We value your right to privacy and make every effort to protect your personal data in accordance with the applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") and any relevant national implementing legislation or regulation.

In this Privacy Policy, we want to inform you in clear terms about what personal data we collect from you, for what purposes we will process this data, the legal basis for this processing, to whom your personal data may be transferred, how long we will retain your data, how we will protect your data and which rights you have with regard to the processing of your personal data.

1. Who are we?

EEVEE BV is a limited liability company incorporated under Belgian law, having its registered office at Watertorenstraat 2, 3590 Diepenbeek, Belgium, registered with the Crossroads Bank for Enterprises under number 0747.470.815 (hereinafter “EEVEE”, “we”, “us” or “our”).

We provide 1) to users like you a mobile application EEVEE App (including EEVEE Mobility for Cars) which is a driver app to handle electric charging costs and 2) to our fleet customers a platform EEVEE Business Web Platform which is a platform to manage the charging costs.

Towards you, the EEVEE App user, we qualify as the data controller (within the meaning of the GDPR) with respect to your personal data. In the event you are a fleet driver part of our fleet customer, that fleet customer is responsible to make the necessary arrangements with you about the use of the EEVEE App.

2. Whose personal data/Personal Information do we collect?

In the context of our business (as described above), we process personal data or personal information of a) persons who use our EEVEE App (including EEVEE Mobility for Cars), b) persons who subscribe to our electronic newsletter, c) visitors of our website, and of d) contact persons of our suppliers and others commercial partners. For the purpose of this Privacy Policy, “Personal Data” and “Personal Information” are used interchangeably and will have the meaning as set out in the GDPR.

3. What personal data/Personal Information do we collect?

We may collect the following personal data/personal information about you insofar as this information is relevant for the purposes for which we need it, as explained under title 4 below. Anytime certain information is mandatory and other information is optional, this shall be clearly indicated as such, so that you can choose whether or not to provide us such information.

Identification and contact information

• Personal identification data: name, surname, email, home address, work address
• Electronic identification data: information collected via cookies (read our cookie policy)

Financial information

• Identification data and bank account numbers
• Financial transactions: amounts that you have to pay and have paid, overview of the payments, etc.
• Agreements and settlements

Consumption

• Information from the account of your electric vehicle:
  • Vehicle name, brand and model
  • Vehicle build year
  • Vehicle battery capacity
  • VIN number
• Vehicle status:
  • Battery percentage
  • Range
  • Mileage
  • Fuel level and range
  • Battery level and range
  • Charging status
  • Charger type
  • Charging time remaining
  • Charge limit
  • Charging power
  • Energy charged
• Charge Pass (if applicable)
  • ID number
  • Status
  • Timestamps
• Charging session information
  • Timestamps
  • Duration
  • Address
  • Coordinates
• Other categories of data
  • Energy consumption
  • Other personal data that you actively provide, for example by creating a profile on our EEVEE App
  • License platee

4. For what purposes do we use your personal data/Personal Information?

We use your personal data for the following purposes:

• to offer and improve our services;
• to offer you a free trail (not in case you are a fleet driver);
• for marketing purposes (if you had subscribed to our electronic newsletter).
• to react to your request for a quote (not in case you are a fleet driver);
• for customer and supplier management;
• for the management of our website;
• for load balancing initiatives;
• for the management of (invoice) disputes and claims;
• for the handling of consumer inquiries and complaints;

For your information, you can find hereinafter the legal grounds applicable to these processing activities:

• for the processing of your personal data for the delivery of services and for the follow-up on sales and invoicing, to provide you with certain information with respect to the purchased service (not in case you are a fleet driver), in the context of customer complaint handling, if you request a free trail (not in case you are a fleet driver) or if you request a quote (not in case you are a fleet driver), we rely upon the necessity for the performance of a contract;
• in all other cases and only if you are not a fleet driver, the processing of your personal data is based on our legitimate business / commercial interests (i.e. the interest of obtaining information about the preferences of customers in order to establish marketing strategies);
• for the processing of your personal data for electronic direct marketing purposes (sending our electronic newsletter), we rely upon your opt-in consent. Only if you have unambiguously stated that you would like to (i) partake in the load balancing initiative in order to prevent grid net overload, your (PH)EV will be connected to this service, and/or (ii) receive our electronic newsletter (you are entirely free to do this), we will register you for our electronic mailings;
• in case you are not a fleet driver, we use for direct marketing of similar products or services the soft opt-in exception under art. 13(2) of the ePrivacy Directive, which allows us to send these communications when your contact details were obtained in the context of our service and you have the ability to opt out at any time.

Note that you have the right to withdraw that consent at any time, free of charge, and without this having any negative implications for you. You may do so by e-mail (see below) or via the opt-out link included in each of our marketing mailings.

5. With whom do we share your personal data/Personal Information?

We may disclose your personal information to the following parties:

• With our service providers who act as our ‘processors’: In the context of our activities as described above, we may share your personal data with third parties, in particular with service providers (IT/cloud service providers, PR/marketing agencies who organise mailing campaigns for us, sales service providers or creative agencies) that act as our ‘processors’.
• In case you are a fleet driver and if applicable, to provide certain home charging services (including the reimbursement) and ensure that charging sessions are correctly allocated and billed, certain data is shared with your employer (or another organisation that has contracted our services). This includes information required for invoicing, such as your vehicle identifier, charging session details (location, duration, consumption), and the costs associated with each session.
• With our professional advisors such as external law firms and accountants.
• With government authorities such as the government, police authorities or the judiciary in case we have a legal obligation to do so.

We will not transfer non-anonymised personal data to categories of recipients other than those listed above without your prior consent, unless we are required to do so by applicable law. We will implement appropriate safeguards when transferring your personal data to third parties. If necessary, we will for example conclude a data transfer or a processing agreement specifying the limitations to the use of your personal data and the obligations with respect to the security of your personal data. Your personal data will not be lent or sold to third parties for marketing purposes without your prior explicit consent. Your personal data will not be sent outside the European Economic Area unless this is required to deliver the Services. If such a transfer is needed, we work with third parties located either in countries that the European Commission has already recognised as offering adequate protection, or, where no adequacy decision exists, we ensure that appropriate safeguards are in place so your data receives a level of protection that is equivalent to EU standards.

6. How long do we store your personal data/personal information?

Your personal data will not be stored for longer than is necessary in relation to the purposes for which we process them (as listed above). Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed in a file. More specifically, the following retention guidelines are applied by us:

• personal data included in accounting, financial or other official documents will be retained for as long as such documents legally need to be kept;
• personal data required for the execution and follow-up of a contractual relationship will be kept for the entire duration of that relationship and for 10 years following termination thereof;
• personal data obtained by your request for a free trail or a quote will be kept as long as needed to fulfil your demand;
• personal data obtained in the context of complaint handling will be deleted (or anonymised) as soon as the complaint is closed; and
• any personal data used for marketing purposes will be retained for as long as we are sending you relevant mailings and for a maximum of 1,5 years thereafter. As soon as we note that your contact details are no longer accurate or active, or whenever you decide to use your right to unsubscribe, we will no longer keep your personal data for these purposes,
• regarding the data of visitors to our website, we refer to our Cookie Policy.

Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings (e.g. in case of a dispute), we will store the personal data for longer periods. More information on our retention periods is available upon simple request.

7. How do we protect your personal data personal information?

We will implement the necessary administrative, technical and organisational measures for ensuring a level of security appropriate to the specific risks that we have identified. We protect your personal data against destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed. Further, we seek to ensure that we keep your personal data accurate and up to date. In view thereof, we kindly request you to inform us of any changes to your personal data (such as a change in your contact details). More information on our protection measures is available upon simple request.

8. What are your rights and how can you exercise them?

Within the limits defined by articles 15-22 of the GDPR, you have the following legal rights with respect to your personal data:

• Right of access: you have the right to obtain confirmation from us as to whether or not we are processing your personal data, to obtain access to that personal data and how and why they are processed, as well as to receive a copy of that data.
• Right to rectification: you have the right to obtain a rectification of your personal data or to request that we complete your personal data if you notice that we are processing incorrect or incomplete data about you.
• Right to erasure (‘right to be forgotten’): you have the right to obtain data erasure in certain specific cases.
• Right to restriction of processing: You have the right to have the processing of your personal data restricted in certain specific cases.
• Right to data portability: you have the right to obtain the personal data that you have provided to us, in a structured, common and machine-readable form, and to transfer those personal data (or have them transferred) to another data controller.
• Right to object: you have the right to object to the processing of your personal data on the basis of our legitimate interest for reasons relating to your specific situation.
• Right not to be subject to automated individual decision-making: EEVEE will not use automated decision making and/or profiling when processing your personal data.

You can exercise the aforementioned rights by sending us an e-mail to privacy@eeveemobility.be or contact us via the EEVEE App.

The exercise of these rights is in principle free of charge. Only where requests are manifestly unfounded or excessive we may charge a reasonable fee. We aim to respond your requests or questions as quickly as possible and at least within 30 days.

Finally, you also have the right at any time to lodge a complaint with the Belgian Data Protection Authority in connection with the processing of your personal data by us. You can reach the authority via contact@apd-gba.be or by regular mail at the following address: Gegevensbeschermingsautoriteit Drukperstraat 35 1000 Brussel Belgium.

9. Changes to this privacy policy

From time to time it may be necessary to change this Privacy Policy. When we post changes to the policy, we will change the date of the "latest update" at the top of this Privacy Policy. The most current version of this Privacy Policy will be available on our website at all times.

10. Contact

If you have any questions or concerns about EEVEE’s Privacy Policy or the processing of your personal data by us, you may contact our Data Protection Officer, us via e-mail to privacy@eeveemobility.be or via the EEVEE app itself, or by regular mail to: EEVEE BV, Watertorenstraat 2, 3590 Diepenbeek, BELGIUM.

11. Cookies

For more information about EEVEE’s use of cookies, check https://legal.eeveemobility.com/cookie-policy.

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