VEVA MOBILE APP PRIVACY POLICY
INTRODUCTION
Em-Lite Limited are committed to protecting your personal data and respecting your privacy.
This policy applies to your use of the VEVA Electric Vehicle Charging App mobile application software (“App”) available on the Apple App Store and Google Play once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”) and any of the services accessible through the App (“Services”).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
1. IMPORTANT INFORMATION AND WHO WE ARE
Em-Lite Limited is the controller and is responsible for the App, and Top-Up Meters Limited is the processor and is responsible for collecting and storing your personal data for the App on behalf of Em-Lite Limited as detailed in this privacy policy (collectively referred to as “we”, “us” or “our” in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager by email at privacy@em-lite.co.uk or in writing to Unit 1, Stevern Way, Peterborough, PE1 5EL.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated in May 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you via the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
THIRD PARTY LINKS
The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
2. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
Identity Data includes first name, last name, username or similar identifier.
Contact Data includes email address.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and details of in-App purchases.
Device Data includes the serial number of your VEVA charge point(s), type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
Profile Data includes your username and password.
Usage Data includes details of your use of the App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Service Data includes data automatically collected from your VEVA charge point (including your charging session history, half-hourly charging profile, daily profile, operating condition, and settings).
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect data about you in the following ways:
Information you give us. This is information (including Identity, Contact, Device and Service Data) you consent to giving us about you by filling in forms on the App. It includes information you provide when you:
download and register an account to use the App;
register a VEVA charge point to your account;
search for the App or Service;
make an in-App purchase;
when you report a problem with the App or our Services. If you contact us, we may keep a record of that correspondence.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Device Data from analytics providers, advertising networks and search information providers;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
Identity and Contact Data from data brokers or aggregators; and
Identity and Contact Data from publicly available sources.
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity: To install the App and register yourself as a new App user
Type of data: Identity, Contact, Device
Lawful basis for processing including basis of legitimate interest:
Your consent
Purpose/Activity: To enable other users to control your VEVA charge point(s)
Type of data: Identity, Contact, Device
Lawful basis for processing including basis of legitimate interest:
Your consent.
Purpose/Activity: To deliver charge point information on your App, including Service Data and charge point information
Type of data: Identity, Contact, Device, Profile, Usage, Service
Lawful basis for processing including basis of legitimate interest:
Your consent;
Performance of a contract with you.
Purpose/Activity: To process in-App purchases and deliver Services including managing payments and collecting money owed to us
Type of data: Identity, Contact, Financial, Transaction, Device
Lawful basis for processing including basis of legitimate interest:
Your consent;
Performance of a contract with you;
Necessary for our legitimate interests (to recover debts due to us).
Purpose/Activity: To manage our relationship with you including notifying you of changes to the App or any Services
Type of data: Identity, Contact, Profile
Lawful basis for processing including basis of legitimate interest:
Your consent;
Performance of a contract with you;
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/Services);
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).
Purpose/activity: To administer and protect our business and the App including troubleshooting, data analysis, system testing and customer support
Type of data: Identity, Contact, Device, Service
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).
Purpose/Activity: To make recommendations to you about goods or services which may interest you; To monitor trends so we can improve the App
Type of data: Identity, Contact, Device, Content, Profile, Usage
Lawful basis for processing including basis of legitimate interest:
Consent;
Necessary for our legitimate interests (to develop our products/Services and grow our business).
5. DISCLOSURES OF YOUR PERSONAL DATA
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
Business partners;
Service providers who provide marketing, payment, IT and system administration services;
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue and Customs, regulators and other authorities acting who require reporting of processing activities in certain circumstances;
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; and
Third parties if we are under a duty to disclose or share personal data in order to comply with any legal obligations, or in order to enforce or apply our Terms of Use or any other agreements, or to protect the rights, property or safety of Em-Lite Limited, our customers and others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the UK.
7. DATA SECURITY
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where you have chosen a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data. See below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 2 years then we will treat the account as expired and your personal data may be deleted.
9. YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy;
Where our use of the data is unlawful, but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
10. GLOSSARY
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to