March 31, 2020
What personal information we are processing, why and on which legal basis
Who do we share your personal information with?
For how long do we keep your personal information?
Your rights concerning our processing of your personal information
Exercising your rights, contacting us and other important information
1. What personal information we are processing, why and on which legal basis
Account management - When you set-up an account as a tenant on our platform, we use the personal information you provide us with to set-up and maintain it. This is necessary to perform the contract with you or your employer.
Billing & administration - For any payable service, we will use the personal information that you provide us with to invoice you. We will also use that personal information to maintain an up-to-date administration. This processing activity is necessary to perform the contract with you (invoicing) and to comply with a legal obligation (keeping an administration).
Contact with you – When you contact us, e.g. through one of the contact forms on our website, if you call us for support, we contact you, e.g. to inform you about certain updates, or in case we have ongoing business with each other, we use your personal data for our ongoing business and to answer your requests, e.g. provide you with support. The legal basis for this processing activity is that we either have a contract with you, or that we take steps at your request prior to entering into a contract.
Due diligence, security of our offerings and preventing fraud – As we aim to provide you with products and services that are most secure and as we want to keep our people and business safe, we have a legitimate interest to use your personal information to conduct due diligence investigations, to maintain the security of our offerings and to prevent fraud.
Everon offerings – If you leave us, or one of our business partners leaves us your personal information (via website, e-mail, phone, in person or any other means) because you are interested in our products and/or services, we store your request and use that personal information to reach out to you, so that we can supply you with a quotation for the products and/or services of your interest.
The legal basis for this processing activity is that we take steps at your request prior to entering into a contract, or your consent.
Legal purposes - Sometimes we need to use your personal information to handle claims, to comply with applicable laws or for law enforcement requests. This processing activity is in our legitimate interest, or to comply with a legal obligation.
Marketing and promotions - If you are an Everon partner or customer, we may contact you for the promotion of our own similar products and/or services. The legal basis for this processing activity is that it is in our legitimate interest, because as a business we strive to create a future where everyday transport is electric, emissions-free, and sustained by a green charging infrastructure. You can easily opt-out of this service by clicking the unsubscribe button provided in our promotional emails.
Online surveys - At times we may ask you to participate in a survey that allows us to improve our offerings. In such case and only if you consent to this, we use the personal information you provide us for that purpose (and we might share it with our survey partner for the same purpose).
Quality improvement - Log-files of connected charging stations contain valuable information for us to improve the quality of our offerings. We use the information contained in those log-files for that purpose. The personal information that we process for this purpose are service data of charging stations that are connected to our platform and charging sessions of EV-drivers that use such charging stations within the Everon network. The legal basis for this processing activity is that it is in our legitimate interest, because we aim for constant improvement of our offerings and to that extent, it is critical for us to have the opportunity to use these statistical data.
Recruitment and onboarding – If you apply for one of our positions, we process your personal information to assess if you are suitable for such position. The legal basis for this processing activity is that it is in our legitimate interest, as we need to assess how you can help us to accelerate the transition towards a zero-emission future. The personal information that we process for this purpose:
Background check information from public authorities;
Character and/or performance information from referees;
Pre-employment assessment information from assessment service providers;
Personal information from the public section of your social media account(s), or other public information about you; and
Personal information that you provide us with.
We will only use the personal information about you if such is necessary and relevant to the position you apply for.
In the application process we will ask you if we can also contact you for any upcoming employment opportunity for which you may be suitable, and thus keep your personal information on file for a period of one year. You can refuse and/or withdraw your consent at any time.
In case your application is successful, we have a legitimate interest to continue to process your personal information so that we can make you an offer, and subject to your acceptance, enter into an employment relationship with you and welcome you aboard.
Everon Academy - Access to Everon Academy is invite only. However, upon initial log in, we request your consent to share with us your company name and country in order to complete the account activation. We need this information (i) to verify that you are an existing Everon customer or partner, (ii) to deliver relevant training information for you based on your location, time zone, and/or language, and (iii) to send you necessary information about the training services which you are receiving. Upon activation, we will request your (i) contact details including first name last name, and business email, and your personal chosen password to access Everon Academy. Optionally, you can share additional information with us on My info page to help us improve your user experience at Everon Academy: My bio, Profile picture, Time zone, Language, and Job title. Also, when using Everon Academy, the learning management system (LMS) automatically generate data which tracks your interactions, progression, and results within the learning objects that you participate in.
2. Who do we share your personal information with?
Everon is a company that operates on a global level and we may have a legitimate interest to share personal information with group companies, for example to a group company that is providing a service for another group company.
We also use trusted service providers to provide certain services for us in relation to the processing of your personal information. For example, we store personal information with an external hosting provider and we use a payment service provider to facilitate ad-hoc payments.
In addition, we may share your personal information with our business partners a reseller to follow-up on your request for information on our products and/or services.
Finally, to the extent we are required by law, regulation or court order, we may disclose your personal information in compliance with that law, regulation, or court order.
3. International Transfers
We may transfer your personal information to a group company or third party that is located outside the European Union or the European Economic Area. If this country does not provide for an adequate level of protection under its domestic law according to the European Commission, we have ensured this adequate level of protection by agreeing on additional appropriate safeguards with that group company or third party through the Standard Data Protection Clauses adopted by the European Commission.
A list of countries that have ensured an adequate level of protection according to the European Commission can be found on the EU Commission website.
Where we use service providers from the US, such US based service provider has registered itself to be on the EU/US Privacy Shield list and has been self-certified with the US Department of Commerce, or we have agreed on additional appropriate safeguards with that service provider.
More information on the European Commission decision on the adequacy of the EU/US Privacy Shield can be found here.
Alternatively, we may ask you for your explicit consent to the proposed transfer. You may request a copy of the Standard Data Protection Clauses by sending us an email (details provided below), motivating your request.
4. For how long do we keep your personal information?
Where possible, we have set specific retention periods for keeping your personal information. These specific retention periods are stated below, or we shall communicate these to you at or before we start processing your personal information.
Where it is not possible for us to use set retention periods, we have stated below the criteria that we use to determine the retention periods.
Specific retention periods
Billing & administration for any of our offerings – we keep your personal information that is required to be kept by law for maintaining an administration for a period of 7 years, or longer if required by local law.
Marketing & promotions - We keep your personal information for as long as you are subscribed, or until we cancel our newsletter service, whichever occurs first. You can easily opt-out of the newsletter by clicking the unsubscribe button provided in the email.
Recruitment & onboarding - In case the job application is successful and we can welcome you aboard, we shall store your personal information in our personnel files, which we shall keep in accordance with our data protection policy retention times.
In case the job application is unsuccessful, we shall keep your personal information for a maximum of four weeks after the job application process has ended.
In case you consent to us keeping your personal information for future opportunities, we shall keep your personal information for a maximum of one year after the job application process has ended.
Everon Academy - When your subscription has ended or been terminated, we will deactivate your account, and your data will be archived and remain recoverable if your subscription is to be reactivated at a later date.
Criteria for determining retention periods
In any other circumstances, we use the following criteria to determine the applicable retention period:
The assessment of your fundamental rights and freedoms;
The purpose(s) of processing your personal information. We shall not keep your personal information longer than is necessary for the purpose(s) we collected it for;
Any relevant industry practices or codes of conduct on keeping personal information;
The level of risk and cost associated with keeping your personal information (accurate and up to date);
Whether we have a valid lawful basis to keep your personal information;
The nature, scope and context of processing of your personal information and our relationship with you;
Any other relevant circumstances that may apply.
In any case, we shall keep your personal information in compliance with applicable law and make periodical reviews of the personal information held.
5. Your rights concerning our processing of your personal information
You have certain legal rights that we wish to inform you of.
Access. You have the right to be informed on whether we process your personal information or not and to related information on that processing.
Consent withdrawal. If you have supplied us with your personal information based on your consent, you have the right to withdraw such consent at any time. You may withdraw your consent by unsubscribing from the service that you have subscribed to if applicable. You may also do so by sending us an email to email@example.com. We shall then permanently remove your personal information from our database.
Data portability. We are required to inform you of your right to receive your personal information from us so that you can transmit that personal information to another service provider.
Lodging a complaint. You have the right to lodge a complaint with a supervisory authority, in particular in the country of your residence, about our processing of your personal information. You can find a complete list of supervisory authorities here.
Rectification. You have the right to have your personal information corrected or completed by us without undue delay. If you have set up an account with us, you may have the possibility to correct or complete your personal information yourself.
Restriction of processing. You have the right to request that we restrict the processing of your personal information based on specific grounds. These are (1) the time for us to verify the accuracy of your personal information on your request; (2) instead of erasure of unlawful processing, you request restriction of use instead; (3) we no longer need your personal information, but you need this personal information in legal proceedings; or (4) we are verifying whether our legitimate grounds override your objection to the processing.
Right to be forgotten. You have the right to have your personal information erased by us without undue delay. This right is limited to specific grounds, for example if you have withdrawn your consent, or if you object and there are no overriding legitimate grounds for us to maintain the processing. If you have an account with us, in some instances you have the option to erase your account yourself, in which case all your personal information is permanently deleted.
Right to object. You have the right to object at any time to our processing of your personal information if such processing is (1) based on our legitimate interest (including us making a profile of you based on your consent); (2) for direct marketing purposes; or (3) necessary for the performance of a task carried out in the public interest or exercise of official authority vested in us. We shall cease to process your personal information based on your objection, unless we demonstrate compelling legitimate grounds overriding your interests, rights and freedoms.