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ZPN Energy Privacy Policy  

How Your Personal Information May Be Used
Use of personal information under UK data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy. An explanation of the scope of the grounds available can be found here.

The main uses of your information are:

Customer Support and Marketing – to respond to enquiries and to bring you news and offers.

ZPN® uses your personal data for customer care and for personalised communications of ZPN® product and service information, with your consent where necessary. For these purposes, ZPN® may transmit this data to authorised distributors or agents and other authorised companies.
In order to ensure that you receive relevant and personalised communications, we will use some of your data to create an individual customer profile and we may share your personal data between ZPN® companies, authorised distributors, agents and other suppliers of ZPN® branded products and services where relevant. This may include data you have provided to these companies, or which is generated by your use of ZPN® products, for example, contact details, preferences, customer history, vehicle usage data, app usage and online behaviour.

ZPN® Sales & Services – to process your sale, configure and supply charging services electric vehicles

ZPN® will obtain Contact Details, Site Configuration Details, Vehicle Technical Information and Sales and Services Information when you engage with us as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your contract.

This information may be accessed by ZPN® or its agents to troubleshoot technical or other issues relating to the delivery of these services.

The above-mentioned controllers may also receive limited Vehicle location information during the maintenance process which will be used only in accordance with location information safeguards.

EVIE™ – to provide and perform digital services in the vehicle.

ZPN® receives information from these digital services, such as:

The ZPN® Electric Vehicle Information Exchange [EVIE] protocol may collect Contact Details, Vehicle Location Information as well as Device and Service Usage information which ZPN® use in accordance with the detailed service descriptions for each element of the services set out in the EVIE services policy.

ZAPME™ APP – to provide digital and charging services relating to the vehicle through a mobile device.

ZPN® may obtain Contact Details, Device and Vehicle location information as well as Device and Service Usage information through the provision of the ZAPME APP which it uses in accordance with the privacy policy and location information safeguards.

Compliance with legal requests for your information – to comply with our legal obligations to law enforcement, regulators and the court service.

We may be legally required to provide your information to law enforcement agencies, regulators, courts and third party litigants in connection with civil or criminal proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or we may notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Legal Grounds For Processing Of Your Personal Information
The use of your information set out above is permitted under UK data protection law on the basis of these principal legal grounds:

Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time through the ZPN® Information Centre

  1. Call on 0800 0096 208 (calls are free of charge plus your phone company’s access charge
  2. Sending an email to info@zpnenergy.com
  3.  by writing to us at: ZPN®, THE PROVING FACTORY, GIELGUD WAY, COVENTRY CV2 2SZ

Where necessary to enter into or perform our contract with you or provide services

Where we need to use it to comply with our legal obligations

Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting ZPN® business and tailoring news to your information supplied, research and development of electric vehicle related products and services, detecting fraud and criminal activities).

There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it to you as soon as possible after becoming aware of the new basis.

Third Parties To Whom We May Transfer Your Data
Personal information which we collect may be transferred to or accessed by third parties on our behalf, with your consent where necessary. The types of third parties apart from ZPN® are:

  1. Marketing and research companies who run and manage marketing and research campaigns
  2. Event companies who run and manage sponsored events
  3. ZPN® customer support
  4. ZPN® distributors or agents who provide services to you
  5. IT providers who provide us systems and services for customer support
  6. Card Payment Services providers who operate payment platforms
  7. Logistics and courier companies who may transport items to you
  8. Companies who provide transport to you or offer you mobility services (e.g. private hire drivers)
  9. Law firms who provide legal advice to us (e.g. where there is a customer dispute)

This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement. ZPN® may also transfer your personal information to a third party without your consent if it is in its legitimate interest or if there is a contractual obligation to do so. For example, ZPN® may pass on your personal details to a third party debt recovery agent if you fail to make the payments.

Who May We Share Your Information With
ZPN® is a multi-national company. Your personal information may be accessed by our staff, agents or contractors from a country outside the European Economic Area (EEA) for any of the purposes set out in this policy. These countries may have in place data protection laws which may be of a lower standard than in the EEA. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.
Certain countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing essentially equivalent protection to EEA data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.
How Do We Collect Your Personal Information
These are the main ways we collect your information:

  1. If you contact us directly via our websites or via our customer hotlines to request information about our products and services
  2. If you buy a product or service directly from us
  3. If you reply to our direct marketing campaigns
  4. If your contact details are transferred from authorised centres or other third parties
  5. If your vehicle data (incl. vehicle identification number) is transferred to ZPN® while you are having your vehicle charged or you are charging it at home
  6. If other ZPN® legal entities or business partners transfer your personal data to usIf we acquired your personal data from other sources, for example social media sites
  7. If you give information on behalf of someone else you must ensure that you have their permission and that they have been provided with this information before doing so
  8. If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian
How Do We Keep Your Information Safe
We use technical and organisational security measures including encryption and authentication tools to protect your personal information, against manipulation, loss, destruction, and access by third parties.

Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:

  1. Tightly restricted access to your data on a “need to know” basis and for the communicated purpose only
  2. Transferred collected data only in encrypted formHighly confidential data stored only in encrypted form
  3. Firewall protection and IT systems to prohibit unauthorised access e.g. from hackers
  4. Permanently monitored access to IT systems to detect and stop misuse of personal data

If you have a personal password which enables you to access certain parts of our website or any other portal, app or service we operate, do not forget your responsibility for keeping this password confidential. We ask you not to share your password with anyone.
What Information May Be Collected About You
The following types of personal information about you may be collected:

  1. Contact Details, Name, Address, Phone numbers, Email address, Personal interests
  2. Information you provide us about your interests Including the type of vehicles you are interested in
  3. Website and Communication usage
  4. How you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies (our Cookies Policy).
  5. Sales and Services Information
How Long Do We Keep Your Information
We retain your information only as long as is necessary and only for the purpose for which we obtained them. We restrict access to your information to only those persons who need to use it for the relevant purpose.

Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised or destroyed securely.

Use for marketing: We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for.For example, used to perform a contract: In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus six years to deal with any queries or claims thereafter.

EVIE and ZAPME APP: We set out how long we retain Charging location and Device Information in relation to each charging service provided in the relevant service descriptions.

Where claims are contemplated: In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Advertisements

  We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

[Add information regarding opt-out options from personalized advertisements, such as:] You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [add applicable email address] .

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at info@zpnenergy.com
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Last Modified 01 April 2024
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