Data Protection & Retention Policy
What is this Policy
What personal information do we collect?
Personal information collected will depend on the circumstances of collection and the services provided to you and may include:
- Identification details such as name, birth date, age and gender;
- telephone number and other contact details;
- email address;
- personal driving data, home energy data, home energy preferences and consumption data, vehicle purchasing preferences and customer behavioural data
- vehicle travel data, vehicle garaging data (de-identified) and vehicle trip logging information
- vehicle insurance and financing details
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys;
- if you are applying for employment with us, personal information that is relevant to such employment; and
- any other personal information that may be required in order to facilitate your dealings with us.
How do we collect information?
We may collect these types of personal information either directly from you, or from third parties. We may collect this information:
- when you register on our website or app;
- when you communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
- when you interact with our sites, services, content and advertising;
- from third parties including those under the heading “To whom we disclose your Personal Information”, which include our associated companies, our service providers and other third parties so that we may provide an enhanced and more relevant user experience, product or service to you; and
- through use of our software or apps in which personal information is stored
We also use software cookies to tell us how you use our website and how we can help you.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to provide services to you to assist you when purchasing an electric vehicle and to make better decisions about products and services related to electric vehicles including energy products, finance and insurance;
- to facilitate the development of low carbon transport initiatives in Australia and/or the United Kingdom;
- to enable you to access and use our website, services and apps;
- to operate, protect, improve and optimise our website, services and apps business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
Where the EU GDPR applies we rely on the following lawful reasons to collect and use your personal information and, on occasion, more than one lawful reason (basis) set out below may apply to the processing:
- our legitimate interests in marketing and providing our goods and services for both our benefit and that of our customers and other third parties interested in what we provide;
- to perform or enter into any contract we may have with you;
- to comply with our legal obligations;
- to protect your vital interests or that of another person (e.g. in an emergency); or
- where you consent to the processing where we ask you to (e.g. for certain sorts of marketing or other processing where the law either requires this or where it is our policy from time to time to seek consent for such processing).
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our services This may take the form of emails, SMS, mail or other forms of communication, in accordance with applicable legislation. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).
To whom do we disclose your personal information?
- our employees and related bodies corporate;
- third party suppliers and service providers engaged in connection with providing our products and services to you (including providers for the operation of our websites, third party web mail servers and developers of various tools in connection with the provision of our services)
- operators of third party web sites, co-branded websites and applications
- professional advisers, dealers and agents;
- our existing or potential business partners, including various governmental and non-governmental agencies involved in the development of low carbon transport initiatives in Australia and/or the United Kingdom and providers of transportation services
- our sponsors or promoters of any competition that we conduct via our services;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to our related bodies corporate located in the United Kingdom and to our business partners and third party suppliers and developers involved in developing our products in the United Kingdom and Ireland and certain business partners located in the United Kingdom.We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.Where the EU GDPR applies to any transfer of personal information, either by us or by any third party to whom we provide your personal information, such transfer will (unless the European Commission considers their laws adequate) be subject to appropriate or suitable relevant safeguards (such as a legally binding contract containing European Commission-approved model clauses or terms consistent with them or, for transfers to the US, the EU-US Privacy Shield). These safeguards will apply to the extent required under the EU GDPR and are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. If you have any queries about the basis upon which we may transfer your personal information outside of Australia, please contact us using our contact details below.
Using our website and cookies
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example:
- access to your personal information is protected by strict user logins and only a limited number of people that need access to, and use of, personal data in order to perform their work shall have access to your personal information;
- other information security protocols are in place with respect to handling and sharing personal information such as using secure networks, using encryption in certain cases and secure storage of personal data
- Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
- All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of applicable Privacy legislation
However, we cannot guarantee the security of your personal information.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the contact us function. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
Data disposal and retention
Your rights under the EU GDPR (if applicable)
Under the EU GDPR (where it applies to you), you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information and to certain other supplementary information
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- where the processing is based on your consent you may withdraw your consent at any time
- otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, see for example the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please:
- email us (contact details below) and let us have enough information to identify you (such as name and registration details)
- let us have proof of your identity and address
- let us know the information to which your request relates, including any account or reference numbers, if you have them.
Making a complaint
If you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take. If, for any reason you do not wish to complain to us initially or if you are unhappy with how we propose to resolve your complaint, then complaint may also be made to the Office of the Australian Information Commissioner.Please note that where it applies, the EU GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the EU (or European Economic Area) member state where you work, normally live or where any alleged infringement of data protection laws occurred.
Or by mail to:
- (in Australia) Evenergi Pty Ltd, Suite 561, 41/464 – 480 Kent Street, Sydney, NSW, 2000, Australia
- (in the EU) Evenergi UK Ltd, 35 Ballards Lane, London, N31XW, United Kingdom