Privacy Policy
United Kingdom and Ireland
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.
USA
1 Introduction
At Applegreen Electric, we recognize that it is important for you to understand how we use your personal data. This privacy notice explains why we collect your data, and how we’ll use, store, handle, and share that data. Therefore, please read the following information carefully. This privacy notice applies to our collection and processing of your personal data in relation to your use of the Applegreen Electric services, such as our corporate website and driver account website (“Website”), the Applegreen Electric App ("App"), and your use of Applegreen Electric electric vehicle (EV) chargers, and elsewhere this privacy notice is linked (collectively, the “Services”). "Applegreen Electric", "we", "us", "our" as used in this notice means Applegreen Electric US Inc. and our U.S. subsidiaries and affiliates.
We will use personal data in ways that are described in this policy or otherwise disclosed to you at the time of collection, and that are consistent with applicable law.
Notably, this privacy notice does not apply to data that is not treated as personal data (or a similar term) under the applicable laws or to the extent the data is subject to an exemption under the applicable laws. In addition, this privacy notice also does not apply to information collected by third-party content, websites, applications, platform, code (e.g., plug-ins, application programming interfaces, and software development kits), and certain cookies and other tracking technologies (“Third-Party Services”).
2. 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 that we de-identify or receive in a de-identified format will be maintained as such and we will not attempt to re-identify it.
Personal data you provide to us
2.1 Ways in which you might provide the personal data to us directly
This is personal data about you that you provide to us directly through your use of the Services, 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 marketing activites by e-mail, SMS, Push notifications through the app, or by corresponding with us by e-mail or telephone (for example, 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, Website or EV chargers, enter into a contract with us, engage with any of our promotions or otherwise provide us with any personal data.
2.2 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 and a profile picture (if you choose to provide one);
(b) Contact Information, including: your postal address, e-mail address and mobile number, your Applegreen Electric account details, and social media handle;
(c) Vehicle Information, including: your vehicle manufacturer, vehicle model, year your vehicle was manufactured, color 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.
2.3 Personal Data collected when you visit one of our Services
CCTV Data
When you visit one of our EV chargers, we may also process your personal data in the form of video via CCTV. In some instances, this CCTV is operated by a third party and shared with Applegreen Electric. CCTV covers the sites where the EV chargers 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, and for related business purposes. Your vehicle number plate may be recorded at some EV charging bays to prevent unauthorised parking and to investigate accidents and other incidents for these purposes as well as for other purposes which are further outlined at section 3 of this notice, ‘Why and how we use your personal data’.
Location Data
We record the location of our EV chargers when you start a transaction at one of our EV chargers.
2.4 Personal data we collect or generate about you
Service Usage Data
When you use our Services, we will collect, generate, store and use personal data about your use of these products or services. This personal data will include the quantum and value of kWh consumed when availaing of our Services, the time of your charging session, the length of time your vehicle parks in an EV charging bay, the length of time you charge your vehicle, the location of your charging session and the make and model of your vehicle.
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.
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 independent Third-Party Services, and we will not store, save or have access to this location data. We will have access to your location when you start a transaction at one of our EV chargers or when you tell our customer support team where you are.
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.
This personal data 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.
2.5 Personal data we receive from other sources
We may collect personal data from third-party sources, such as other members of our corporate group, vendors, Third-Party Services, and the owners of property on which our EV chargers are located.
3. Why and how we use your personal data
To help you to understand what we do with your personal data and why, we have described the various purposes of processing your personal data, and the categories of personal data associated with each processing purpose, in the below table.
| Purposes of processing | Categories of personal data we use for this purpose |
|---|---|
| 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 account setup validation) and respond to your questions and comments). |
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| To measure how satisfied our visitors and usersof our Services 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). |
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| 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. |
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| 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. |
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| To keep you informed whether it is by email, SMS, push notifications and/or via our Website or App about relevant products and services that we think might interest you including tailored special offers, discounts on EV charging, promotions, events, competitions and so on from us or from our wider group. |
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| To measure or understand the effectiveness of advertising we serve to you. |
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| To carry out market research or similar surveys. |
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| 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. |
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| To notify you about changes to our services and terms and conditions. |
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| 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 EV charging services. |
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| 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. |
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| To prevent unauthorised parking, and to investigate accidents or other incidents. |
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| Sharing relevant information to comply with our obligations under any leases or third party agreements and other contracts for the physical placement and maintenance of our charging stations, including audit provisions of such contracts. |
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Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules and 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.
4. What if you decide not 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.
5. Change of purpose
We will only use your personal data for the purposes for which we collected it, and for purposes that are reasonably necessary to or compatible with such purposes. If we need to use your personal data for such purposes, we will provide you, prior to that further processing, with information about the new purpose. We will explain our legal justification for such further processing and we will provide you with any relevant further information. We may also direct you to a new or updated privacy notice (if required).
6. How we share your personal data
On occasion we may share your data with certain third parties including our affiliates and subsidiaries of the Applegreen group, service providers, business partners, suppliers and sub-contractors, and other parties listed below. The categories of personal data that we share with such parties may include all of the categories we describe in section 2 of this notice, ‘Personal data we may collect from you and how we collect it’.
6.1 Third party suppliers and service providers who 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 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 communications with you.
If we share your personal data with such third parties, we will take reasonable steps to ensure it is kept safe. We take reasonable steps to ensure that these suppliers are bound by contractual standards for the protection of your personal data in accordance with applicable laws and that we provide only the information they need to perform their specific services. We also take reasonable steps to ensure that these suppliers are only permitted to use your personal data in order to provide us with services (and not for their own purposes).
We take reasonable steps to ensure that such suppliers 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 law. We have a practice of contractually obligating our suppliers to ensure that your privacy is respected and protected at all times, including requiring personal data to be deleted, returned to us or rendered anonymous if we stop using their services or if it is no longer necessary for personal data to be retained by them.
6.2 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 and other business operations, which may include marketing. 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.
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.
6.3 Other scenarios in which we might share your personal data
We may also share your personal data:
(a) with government authorities or professional bodies, where required by applicable law or legal processes;
(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); and/or
(f) if our business or a portion of it, 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.
7. How do we protect your personal data?
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. In addition, we have implemented processes to 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, and who are subject to a duty of confidentiality.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure or that it is compromised, or you wish to obtain further information about the data protection measures we take please contact us by using the contact information set out at section 14 of this notice, ‘Contact’.
8. How long do 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, or for purposes that are reasonably necessary to or compatible with such purposes.
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 you with the Services. In most cases, this period is two (2) years after you cease to be an active customer, but it may be up to seven (7) 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 each case subject to ours and third parties’ standard data back-up procedures and to the extent technically practicable.
In some circumstances we may retain and anonymize your personal data so that while it can no longer be associated with you, it can be used for statistical analysis, business planning, and other business and commercial purposes. In this case, we may retain such information for a longer period without further notice to you.
9. 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.
Depending on your state of residence, applicable data protection laws may grant you certain rights in respect of your data, which we explain below. To make a request and for information on our authentication process, see section 10 of this notice, ‘Exercising your rights’. For residents of states without consumer privacy rights, we will consider requests but will apply our discretion in how we process such requests. For residents of states that have passed laws that may apply to us but that are not yet in effect as of the date this privacy notice was last updated (Delaware, effective Jan. 1, 2025 and New Jersey, effective Jan. 15, 2025), we will consider such requests but will apply our discretion in how we process such requests.
Applicable data protection laws may limit the number of times that we are required to take action on your privacy requests. For example, some of the applicable laws allow you to receive information in response to a privacy request free of charge, once per calendar year. If you make additional requests, we reserve the right to charge you for the administrative costs of responding, and will notify you of this as well as an estimated cost prior to proceeding. In addition, if requests from a consumer are manifestly unfounded, excessive, or repetitive, we may charge the consumer a reasonable fee to cover the administrative costs of complying with the request, or decline to act on the request. You may have the following rights under applicable data protection laws:
9.1 Request to confirm whether your personal data is being processed by us.
9.2 Request access to a copy of your personal data that we have collected and retained, in a portable and, to the extent technically feasible, readily usable format.
9.3 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, taking into account the nature of the personal data and the purposes of processing the same. Please note that if you have an account with us, you may be able to correct certain information by logging into your account and accessing self-service features in the account.
9.4 Request deletion of your personal data. You have the right to request that we delete certain personal data that we have collected and retained, subject to certain exceptions which we will explain (if they apply). After we confirm that your deletion request is a Verifiable Consumer Request (as defined in section 10 of this notice, ‘Exercising your rights’), subject to permitted retention exceptions, we will carry out one or more of the following:
(i) permanently erase your personal data on our existing systems with the exception of archived or back-up systems,
(ii) deidentify your personal data, or
(iii) aggregate your personal data with other information. In our response to your request to delete, we will tell you the method for deleting your personal data. Where legal exceptions will apply to your request for deletion, we will tell you which one(s) and will limit retention to the permitted purpose(s).
In addition, we provide functionality within our App to allow you to delete your account, which you can do by following these instructions:
- 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 after which, all historical transactions will be anonymised. You will receive an email confirming the deletion of your account.
9.1 Request to opt-out of profiling in furtherance of certain decisions that produce legal or similarly significant effects. We do not believe we carry out such activities.
9.2 Request to opt-out of the sale of your personal data, which is defined under applicable data protection laws as the exchange of personal data for monetary or other valuable consideration by the controller (i.e., Applegreen Electric) to a third party. We do not believe we sell personal data as that “sell” is defined under applicable data protection laws.
9.3 Right to limit processing of sensitive data. Certain personal data qualifies as sensitive data under applicable laws and, for certain purposes, requires your consent to process and/or the provision of the right to opt-out. However, we do not process sensitive data in a way that would make these rights applicable.
9.4 Request to opt-out of the processing of your personal data for targeted advertising purposes. You can subscribe to e-mail, SMS and push notification marketing communications on our website or via our App. These activities, and the manners in which you can make such an opt-out request, are described in further detail below.
Third-party digital businesses (“Third-Party Digital Businesses”) may associate tracking technologies that collect personal data about you on the Services, or otherwise collect and process personal data that we make available about you, including digital activity information. Giving access to personal data on the Services, or otherwise, to Third-Party Digital Businesses could implicate activities that constitute targeted advertising. Therefore, we will treat such personal data collected by Third-Party Digital Businesses (e.g., cookie ID, IP address, and other online IDs and internet or other electronic activity information) as such, and subject to the opt-out right. In some instances, the personal data we make available about you is collected directly by such Third-Party Digital Businesses using tracking technologies on our Services or our advertisements that are served on third-party sites (which we refer to as “Cookie Personal Data”). However, certain personal data which we make available to Third Party Digital Businesses is information that we have previously collected directly from you or otherwise about you, such as your email address (which we refer to below as “Non-Cookie Personal Data”).
Please note that there are distinct instructions for opting out of Cookie Personal Data and Non-Cookie Personal Data, which we explain further, below.
Opt-out for Non-Cookie Personal Data:
If you would like to opt-out of our processing of your Non-Cookie Personal Data for targeted advertising purposes, please use the methods in section 14 of this notice under, ‘Contact’.
(a) Opt-out for Cookie Personal Data: If you would like to submit a request to opt-out of our processing of your cookie-related personal data for targeted advertising, a tool is available for our app and our website account portal (https://driver.us.applegreenelectric.com/), which you can access in the settings menu to exercise your opt out rights. You must exercise your preferences on each of our websites and apps you visit, from each browser you use, and on each device that you use.
Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again via our cookie management tool.
9.9 Right to appeal
Residents of Connecticut (and, when their states’ privacy laws go into effect, of Delaware and New Jersey) have the right to appeal our decision regarding a request by following the instructions in our response to your request.
If you want to exercise any of the rights set out above, please see section 10 of this notice, ‘Exercising your rights.’
Your additional tracking technologies choices
Third-Party Digital Businesses may use cookies and other tracking technologies (“Tracking Technologies”) to recognize your computer or device and/or to collect and record information about your visits to the Services and other websites over time, so that they can facilitate feature functionality, measure the effectiveness of ads, track page usage and paths followed during visits, and provide interest-based advertisements to you. These companies may provide some of this data to us. If you would like more information about this practice and to know your choices about certain kinds of online interest-based advertising, please visit National Advertising Initiative Consumer Opt Out https://optout.networkadvertising.org/?c=1], Digital Advertising Alliance Your AdChoices : https://youradchoices.com/ ], or AdChoices for your mobile device. Applegreen Electric does not provide any assurances that these third-party tools, programs or statements are complete or accurate. We understand that certain parties offer “Do Not Track” signals, but we do not honor them as there is not a consensus in the industry in relation to the same.
10. Exercising your rights
To make a request, please use the methods in section 14 of this notice under, ‘Contact’. As permitted by the U.S. Privacy Laws, certain requests you submit to us are subject to an identity verification/authentication process (“Verifiable Consumer Request”) as described below in section 10.1 of this notice, ‘Verifying Your Request’. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal data.
Some personal data we maintain about consumers is not sufficiently associated with enough personal data about the consumer for us to be able to verify that it is a particular consumer’s personal data when a consumer request (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that personal data in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. We will use personal data provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave the personal data to us for another purpose. To the extent legally and technologically possible, we will make commercially reasonable efforts to identify personal data that we collect, process, store, disclose, and otherwise use and to respond to your privacy requests.
10.1 Verifying your request
When you make a request, we will verify that you are the person you say you are, or, if you are seeking information on behalf of another person as an agent (see further below), that you are authorized to make the request on their behalf. In addition, we will compare the information you have provided to ensure that we maintain personal data about you in our systems. As an initial matter, we ask that you provide us with, at a minimum, name and email address. Depending on the nature of the request and whether we have the information you have provided in our systems, we will request further information from you in order to verify that you are the consumer about whom we have collected information. The same verification process does not apply to opt-outs of sale, targeted advertising, or profiling but we may apply some authentication measures to avoid answering fraudulent requests. We will not fulfill a request that is not verified (if verification is required), or where we suspect (or have confirmed) fraud.
The verification standards we apply for different types of requests may vary. For more sensitive or consequential types of requests, we may require more information from you, and may ask for a signed declaration, under penalty of perjury, that you are the individual whose personal data is the subject of the request.
10.2 Authorized agent/parent/guardian/conservator
Depending on where you reside, you may have an authorized agent or court appointed guardian/conservators submit a consumer request on your behalf by submitting a request in the manners described above. Connecticut law does allow parents of children under 13 to submit requests on the child’s behalf, but we do not collect personal data from children under 13. If you are an authorized agent, guardian, or conservator who would like to make a request, U.S. Privacy Laws require that we ensure that a request is a Verifiable Consumer Request, as applicable, and allows us to request further information to ensure that the consumer has authorized the agent, guardian, or conservator to make the request on their behalf. Generally, we will request proof that the consumer gave the agent signed permission to submit the request, and/or court order showing guardian/conservatorship, and, as permitted under the U.S. Privacy Laws, we also may require the consumer to either verify their own identity or directly confirm with us that they provided the agent permission to submit the Verifiable Consumer Request.
Notwithstanding anything to the contrary, we may collect, use, and disclose your personal data as required or permitted by applicable law and this may override your rights under U.S. Privacy Laws. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
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 United States and may be processed elsewhere, including in the European Economic Area (EEA), United Kingdom (UK), or Israel.
Where your personal data has been transferred to companies within the Applegreen group or to other authorised third parties located outside of the United States, we will ensure that we take the necessary steps to protect your personal data as required by applicable data protection laws.
12. Third-party websites
Our Website or App may, from time to time, contain links to, embed the functionality of, or otherwise utilize Third-Party Servcies, including X (formerly known as Twitter), Facebook, Instagram, LinkedIn, Applegreen.com, Apple Maps, 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 and Applegreenstores.com. While this site is operated by an Applegreen group company, personal data submitted to this website is not processed by Applegreen Electric. Applegreen.com has a separate and distinct privacy policy (available https://applegreenstores.com/privacy-policy/), which you should review before you visit that separate site or otherwise submit any personal data to that site.
13. 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. When we update or amend this privacy notice, we will update the Effective Date of the policy or provide notice to you on the Services, or in a manner required by applicable laws. We may also notify you about the processing of your personal data in other ways from time to time (such as at the point of collection).
14. 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 available to residents of certain states set out in section 9 of this notice, ‘Your rights in connection with your personal data’, please contact us using one of the methods below.
Email: DataProtection@petrogasglobal.onmicrosoft.com
Post: Data Protection Officer, Applegreen Electric, Unit 17, Joyce Way, Parkwest, D12F2V3, Ireland