Privacy Policy

In our updated Privacy Policy, you can read more on how we treat your personal data. This, together with any other documents referred to within, sets out the basis on which we will process any personal data that we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1.    INTRODUCTION

Recharge AS (we, us, or our) is committed to protecting the privacy of our customers, clients, and users of our services in an open and transparent matter. This Privacy Policy outlines how we process your personal data.

 

2.    DATA CONTROLLER

As the data controller, Recharge AS is responsible for deciding how and why your personal data is processed. We ensure that your data is handled legally and fairly.

 

3.    THE PERSONAL DATA WE PROCESS

We may collect and process the following types of personal data necessary for our relationship with you, including but not limited to:

  • Contact information (such as name, address, email, and phone number)
  • User account information
  • Professional information (e.g., for B2B clients/customers)
  • Transaction and billing data (e.g., payment card number)
  • Usage data of our services (e.g., charging consumption, consumption pattern, IP address)
  • Communications (e.g., feedback, survey responses)
  • Any other personal data provided by you during our services

 

4.    SOURCES OF PERSONAL DATA

We gather personal data in several ways, such as data you provide when signing up for our services, contacting customer support, or participating in surveys, data collected via cookies and other tracking technologies when you use our website or app, and data received from partners or public sources like credit reference agencies.

 

5.    PURPOSES OF PROCESSING

We may collect and process the following types of personal data:

  • Providing and managing our services
  • Billing and transactional purposes
  • Improving our services and offerings
  • Marketing and sales activities (subject to your consent where required by law)
  • Enhancing security and availability of our services
  • Conducting market research and customer satisfaction surveys
  • Personalizing user experience on our platforms
  • Purchasing and procurement
  • Due diligence
  • Recruitment
  • Fraud prevention
  • Legal obligations

 

6.    LEGAL BASIS FOR PROCESSING

We process your data based on:

  • Your consent, where you have explicitly agreed to data processing (e.g., for marketing purposes).
  • Contractual necessity, to fulfill our contractual obligations to you (e.g., billing and service delivery).
  • Legal obligations, to comply with laws and regulations (e.g., tax and audit requirements).
  • Legitimate interests of Recharge, for our legitimate business interests, balanced against your rights and freedoms.
  • Protection of vital interests of any person.

 

7.    AUTOMATED DECISION-MAKING

We may make decisions about you through automated decision making. Such include e.g. automated checking of the validity of your payment card; automated pattern detection in the use of your payment card to detect, investigate and prevent potential frauds; and automated tracking of your potential debt to Recharge from previous unpaid use of our services.

Our automated decision-making procedures may affect your ability to use our services. We may need to do this either to perform our legal obligations or because it is necessary for entering into, or the performance of, a contract between you and us. We also carry out profiling to provide our customers with better targeted sales and marketing communication.

If we have made a decision about you solely on the basis of an automated process (e.g. through automatic profiling) and that affects your ability to use the services or has another significant effect on you, you can ask to not be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us.

 

8.    DATA RETENTION

We adhere to the principle of storing personal data only for as long as necessary to fulfill the purposes for which it was collected, taking into account legal, accounting, and reporting requirements.  Our data retention practices are designed to ensure that personal data is not kept longer than necessary, reflecting our commitment to data minimization and privacy protection.

As a standard practice, we retain your personal data for a period of three (3) years following the end of the last charging session or the conclusion of our customer relationship. Information related to financial transactions is retained for a minimum of five (5) years to comply with legal obligations. If SMS is used as a payment method, your mobile subscription number may be stored on a list under certain conditions (e.g., insufficient prepaid balance or blocked Premium SMS). In such cases, we are required to retain your number for at least six months.

We regularly review and evaluate the retention periods for different types of personal data to ensure they are appropriate. This evaluation takes into account the nature of the data, the purpose of processing, and any legal or regulatory obligations that require data retention.

Upon reaching the end of the retention period, or when personal data is no longer necessary for the purposes for which it was collected, we will take steps to delete or anonymize it promptly. Our aim is to protect your privacy by ensuring that unnecessary data is not retained.

 

9.    DATA PROCESSORS AND TRANSFERS

Personal data is processed within the Recharge group of companies, strictly adhering to existing privacy laws. We ensure that the access to your data is restricted and only authorized employees or affiliates who need the information for processing purposes have access to it.

To support the development, delivery, and maintenance of our products and services, we engage third-party processors. These entities also assist in fulfilling other purposes outlined in this Privacy Policy.

Below is a list of the categories of these third parties, who act as data processors on our behalf:

  • Service Providers: Including printing services, customer support, and installation partners.
  • Sales and Marketing Partners: Entities involved in marketing and sales activities.
  • Payment Service Providers: Companies that manage payment processing.
  • Cloud Service Providers: Entities providing cloud storage and processing capabilities.
  • Charger Manufacturers: Manufacturers of the charging hardware we use.
  • Roaming Platform Providers: Companies facilitating charger network interoperability.
  • IT Service Providers and Consultancies: This includes developers, designers, and testers who support our IT infrastructure.
  • Service and Maintenance Partners: Entities responsible for hardware repair and maintenance.
  • Charger Cloud Systems Providers: Providers of cloud systems specific to charger operations.
  • Invoicing and Debt Collection Services and System Providers: Companies assisting in invoicing and debt recovery processes.
  • Data Hosting System Providers: Entities managing the hosting of our data systems.
  • Warehouse Service and Management System Providers: Companies overseeing our warehousing needs.
  • Software and Tool Providers: Suppliers of various software tools for development, analytics, sales, marketing, work order management, CRM, online conferencing, and communication.
  • Operational Companies: Such as postal services and delivery couriers.
  • Research Companies: For conducting customer satisfaction surveys and product/service development research.
  • Telecommunications System Providers: Providers of telecommunications infrastructure.

When engaging third-party processors, we establish stringent contractual arrangements to ensure that the processing of personal data is conducted in a secure manner, in compliance with privacy laws and best practices in data processing.

In addition to these categories, we may disclose personal data to legal and regulatory authorities as required by law. Such disclosures are made in accordance with existing privacy laws and upon demands made by competent authorities.

As a general rule, Recharge AS does not transfer personal data outside the European Union (EU) or the European Economic Area (EEA). In instances where personal data is transferred outside of the EU or EEA, we ensure that appropriate safeguards are in place in accordance with existing privacy legislation. This includes utilizing standard contractual clauses approved by the European Commission.

 

10. YOUR RIGHTS UNDER GDPR

As a data subject, you have extensive rights, including:

  • Access: The right to receive a copy of your personal data.
  • Rectification: The right to correct inaccuracies in your data.
  • Erasure: The right to request deletion of your data under certain conditions.
  • Restriction: The right to limit how we use your data.
  • Data Portability: The right to receive and transfer your data in a structured, commonly used format.
  • Objection: The right to object to certain types of processing, such as direct marketing.
  • Automated Decisions: The right to not be subject to decisions based solely on automated processing, including profiling, which has legal effects or similarly significantly affects you.
  • Withdrawal of Consent: Where processing is based on your consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

 

11. USE OF COOKIES ON OUR WEBSITES

Our website uses cookies to enhance user experience, gather analytics, and personalize content and advertising. You have the option to block cookies through your web browser settings. However, please be aware that disabling cookies may impact the functionality and user experience of our services.

Third parties, such as marketers, advertisement networks, and measurement and tracking service providers, may access data collected on Recharge’s websites. These entities may use your personal data for purposes like delivering targeted advertisements or compiling website usage statistics.

We ensure that third parties comply with existing privacy laws through contractual agreements. This is to maintain the security and privacy of your personal data.

If you provide clear consent, we may use the location data of your device to offer services based on your geographical location. You have the right to withdraw your consent at any time by changing the appropriate settings on your device.

 

12. SECURITY OF YOUR DATA

We are committed to safeguarding the privacy and security of personal data. We employ security measures to protect your data, including:

  • Systems to ensure that only authorized personnel have access to personal data.
  • Our network is protected by robust firewalls and IP filtering technologies to safeguard against unauthorized access.
  • Enhanced security measures, such as multifactor authentication, are in place to verify the identity of users accessing our systems.
  • Where possible, we pseudonymize personal data to protect individual identities.
  • Personal data is encrypted during transmission and storage, providing a high level of data security.
  • Our personnel receive detailed instructions and ongoing training on the protection of personal data, emphasizing the importance of data security and privacy.
  • We exercise careful consideration in selecting service providers involved in processing personal data, ensuring they meet our stringent data protection standards.

 

13. CHANGES TO THIS POLICY

We may update this policy to reflect changes in our practices or legal requirements. Notice of significant changes will be provided through our website or via email.

 

14. CONTACT

For any questions or requests regarding this policy, or to exercise your rights, please contact us at privacy@rechargeinfra.com.

This Privacy Policy was last updated February 2024.

 

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