PRIVACY POLICY FOR THE 

PURCHASE DIRECT EV APP

 

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read this information.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.

YES I consent to the installation of the App for the purposes of charging of electric vehicles and payment to for energy used.

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us Purchase Direct Limited, 4 Falcon Way, Welwyn Garden City, AL7 1TW, Tel: 01707 299100 but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology or Wi-Fi so that location-enabled Services are activated to disclose chargers close to your location).

NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

Location Data

Purchase Direct Limited (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our end-user licence agreement as set out at https://www.purchase-direct.co.uk/enduserlicenceagreement/ (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

This policy is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED?

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

GLOSSARY

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Important information and who we are

Purchase Direct Limited is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

We have appointed a data privacy manager . If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 20/12/2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

We explain these categories of data here LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA BELOW.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Cookies

We use cookies, which are files which are downloaded by your Device to make your experience of using our App/Site better. Cookies are used for a variety of reasons as set out in below. 

Use of Cookies

If cookies are disabled cookies this affects the functionality and features they add to this App/Site. It is recommended that you leave on all cookies. However, you can disable cookies by adjusting the settings in your browser, but this may disable certain features of the App/Site.

We use cookies in relation to:

Third Party Cookies

We may use cookies from trusted third parties, such as:

If you require more information about our use of cookies, please contact using the following contact details:

 

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Click here LINK TO GLOSSARY: LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us or using the opt-out link in any email communication.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact

Financial

Device

Your consent

To process in-App purchases and deliver Services including managing payments and (depending on the user) collecting money owed to us

Identity

Contact

Vehicle Registration

Financial

Transaction

Device

Marketing and Communications

Location

 

Your consent

 

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To reset your password on your account

Identity

Contact

Device

Performance of a contract with you.

To manage our relationship with you including notifying you of changes to the App or any Services

Identity

Contact

Financial

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Vehicle Registration

Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:

International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We keep your personal data for the length of your contract with us.

We keep your vehicle make and model on an anonymous basis (not linked to your personal data) indefinitely.

Your location data is used for a single transaction only and not stored. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data, such as your vehicle make and model (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us using the contact details above.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

External third parties

Service providers acting as processors based in the EEA, USA and Australia who provide IT and system administration services.

We share data with our car dealership members, as they monitor who is using the Chargers on their premises and to provide data on energy usage.

Stripe is the service provider providing card payment services

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.



Your legal rights

You have the right to:

Description of categories of personal data