Privacy Policy
1 Introduction
At Applegreen Electric ("Applegreen Electric", "we", "us", "our") we recognise that it is important for you to understand how we use your personal data. Therefore, please read the following information carefully as it contains important information regarding the use of your personal data in relation to your use of the Applegreen Electric website (this/our “Website”), the Applegreen Electric App (this/our "App") and your use of Applegreen Electric vehicle charging stations.
This Privacy Notice explains the types of personal data we may collect about you when you visit our Website, use our App and/or charge your electric vehicle at one of our charging stations. It also explains why we do so, and how we’ll use, store and handle your personal data.
We will only use personal data in ways that are described in this Privacy Notice and that are consistent with our obligations and your rights under applicable Data Protection Laws.
2 Who we are
If you are a customer in Ireland, the controller of the personal data you provide to us is Applegreen Electric IRL Limited, and for the purpose of applicable Data Protection Laws, is the data controller (in other words, the legal entity that determines how and for what purposes your personal data is used). You can find out how to contact us at Paragraph 15 of this Privacy Notice below.
If you are a customer in the United Kingdom, the controller of the personal data you provide to us will be the Applegreen Electric UK group companies. If you are availing of our electric charging services location at a Welcome Break Service Station, Applegreen Electric UK Service Areas Limited will be the controller of your personal data and if you are availing of our electric charging services located at an Applegreen Electric Plaza, Applegreen Electric UK Limited will be the controller of your personal data. References to "Applegreen Electric", "we", "us" or "our" in this notice therefore includes Applegreen Electric IRL Limited, Applegreen Electric UK Service Areas Limited and Applegreen Electric UK Limited (as the case may be).
Applegreen Electric is part of the wider Applegreen corporate group and references to “Applegreen” refer to the other parts of the wider corporate group’s business, which may process your personal data as a separate controller as a result of your use of other Applegreen services. “Welcome Break” refers to the corporate entity that owns a number of Service Stations where our electric charging services are made available to our customers based in the United Kingdom and who may process your personal data as a separate controller as a result of your use of other Welcome Break services. The processing of personal data in connection with services made available directly by Applegreen and/or Welcome Break are not covered by this Privacy Notice.
3 Personal data we may collect from you and how we collect it
Your privacy is important to us and we are committed to protecting it. In the course of our dealings with you, we will collect and process personal data about you. Personal data is any information that allows you to be individually identified. We will use your personal data in accordance with all applicable laws and regulations that relate to data protection and privacy, including the EU General Data Protection Regulation (GDPR) and UK GDPR (“Data Protection Laws”).
Personal data you provide to us
3.1 Ways in which you might provide personal data to us directly
This is personal data about you that you provide to us directly, for example, by registering as an Applegreen Electric customer, subscribing to use Applegreen Electric products or services (such as the App), your use of those products or services over time, signing up to our newsletter, corresponding with us by e-mail, telephone or SMS (including if you call us for customer support) or if you mention or interact with us on social media (for example by mentioning/tagging us or by contacting us through direct messaging). It also includes personal data you provide when you provide us with feedback, report a problem with our App or Website or charge point, enter into a contract with us, engage with any of our promotions or otherwise provide us with any personal data.
3.2 What type of personal data might be included?
The exact personal data you give us will depend on your interactions with us and your use of Applegreen Electric products or services, and may include:
(a) Personal information, including: your name, gender (and preferred salutation), date of birth, occupation, a profile picture (if you choose to provide one);
(b) Contact information, including: your postal address, e-mail address and phone number (including mobile number), your Applegreen Electric account details and social media handle;
(c) Your vehicle information, including: vehicle manufacturer, vehicle model, year vehicle was manufactured, colour of vehicle and registration number;
(d) Payment information, including your payment card information and billing address; and/or
(e) Feedback and customer support information, including your feedback about our products (including complaints and reviews) and any other information that you provide to us during a customer support call, such as your location, or your most recent account sign in.
3.3 Personal Data collected when you visit one of our sites
Location Data: We record the location of the electric vehicle charging point when you start a transaction at that charging point.
3.4 Personal data we collect or generate about you.
(a) Service Usage Data: When you use Applegreen Electric products or services to charge your vehicle at one of our charging stations, we will collect, generate, store and use personal data about your use of these products or services. This personal data will include the amount of electric charge you purchase for your vehicle, the time of your charging session, the length of time your vehicle parks in an electric vehicle charging bay and the length of time you charge your vehicle, the location of your charging session and the make and model of your vehicle.
(b) Preferences Data: We may also collect details of your vehicle charging preferences which help us to recommend items of interest to you where you have signed up to receive marketing communications from us.
(c) Location Data: Our App also features optional functionality that allows you to use your location data to find your nearest Applegreen Electric vehicle charging point. This information will be processed by your GPS map application, such as Google Maps or Apple Maps as an independent third party, and we will not store or save this location data. The only time we have access to information about your location is when you start a transaction at one of our electric vehicle charging points or when you tell our customer support team where you are. We may also anonymise information about your location (so that we can no longer identify you from it, meaning it is no longer personal data) for our own commercial purposes.
(d) Digital usage data
When you visit our Website, use our App or get in touch with us, we may collect, generate, store and use certain personal data about you.
This personal data may include: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if accessing an account with us), browser type and version, time zone setting, browser plug-in types and versions, device types, hardware model, operating system, version, time and date of consent and platform, any phone number used to call our customer service number, who your mobile network operator is and any other relevant network information.
It may also include information about your visit to our Website, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed, searched for or purchased, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse our Website and any other information gathered by the use of cookies in your browser. Learn more about cookies here: https://www.applegreenelectric.com/cookies
If you dispose of or pass on your mobile device, we strongly urge you to restore it to its factory settings. If the device is lost or stolen, please contact Applegreen Electric using the details at Paragraph 15 of this Privacy Notice below so we can amend our records accordingly.
(e) Personal data we receive from other sources.
CCTV data: When you visit one of our charging locations, we may also process your personal data in the form of video or audio recordings via CCTV. In some instances, this CCTV is operated by a third party and shared with Applegreen Electric. CCTV covers the sites where the charging stations are located for the safety and security of staff, customers, equipment and properties, and to aid in the prevention, detection and investigation of any crimes committed in relation to them. Your car number plate may be recorded at some electric vehicle charging bays to prevent unauthorised parking and to investigate accidents and other incidents, and this information may be collected by Applegreen Electric and/or shared with Applegreen Electric where necessary for the purposes outlined in Paragraph 4, below.
We do not use CCTV for other monitoring purposes. If you would like more information about Applegreen Electric’s use of CCTV, please contact us to request additional information.
4 Why and how do we use your personal information and what is our "lawful basis" for doing so?
Whenever we process your personal data, we are required to do so for a specified purpose and to identify and maintain a valid "lawful basis" (i.e. a legally compliant justification) for the processing. To help you to understand what we do with your personal data and why. We have described the various relevant lawful bases that we rely on in the table below. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
| How and why we use your personal data | Categories of personal data we use for this purpose | Our lawful basis for processing your personal data |
|---|---|---|
| To provide you with the information and services that you request from us (i.e. to complete certain tasks, processes, and to communicate with you regarding those services that you request from us (such as providing you with our App to assist in your charging sessions) and respond to your questions and comments). |
|
We rely on our contractual arrangements to collect and process your personal data in relation to an order for products and services. Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues). 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. |
| To measure how satisfied our Website visitors, our App users and our customers are and provide customer support services (including troubleshooting in connection with your requests for services or when you ask us questions by email, by telephone or on social media). |
|
We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order for products and services. Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues). 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. |
| To prevent or detect crime, fraud or abuses of our products and services, our Website or our App and to enable third parties to carry out related technical, logistical, research or other functions on our behalf related to these purposes. This will include ensuring that the personal and financial information that you provide to us is accurate and managing risk to us and our customers. |
|
In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, if we receive a legitimate request from a law enforcement agency). Please see an indicative list of Irish laws Click here
from which such an obligation may arise. In other cases (such as the detection of theft, fraud or ensuring security of our website) we rely on our legitimate interests in keeping our employees, our App and our Website secure and to prevent theft and fraud. |
| To administer our Website and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and for the control of illegal acts. We reserve the right to check log files and data retroactively if there is reasonable suspicion of an illegal act due to concrete indications. |
|
We rely on our legitimate business interests as a digital service provider to administer our Website and App. |
| To find out more about the visitors to our Website, our App users and our customer base as a whole (and not to find out more about you as an individual) to ensure that the products and services that we offer are most likely to interest our Website visitors, our App users and our customers. We may use cookies to do this. |
|
We rely on our legitimate interest to improve our products and services. For the use of cookies other than "strictly necessary" cookies we rely on your consent. For information on how we use cookies, please see our cookie policy https://www.applegreenelectric.com/cookies/ |
| To notify you about changes to our services and terms and conditions. |
|
We rely on our contractual arrangements with you as the lawful basis for this processing. In some cases, we rely on our legitimate interests as a business to send you these updates. |
| For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our Website, App or electric vehicle charging services. |
|
We rely on our legitimate interest to respond to your contact for the purposes of administering our business. |
| For ensuring the safety and security of our staff, our customers, our equipment and our properties, and to prevent, detect and investigate any criminal activity in relation to them. |
|
We rely on our legitimate interest to ensure the safety of our staff, our customers, our equipment and our properties. In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, in the event of any criminal investigations, we may be required by law, to share the data captured with the relevant authorities). |
| To prevent unauthorised parking, and to investigate accidents or other incidents. |
|
We rely on our legitimate interest to ensure our equipment is operated safely, in accordance with our terms and conditions, and that all accidents or other incidents are properly investigated. |
| Sharing relevant information to comply with our obligations under lease or third party agreements and other contracts for the physical placement and maintenance of our charging stations, including audit provisions of such contracts. |
|
We rely on our legitimate business interests to process, including sharing, information that is required under provisions of our agreements with third parties, including with Applegreen and Welcome Break entities. Where possible, information processed in this way is anonymised and/or aggregated. |
| To send you electronic marketing communications if you (a) provide your consent to receiving such communications or; (b) in certain circumstances, where you are an existing customer. |
|
We rely on your consent to send you electronic marketing communications, where you have provided your consent to receiving such communications. In some cases, where you are an existing customer, we may rely on our legitimate interests to send you electronic marketing communications, giving you the opportunity to opt-out to receiving such communications. |
| To process your personal data in connection with competitions that we run for marketing and promotional purposes, where you choose to enter such competitions. |
|
We rely on our legitimate interests to process your personal data in connection with competitions that we run for marketing and promotional purposes. |
We safeguard your interests by anonymizing your IP address upon collection so that you are not identifiable. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. If you provide other people with access to your account, please direct those other users to this Privacy Notice so that they are able to understand how we process their personal data.
5 What if you fail to provide personal data?
If you do not provide us with certain information when requested, we may not be able to provide you with products or services. In some cases, we may have to cancel or withdraw an existing product or service of ours that you are using or you have with us. We will notify you if this circumstance arises.
6 Change of purpose
We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new Privacy Notice to you.
7 How we share your personal data and where it may be processed
On occasion we may share your data with trusted third parties including subsidiaries of the Applegreen group and/or the Welcome Break group, business partners, suppliers and sub- contractors.
7.1 Third party suppliers and service providers which process your personal data
Like most businesses, we may provide your personal data to third parties for processing as part of the services that those third parties carry out on our behalf as part of the day to day operations of our business. These trusted suppliers will process your personal data on our behalf and provide us with services such as the provision of IT services, third party software providers (such as our App provider), the hosting of your personal data, direct marketing and the management of our electronic communications with you.
If we share your personal data with such trusted third parties, we ensure it is kept safe. We will always make sure that these trusted suppliers are bound by contractual standards for the protection of your personal data in accordance with applicable Data Protection Laws and we will provide only the information they need to perform their specific services. Third parties will only be permitted to use your personal data in order to provide us with services (and not for their own purposes).
We require all third parties to take appropriate technical and organisational security measures to protect your personal data and to treat it subject to a duty of confidentiality and in accordance with applicable Data Protection Law. We work closely with them to ensure that your privacy is respected and protected at all times and if we stop using their services, any of your personal data held by them will either be deleted, returned to us or rendered anonymous.
7.2 Sharing your personal data with other entities in our group and our investors
We will share your personal data with other entities in our corporate group and our investors as part of the administration of our business. Our group companies share various operations and business processes. We may share your personal data with any member of our group in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so.
For example, we may share personal data as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
7.3 Other scenarios in which we might share your personal data
We may also share your personal data:
(a) with government authorities or professional bodies, such as HM Revenue & Customs in the United Kingdom (for tax purposes) and the Revenue Commissioners in Ireland (for tax purposes), where required by applicable law;
(b) with our professional advisors including tax, financial, legal or other corporate advisors who provide professional services to us;
(c) with regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised law enforcement bodies, for the purposes of investigating any actual or suspected criminal activity, for bringing or defending legal proceedings or other regulatory or legal matters etc.;
(d) in the event that we consider selling or buying any business or assets we may disclose your personal data to any prospective sellers or buyers of such business or assets;
(e) in the event of any insolvency situation (e.g. administration or liquidation);
(f) if we, or substantially all of our assets, are acquired by a third party, in which case your personal data will be one of the transferred assets;
8 How do we protect your personal information?
Applegreen Electric has put in place physical, technical, operational and administrative strategies, controls and measures to help protect your personal data from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We keep these under regular review to make sure that the measures we have implemented remain appropriate.
You can obtain further information about the data protection measures we take by contacting us using the contact details set out at Paragraph 15 of this Privacy Notice below.
In addition, we limit access to your personal data to those employees, workers, agents, contractors and other third parties acting on our behalf who have a business need to know in order to perform their job duties and responsibilities. They will only process your personal data on our instructions and where they are subject to a duty of confidentiality.
9 How long we keep your personal information?
Applegreen Electric will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected and processed. Information about your vehicle and use of particular Applegreen Electric charging stations will generally be retained for the time required under any lease agreement or other third party agreement where Applegreen Electric have an obligation to share this information with an applicable third party and retain the applicable personal data in order to comply with audit obligations under such agreements.
This means that your personal data will be kept only for as long as necessary to continue to provide services or through our App, your use of charging stations, or your use of our Website. In most cases, this period is two years after you cease to be an active customer, but it may be up to seven years in order to comply with our legal, tax, health and safety, reporting or accounting requirements.
Personal data which is no longer required to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy, return or erase such personal data where applicable.
In some circumstances we may anonymise your personal data so that while it can no longer be associated with you, it can be used for statistical analysis and business planning. In this case, we may retain such information for a longer period without further notice to you.
10 Your rights in connection with your personal data
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes so that our records can be updated. We are not responsible for errors in your personal data in this regard where you have failed to notify us of the relevant change.
Data Protection Law grants you a number of specific rights in respect of your personal data in addition to the broad and general right to have your personal data protected. We have set out some information in respect of each of those specific rights, below:
10.1 Right to be informed about how your personal data will be processed. This enables you to receive information about how we use your personal data. We have set this information out in this notice.
10.2 Request access to a copy of 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, usually free of charge (unless your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your requests in these circumstances).
10.3 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
10.4 Request erasure of your personal data (commonly known as the "right to be forgotten"). 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 exercised your right to object to processing. Please see below steps to be followed to delete your account from our App.
10.5 Object to processing of your personal data where we are relying on the lawful basis of our legitimate interests (or those of a third party) to process your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes, on the basis of our legitimate interests.
10.6 Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent to such processing. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
10.7 Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish
its accuracy or the reason for processing it or while we are considering an objection you have made to processing of your personal data.
10.8 Request your personal information in a format that makes it easier to reuse your information in another context, and to request the transfer of your personal data to another party, if technically feasible.
10.9 Not to be subject to a decision solely based on automated processing. We do not anticipate making decisions about you based solely on automated decision making where that decision would have a significant impact on you. If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human.
10.10 To submit a complaint to the data protection supervising authority for your country, as set out in section 16 of this Notice. While it is not legally required, we would ask that you contact us in the first instance to allow us the opportunity to address your concerns if you wish to make a complaint.
If you want to exercise any of the rights set out above, please contact us using the contact details set out at Paragraph 15 of this Privacy Notice below. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How to delete your account on our App:
- Step 1 & 2: From the App Home page, go to the menu and tap My Account > Profile.
- Step 1 & 2: From the App Home page, go to the menu and tap My Account > Profile.
- Step 3: Scroll down to the bottom of the Profile page and tap Delete My Account.
- Step 4: In the popup that appears, tap Delete my account.
- Step 5: A representative will receive the request and delete your account, including references to all historical activities. You will receive an email confirming the deletion of your account.
11 Processing your personal data in other territories
Given the international location of some of our suppliers and group companies, your personal data will be transferred in and out of the UK and the European Economic Area ("EEA") where local laws may not provide legal protection for personal data in the same way as is applicable in the UK or the EEA. For example, our App, although hosted in the UK, is provided to us by a supplier in Israel. As a result your personal data may be processed in Israel.
Where your personal data has been transferred to companies within the Applegreen group or to other authorised third parties located outside of the EEA and processed outside of the UK and EEA, we will ensure that we take the necessary steps to protect your personal data as required by Data Protection Laws (including consideration of the adequacy regulations and appropriate safeguards under GDPR).
12 Cookies
Our Website uses cookies to distinguish you from other users of our Website and App. Cookies are also used for the purposes of providing you with a good experience when you browse our Website and App and allowing us to improve our Website, our App and our services. In order to log into your account online or in the App, Applegreen Electric may use cookies to store session information at our convenience. These cookies can be blocked or deleted by you at any time.
We will not place cookies other than "strictly necessary" cookies on your device unless you have told us that you are happy for us to do so. For information on how we use cookies, please see our cookie policy https://www.applegreenelectric.com/cookies/
13 Direct Marketing
We use your personal data to send you electronic marketing communications if you (a) provide your consent to receiving such communications or; (b) in certain circumstances, where you are an existing customer and we have given you the opportunity to opt-out from receiving such communications.
You have the right to opt-out of the use of your personal data for marketing purposes at any time. Please contact us using the information in the ”Contact” section of the Privacy Notice below. Alternatively, each time you receive a marketing communication, you will have the option to opt-out from receiving further marketing communications from us.
14 Third-party websites
Our Website or App may, from time to time, contain links to third-party websites and applications such as Twitter, Facebook, Instagram, and Google Maps. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Our Website or App may also contain links to Applegreen.com, or to Welcomebreak.co.uk. While this site is operated by an Applegreen group company, personal data submitted to this website is not processed by Applegreen Electric. Applegreen.com and Welcomebreak.co.uk have separate and distinct privacy policy Applegreen Privacy Policy / Welcome Break Privacy Policy, which you should review before you submit any personal data.
15 Changes to this Privacy Notice
We reserve the right to update or amend this Privacy Notice at any time, including where we intend to further process your personal data for a purpose other than that for which the personal data was collected or where we intend to process new types of personal data. We will issue you with a new privacy notice as soon as practicable when we make significant updates or amendments. We may also notify you about the processing of your personal data in other ways from time to time.
This Privacy Notice was last updated on 23rd May 2023.
16 Contact
If you have any questions about this Privacy Notice or how Applegreen Electric handles your personal data, or if you would like to exercise any of the rights set out in the section “Your rights in connection with your personal data”, please contact us using one of the methods below.
Any territory
Electronic request: Please complete our webform here.
Email: Dataprotectionofficer@applegreenelectric.com
Post:
Applegreen Electric Data Protection Officer,
Applegreen Electric, Unit 17, Joyce Way,
Parkwest, D12F2V3, Ireland
England
Post:
Data Protection Officer, Applegreen Electric, Office 3,
The Limes, Dunstable Street, Ampthill,
Bedfordshire, MK45 2GJ, United Kingdom.
17. Complaints
We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal data (our details are in the section immediately above). We will try to put things right.
However, if you feel that your personal data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the supervising authority for your country, as follows:
Ireland
Email: dpo@dataprotection.ie
Phone: +353 (0)761 104 800 or +353 (0)57 868 4800
Post: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2 D02 RD28, Ireland
Website: www.dataprotection.ie
United Kingdom
Email: icocasework@ico.org.uk
Phone: 0303 123 1113
Post: Customer Contact, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom
Website: www.ico.org.uk
If you are based outside the UK or Ireland, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
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