, e.g. state law enforcement agencies and rescue service providers, to provide related services.
Data Processing on Our Behalf
We restrict access to your Personal Data to ChargeGuru employees and suppliers who need to use the information to process it on our behalf and who are contractually bound to maintain the security and confidentiality of your Personal Data. We seek to select the option of Processing services that best preserves the integrity of your Personal Data vis-à-vis a third party.
International Data Transfers
Your Personal Data will not be transferred, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Data.
We will not sell or trade your Personal Data to third parties without your consent to do so. We will not share your Personal Data with third parties for their marketing purposes unless we have received your consent to disclose it. If you have given this consent, but no longer wish to receive marketing materials from a third party, we invite you to contact this third party directly. We may provide you with information regarding new products, services, events or similar marketing activities. If you wish to unsubscribe from a particular electronic newsletter or similar communication, please follow the instructions of the communication in question.
Our services are not intended for use by children. We do not knowingly request or collect Personal Data from anyone under the age of 18 and we do not market our products and services to them. If a child has provided us with Personal Data, their parents or guardians may contact us to have that information deleted from our records. Please contact us if you believe we may have information about a child under 13. If we become aware that we have unwittingly collected Personal Data from a child under the age of 13 or below the minimum age required by applicable law, that information will be deleted from our records.
Filing a Complaint to the Supervisory Authority
If you believe that we are Processing your Personal Data in breach of data protection laws, you have the right to lodge a complaint with the Information Commissioner's Office.
To exercise your rights as a data subject, for example to obtain information on the Processing of your Personal Data by ChargeGuru or to access the Personal Data concerning you processed by ChargeGuru, we invite you to contact us by email at [email protected] or by post to Raiden Charging UK Ltd (trading as ChargeGuru UK), 21 Holborn Viaduct, London, EC1A 2DY.
Changes to This Policy
We may change this policy from time to time, so please be sure to check back periodically. We will post any changes to this policy on our website. If we make any changes to this policy that materially affect our practices with regard to the information we have previously collected about you, we will endeavour to provide you with notice in advance of such change by highlighting the change on our website or sending you an email.