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Privacy Policy
1. Introduction
Our mission at ev.energy is to deliver simpler, cheaper and greener electric vehicle charging for everyone. We do this by controlling your car or your charger to shift your charging to match lower cost and lower carbon energy within the constraints of the grid.
We need to collect some personal data from you, but we promise at all times to only capture the minimum amount of information required to offer our services and to help you. We will treat your personal data as if it were our own, keeping it safely and securely, never keeping it longer than is necessary and only sharing it with your knowledge, permission or if we are required to do so by law.
This policy outlines the details of how we use your information and also some small print which you need to know, and we are required to provide by law.
Just so you know, EV DOT ENERGY LTD is registered in England under company number 11468310, and its subsidiaries including EV.ENERGY CORP, are collectively known as ev.energy (or also just ‘us’, ‘we’, ‘our’). We are registered with the UK Information Commissioners Office (ICO) under registration number ZA464860.
This privacy policy applies to this website and the services offered by ev.energy be that via the ev.energy platform or the ev.energy app, which you can download in the App Store and Google Play.
We also offer our services via other companies under their branding. This policy also explains how our partners may use your information. For ease of reference, we shall refer to any service we offer directly or via a partner as the “Service”.
2. Service and reason for processing your data
We provide software to electric vehicle owners (collectively known as “Users”) through an app, platform and website (the “Service” we provide). This Service offered by ev.energy intended for use as is.
The personal information that we collect enables ev.energy to:
- Deliver and improve the Service;
- Support you to use the Service;
- Work with your energy company or DSO to deliver the Service; and
- Provide enhanced services and rewards to you (in partnership with third-parties).
Before using the Service, ev.energy will ask for your consent before we process your data. We only collect the personal data required to enable us to deliver and support our Service to you.
A full list of the personal data we collect is in Section 3. There may be certain aspects of the ev.energy service, which we deliver in partnership with third-parties. We will only share personal data with third parties with your consent. We will always explain to you why we are sharing your personal data, our relationship with the third-party and how your data will be used. Please see Section 6 for a full list of the data we share.
3. Personal data we collect
To deliver our service, we may collect personal data, including but not limited to:
- Identity and Contact Data about you and how to contact you.
- Profile and Consent Data which comprises preferences (for marketing and other notifications), feedback and survey responses you have provided and partly anonymised analytical information about how you use our app.
- Hardware Data about your electric vehicle and charger so we know when to smart charge and can control charging.
- Energy Data such as your energy supplier, tariff and meter reference number so we can apply the right tariff and grid information to your supply, and so (with your consent) we can identify smart charging to third-parties.
- Third-Party Account Data which allows us to link your ev.energy account to your vehicle, charger or energy supplier accounts.
- Technical Data about the device you use to connect to our platform, your time zone and locale to enable us to tailor the user experience for your device and to ensure we support the devices you want to use to access the app and platform.
- Transaction and Financial Data about your energy usage and for any services you purchase through the platform
- Tracking Data which includes information we or others collect about you from cookies and similar tracking technologies such as web beacons, pixels and mobile identifiers.
For more detail on the specific data within any of these categories, please see Appendix A.
The information that we request will be used and retained by us and only shared with third parties where it is necessary to provide the service to you, and then only as described in this privacy policy. We do not use your data for any automated decision-making or profiling.
We may use, collect, and share aggregated data with third-parties. Aggregated Data may be derived from your data, but, as this data does not directly or indirectly reveal your identity, it is not considered personal data in law. For example, we may aggregate your and other users’ Electric Vehicle Data to help utilities plan their charging networks.
4. Log data
Whenever you use our service, we collect some usage and log data. For example, in the case of an error in the app, we log information about the error to help us fix the error and stop it happening again in the future.
This Log Data may include the information listed under ‘Technical Data’ in Section 3 and Appendix A, as well as the time and date of your use of the Service and configuration specific to your user account or profile.
5. Cookies
Cookies are one of the most widely used technologies on the internet and many essential website functions are dependent on their use. Cookies and other online tracking technologies are small pieces of data or code which contain user IDs that are automatically saved onto your computer or device when you visit a Website. These are used to identify your devices when you use and interact with our Website to personalise your experience. For example, they are often used to remember you are logged in, or to remember your preferences.
We use cookies and similar devices to facilitate your browsing on our website, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits. You should now read our Cookie Policy. to understand this in more detail.
6. Providing your personal data to others
There are several reasons why we may share your data with other parties to enable us to deliver our Service to you.
6.1 Sharing your data to deliver and improve our Service
To provide our Service to you, ev.energy uses selected third parties to provide you with the service, and shall share some information with them, under strict confidentiality obligations, to provide you with the services.
Our service providers include:
- Amazon Web Services, to enable us to run our cloud-based platform (Privacy Policy).
- Freshdesk, to help provide customer support to you (Privacy Policy).
We may additionally ask for your permission to share your personal data with your electric vehicle manufacturer and/or your charger manufacturer, to enable us to deliver our Service to you, and obtain Electric Vehicle Data, Account Data and Transaction from your car or charger manufacturer.
For more information on our service providers, links to their policies and their location, please see Appendix B.
6.2 Sharing your data to support you as a customer
If you require support from ev.energy, ev.energy may share your personal data with suppliers and subcontractors to help resolve this issue. The data will include the nature of the query and any data supporting that, which may include Identity and Contact Data, Technical Data, Hardware Data as defined in Section 3.
We will only share the information where it is necessary to allow us to be able to provide those products and services to you.
6.3 Sharing your data to provide enhanced services and rewards
We may offer you enhanced services and rewards (e.g. smart charging rewards), which may be delivered in partnership with third-party providers.
For example, our smart charging rewards program is partially funded by energy networks and energy service companies to provide services to support the electricity grid whilst you charge your electric vehicle.
To confirm eligibility for these services, we may share Energy Data and Contact Data about you (specifically your postcode, the first line of your address, your meter identification number and your energy usage) with these third-party energy companies:
- Electricity network companies, who deliver the electricity network in your local area;
- Electricity market operators who help balance the grid on behalf of energy generators, network companies and consumers; and
- Energy service providers who provide aggregation or access services to energy markets.
For more information on which companies we partner with and where they are based, please see Appendix B.
We may also share your email address and contact details to enable us to deliver an enhanced service and/or reward to you (e.g. send you a reward card from a well-known coffee chain).
If you change your mind, you can opt-out of any of our services or enhanced services at any time. If you are unsure how to do this, please reach out to our customer support team.
Our US visitors and users should be aware that ev.energy is compliant with and understands its responsibilities under the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM Act).
6.4 Sharing your personal data with your energy company or DSO
We may work with your energy company or DSO to deliver our Service to you and may share your personal data with them, subject to the contractual relationship you have entered with them.
6.5 Sharing your data for legal reasons
Usually, we will only share personal information with your consent; however, we will share personal data where we have a legal obligation to do so; for example when directed by a court, or if requested with an appropriate warrant by law enforcement or tax agencies.
We may also share information without your permission where a person’s life is in danger and to instigate or defend a legal claim, for example, with a solicitor, our professional advisors, or a court.
6.6 Sharing your data for other reasons
We may share anonymised data with energy companies, DSOs and other Third Parties. The information transmitted is anonymised, which means no personal information about you is provided and location data is obfuscated to a larger area (such as a neighbourhood, or a position to within 100m to suitably ensure anonymity). Consequently, a third-party will not be able to identify you from any data shared directly from ev.energy.
On our site and in our app, with your consent, we may advise you of third-party goods or services which may interest you. If you give your permission, we may share your enquiry data with one or more selected third-party suppliers of goods and services identified, so that they can deal directly with you.
We may employ third-party companies and individuals to help us deliver and improve our Service to you.
We will take all reasonable precautions to ensure that any third party who processes your personal information on our behalf does so lawfully, commits to keeping your personal data both safe and secure, and will not share it with any other parties without our explicit permission. All third-parties will undergo a due-diligence assessment and a written agreement with specific terms around data security and privacy is in place.
7. Third-party websites and links to other sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. We do not operate these external sites and we therefore strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
8. Retaining and deleting personal data
We will retain your data no longer than is required, as per data protection laws. We will keep data relating to your continued usage of our service and programmes for as long as you remain a customer and then for a period of time following cessation of use of the ev.energy service unless you exercise your ‘right to erasure’ and we have no overriding grounds to retain your personal data. Occasionally, there will be ad-hoc consideration to delete data we no longer require.
There may be circumstances in which we cannot delete some personal data where we have a legal requirement to retain it, such as participation in a Flexible Grid Services project. If you have any questions or want to know more about the data we are unable to delete, feel free to contact us using the details provided below.
Users can initiate account deletion, i.e. exercising their right to erasure, in our app by heading to ‘Settings’ -> ‘Account’ then pressing ‘Close my account’.
The longest ev.energy will retain your personally identifiable information is seven (7) years from the date you last used our Service to ensure compliance with legal obligations. Anonymized statistical data regarding the use of the app, services and charging activity will be kept indefinitely but will have no personal data associated with this information.
9. Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
The primary data store for all data in our platform is within the EU. To enable us to attract the best and most diverse talent, and deliver support around the clock, our employees are based worldwide. They can access the data which is stored in the EU but only under strict access controls. For a detailed list of our service providers, their privacy policies and where they are based, please see Appendix B.
We encrypt all data within our systems at rest. For services provided by third parties (such as those listed in Appendix B), we ensure that, at a minimum, confidential and financial data (such as passwords and cardholder data) are encrypted at rest, and access to all data are encrypted in transit.
Only secure access (such as HTTPS or WSS) is possible to the ev.energy platform. We send all information to the app securely, protected by encryption, to your device. Additionally, where data are accessed directly on our platform by third-parties, access to your data is secure, encrypted and logged.
We will take every precaution to protect your personal data once in our care; however, the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent by you or us over the internet. We value your trust in providing your personal data to us, and we will use all reasonable and commercially acceptable means to protect it. Still, unfortunately, no method of transmission over the internet, or method of electronic storage is 100% secure and reliable.
To help protect your account and personal information, you should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential, and we will not ask you for your password (except when you log in to our platform). The ICO has some great advice for protecting your information online.
We won’t ask you to share sensitive information either, such as bank details, for the purpose of verifying your identity. If anyone purporting to be from ev.energy does ask for sensitive information, then please contact us using the details provided below.
10. Lawful bases of processing your information
ev.energy processes information on electric vehicle charging behaviour. We use this information to provide services to third-party energy, charging and automotive companies that enable those third-parties to monitor and control electric vehicle charging.
When you download our app, sign up to either our Service, or a Service that we deliver on behalf of one of our partners, ev.energy will ask for your explicit consent to capture, process and share your information. We will also ask for your permission to share your login details with third-party energy companies and energy information providers to verify which energy rate plan or tariff you are using.
You may hear about ev.energy from your electric vehicle charger installer or dealership, and they may provide your contact details to us after asking for your consent. We will rely on this consent provided to your installer or car dealer to tell you about our Services.
It may be necessary to share charging data, invoice details and other energy data with third parties, and we will process this data under our contractual obligations to either yourself or your energy company. We may share your data under our legal obligations or where a person’s life is in danger, as outlined in Section 6.5.
11. Your rights
You have the following rights concerning your personal data:
The right to be informed – an obligation on us to tell you what we do with your personal data (which we do in our software and via this privacy policy) and we shall inform you if there is a serious breach of your personal data which would result in a high risk to your fundamental rights and freedoms.
You have the right to be made aware of any automated decision-making, made without any human involvement, or profiling of your personal information by ev.energy. Currently, we don’t use any automated decision-making.
The right of rectification – an obligation in certain circumstances to correct your personal data if it’s inaccurate or incomplete.
The right to erasure – an obligation in certain circumstances to delete or remove your personal data where there is no compelling reason for its continued processing (some jurisdictions also call this right ‘the right to be forgotten’). In some cases we are legally required to retain some personal data about you, for more information on exemptions on the right to erasure, see this information from [ICO: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/#ib6]
The right to restrict processing – an obligation in certain circumstances to stop actively processing your personal data.
The right to data portability – an obligation in certain circumstances to allow you to transfer your personal data from us to a third party.
The right to object – an obligation in certain circumstances to allow you to object to us processing your personal data where we do not have an overriding reason. You also have an absolute right to object to use of your personal information for direct marketing purposes.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
The right of access – a right to be told what personal data we hold about you and obtain a copy of that information.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you ask for a copy of your personal information we will need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights), to ensure that we do not disclose personal data to any person who has no right to it. We may also contact you to ask you for further information concerning your request to speed up our response.
We have included ways to contact us in S. 18 of this privacy policy should you wish to exercise any of your rights listed here.
We try to complete all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you informed of how we will deal with your requests.
If you have made an enquiry directly to us and we have not dealt with it to your satisfaction, you have the right to complain to the supervisory authority responsible for data protection in whichever state or country you reside. The data protection authorities in the European Union are here. In the UK, this body is the ICO, and in Australia, this body is the Office of the Australian Information Commissioner.
12. Representation for data subjects in the EU
We value your privacy and your rights as a data subject and have appointed Prighter as our privacy representative and your point of contact if you are based outside of the UK. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/14389734305
13. Job applicants’ privacy
Information we collect about you
In order to process your application, we ask you to provide certain personal data, also referred to as personally identifiable information (PII). The legal basis for processing your PII is by consent and therefore providing it is voluntary, however, some are required for us to properly consider your application. If you were not successful in your application, we will keep a copy of it for a period of 6 months from the closing date of the role you have applied for.
We may collect, store, and use the following categories of information about you during the application phase:
- Personally Identifiable Information: We collect your personal contact details such as name, address, email address and telephone number. We also collect contact information for your references; it is your responsibility to obtain consent from your references before providing their personal information to the ev.energy.
- Sensitive Data: We ask you not to disclose any sensitive personal data during the application phase as we do not feel this required.
- Internet or Other Electronic Network Activity Information: Our website uses cookies, which you can read more about at https://ev.energy/cookies
Application subprocessors
We use third party service providers to assist with our application procedure and only share data where appropriate measures are in place to protect the security of your data. This list isn’t designed to be exhaustive, but is indicative of the types of services we engage to assist us in hiring new talent:
- Application Management Systems: Freshteams
- Talent Acquisition Consultants: People Club Ltd and Motive Group
We would like to take this opportunity to remind you of your rights under S. 11 of our Privacy Policy and should you wish to exercise any of these, please feel free to contact us via our support form or contact us using the details in the contact us section below.
14. Children’s privacy
These Services do not address anyone under the age of 16. We neither target, or knowingly collect personally identifiable information from children under 16. In the case we discover that a child under 16 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to perform the necessary actions.
15. Third-party users
There may be occasions when a third-party who has not agreed to our terms of use or privacy policy will interact with our service, either by way of an integrated vehicle or an integrated charger. It is the responsibility of the account holder to ensure that third-parties are made aware of the integration prior to interacting with our service
16. User Research
ev.energy undertakes regular user research in order to guide the development of the platform. The data collected will only be used for research purposes and never sold to third parties. We occasionally work with third parties to improve green technology services, but we will always notify you of our partners in advance. We record the user interviews to enable post-review, however these are deleted as soon as they are no longer relevant or after a period of three years (whichever is soonest). If we transcribe your interview, then we will retain this following the expiry of three years, however we will anonymise all personally identifiable information. We will, at all times, keep research source materials secure.
17. Changes to this privacy policy
This is version 2.3.0 of the ev.energy privacy policy, effective from 11th April 2022.
We may update our Privacy Policy from time to time. We advise you to review this page periodically for any changes. These changes are effective immediately after they are posted on this page.
Changelog
- V2.3.0 was released 11th April 2022
- Clarified data types under Appendix A
- Updated subprocessors in Appendix B
- Added sections on data retention, third party users, and user research
- Added Appendix for California residents only
- 2023.2.15 Moved to new date-based version number, removed changelog from before April 2022, updated Contact Us information and added additional Energy Companies under Appendix B.
- 2023.3.30 Included additional Energy Companies under Appendix B.
18 Contact us
If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact our DPO by email: privacy@ev.energy. You can write to our DPO at the address listed on our ICO registration marked for the attention of “ev.energy DPO”.
If you are within the EU, you can also contact us via our representative Prighter here: https://prighter.com/q/14389734305.
Appendix A
Not all of the below data is personal data nor is it all relevant in every use case, however our aim is to be transparent in how we process data in the course providing a service to our users
Identity and Contact Data
- First name and last name
- Your username or similar identifier in the ev.energy platform
- An encrypted version of your password
- Your social media username (if you interact with us via social media)
- Your home address, e-mail address(es) and telephone number(s)
Profile and Consent Data
- Your preferences on how and when we can contact you
- Preferences on your subscriptions to digital marketing and non-marketing communications
- A record of where you have provided or withdrawn consent to share your data with third-parties
- Feedback to surveys and questionnaires delivered via e-mail and in-app
- Feedback provided during design research programmes (which may be anonymised or semi-anonymised)
- Partly anonymised data from app analytics platforms such as Google Analytics which show an aggregated view of how you use our apps and platform
Hardware Data
- The make, model, trim, registration or licence and VIN of your vehicle
- The battery size and charging capabilities of your vehicle
- The make, model and configuration of your charger
- The state of charge of your vehicle
- The location of your vehicle and charger
- If your vehicle and charger are connected
- If your vehicle is charging
- If your vehicle is in a manufacturer service mode
- If your vehicle is stationary
Energy Data
- Your energy supplier name and price plan or tariff name
- Your home energy consumption (typically just your EV consumption, but this may include your overall home consumption)
- Billing information about your supply such as your energy supplier account number
- MPAN or Meter Serial Number
Third-Party Account Data
- Encrypted username and password or access token for a third-party service kept in a secure enclave
- Account identifiers or references to identify your account in a third-party’s system
- These data will only be requested and stored after you have provided consent
Technical Data
- Connection information such as IP address
- Device geolocation
- Client information such as the type and version of the device, operating system, browser and any plugins you may be using
- Your time zone and locale
Transaction and Financial Data
- Details of the products and services you have purchased from us
- Details of how much energy used to charge your electric vehicle, and when this charging happened
- Payment information made to us from you, including references to your account stored in our payment providers’ system
Tracking Data
- Includes information we or others collect about you from cookies, user attribution and similar tracking technologies
Appendix B
This list is updated periodically and therefore may not be exhaustive, but remains indicative of the type of partners we engage to help us provide our Service. We will always notify users where a material change in processing takes place.
Direct service providers to ev.energy
| Name | Region |
|---|---|
| Adjust, GmbH | EU |
| Agorapulse SAS | EU |
| Allstar Business Solutions | UK |
| Amazon Web Services | EU |
| Braze Inc. | EU |
| Codibly | EU |
| Datadog | USA |
| Enode.io | EEA |
| ev.energy Corp | USA |
| Freshdesk | EU |
| Freshteam | USA |
| GoCardless | EU |
| EU | |
| Iterate | USA |
| Loom App | USA |
| MailGun | EU |
| Microsoft | EU |
| Monday | Israel |
| Notion | USA |
| Otter.ai (not EU or UK users) | USA |
| Redash.io | EU |
| Slack | EU |
| Smartcar | USA |
| TypeForm | EU |
| Zapier | USA |
| sentry.io | USA |
Energy suppliers & utility partners
| Name | Location |
|---|---|
| AGL Energy Limited | Australia |
| Alabama Power | USA (Alabama) |
| Con Edison | USA (New York) |
| Electric Ireland | Republic of Ireland |
| ESB Ireland | Republic of Ireland |
| El Paso Electric | USA (Texas) |
| Elli | Germany |
| E.ON UK plc | UK |
| EWE AG | Germany |
| Hawaiian Electric | Germany |
| Madison Gas & Electric | Germany |
| Marin Clean Energy | USA (California) |
| National Grid | USA |
| Nova Scotia Power | Canada |
| Peninsula Clean Energy | USA (California) |
| PG&E | USA (California) |
| O&R (Orange & Rockland) | USA (New York) |
| Silicon Valley Clean Energy | USA (California) |
| Verbund | Austria |
| United Illuminating | USA (Conneticut) |
Distribution systems operators and network partners
| Name | Location |
|---|---|
| AusNet | Australia |
| National Grid | UK |
| Scottish and Southern Electricity Networks | UK |
| SP Energy Networks | UK |
| UK Power Networks | UK |
| Western Power Distribution | UK |
| Electricity North West | UK |
| Northern Power Grid | UK |
| Flexitricity | UK |
| Piclo | UK |
| NODES | UK |
| ELEXON | UK |
| MP2 Energy | USA (Texas) |
| Leap Energy | USA (Texas) |
Residents of California Only
ev.energy will share your data for purposes allowed under the CCPA and in accordance with the law of the State of California. We will periodically update this list to ensure that we are transparent with how we handle your data. If you want to opt out, email us at support@ev.energy.
| Name | Location | Data Shared | Purpose |
|---|---|---|---|
| 3Degrees Group, Inc | USA | VIN; Charging Logs | Claiming LCFS credits from CARB |