Privacy Notice

Last Reviewed: July 2023

This privacy notice includes important information about your Personal Data, and we encourage you to read it carefully.


Introduction

Pod Point limited, also referred to in this privacy notice as ‘’Pod Point, we, our and us’’, is the operating company and a wholly subsidiary of the Pod Point Group Holding PLC.

We are a leading supplier of Electric Vehicle (EV) chargers for both domestic and commercial use in the United Kingdom (UK) and Europe. With manufacturing operations across both UK and Europe and with sourcing, sales and design based out of the UK, we can provide products and services to our customers and commercial clients in an efficient manner.

As a UK technology company in the electric vehicle charging market, our mission is that ‘travel shouldn’t damage the earth’. Our objective is thus to build a smart, easy to use network of charge points that are available to you everywhere you park.

To provide our products and services to our customers and fulfil our contractual obligations with our commercial clients, we collect and process Personal Data and information. Therefore, as per the General Data Protection Regulation (GDPR) (and the GDPR as implemented into UK law by the Data Protection Act 2018 (UK GDPR)), Pod Point is a Data Controller of the Personal Data it collects and processes from you and complies with the UK GDPR and GDPR.

Pod Point recognises the importance of your personal information and its security and is committed to safeguarding your privacy. This privacy notice applies to you if you are a direct or indirect (potential or actual) EV charging solution customer of Pod Point or a public and/or commercial site's Pod Point EV charger user.

2. Data that we collect and how we use it

2.1 How we collect your data.

We may collect your data in a number of different ways:

  • Direct interactions. We may collect directly from you Contact data, Grant Application Data, Account Data, Publication and Feedback Data, Enquiry Data, Payment Data, Marketing and Communication Data, or Correspondence Data. For example, we may collect this information from you when you:
    • Create an account with us.
    • Sign up to receive marketing communications from us.
    • Make enquiries or otherwise contact us.
    • Order our products/services.
    • Engage with us on social media.
  • Automated technologies or interactions. As you interact with us, including via our website or mobile application, we may automatically collect Technical and Website/ mobile Application Usage Data about your equipment, browsing actions and patterns. We may also collect Technical and Website App Usage Data from cookies and similar technologies when you use our website or when you click on one of our adverts (including those shown on third party websites). We also collect your Energy Usage and Charge Data from your use of the EV charging units.
  • Third parties or publicly available sources. We may receive personal data about you from various lawful sources, including:
    • Technical and Website/App Usage Data from analytics providers (such as Google), advertising networks and search information providers.
    • Contact Data, Payment Data and Account Data from providers of technical and payment services.
    • Third party review sites and social media such as Trustpilot.
    • Location Data from Google, where you request to see where the nearest Pod Point charging point to your location is.
    • Contact Data from our referrers (which may include your employer, vehicle dealership or manufacturer) where they think you will be interested in our products and services, so that we can contact you to tell you about them.
    • Contact Data from your employer or building management company for the purposes of providing you access to the charge points at your place of work/where you live (we process this data as a Data Processor on their behalf and only on their instructions).

    • Please see these third parties’ privacy policies for how and why they collect, process and share your data.


    2.2 Categories and types of data collected.

    We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

    • Where we need to perform the contract, we are about to enter or have entered into with you. For example, when you purchase our products/services personally, that’s a contract with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include the interest of our business in conducting and managing our business, or communicating with you when the business you represent is or will benefit from ordering our products/services.
    • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
    • Where we have your consent. Where our legal basis is consent, you have the right to withdraw consent at any time.

    The table below shows you a description of all the ways we plan to use Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Category of data

    Purpose(s)

    Source / data types

    Lawful basis

    Contact Data

    To create an account for you on our systems or mobile application.

    To verify your identity when you contact us to discuss your account or charger.

    To respond to your queries, complaints or disputes.

    check or keep you updated about your order.

    Arrange the installation of the home charging or the commercial solution.

    To keep you updated about your order and installation.

    Process your Grant application where you are eligible to.

    For our analysis and reporting purposes.

    To send you newsletters, EV product information/guides and marketing communications.

    Where you have agreed to or when the Grid is at risk of overload (there is a risk that at a certain period the capacity of the electricity network, your home or commercial site is located in, will be exceeded), to turn off your charging unit.

    Name, email address, telephone number, home or business address details including postcode.
    1. Our legitimate interests (to provide you with good customer service; Grid Load Management when we are required to by Law, to promote our products, to fulfil our obligations/rights under a contract with our commercial client where you represent them).
    2. Performance of a contract (creating your account and supplying you with the products you have ordered from us or the services you have requested or agreed for us to provide to you such as warranty.
    3. Consent (where you have requested, we send you information, newsletters, or other marketing).

    Technical and Website/Mobile Application Usage Data

    To carry out analytics to determine the success of our website and mobile application features.

    To enable us to improve our website and mobile application to better fit your needs.

    To build and improve our website/mobile application, including providing functionality, analysing performance, fixing errors, keeping it secure and improving usability / effectiveness.

    IP address, MAC address (device ID used to access our website, mobile application, or services), browser type and version, operating system, referral source, length of visit, page views and website navigation paths, the timing, frequency, and pattern gathered from our Google analytics tracking systems.
    1. Our legitimate interests (to maintain and improve our website, mobile application, products, and services; to build and manage our IT security, network and stack).

    Energy usage and Charge Data

    To enable you to monitor, track and optimise your electrical consumption, allows us to provide you with charging analytics for your home via Pod Point mobile application and for you to benefit from many of our smart charging features.

    We also use this data for our internal analysis and reporting purposes, Grid Load Management, to inform our product/service development and marketing.

    The amount of energy drawn through the charge points, charge points used, charge point location, charge time (start and end), amount of charge, length of charge, socket size, speed, and cost of charge.
    1. Our legitimate interests (to provide you with information about the use of your charger; to improve our products / services and Grid Load Management).
    2. Performance of a contract with you (where we have obligations to provide you with this information).

    Location data

    To show you the result of your online or mobile application search about the nearest Pod Point charging units to your location.

    Geographical location

    1. Our legitimate interests (to direct you to our charging units when you want to use them).

    Grant application Data

    To make grant applications on your behalf or support you in making the application where you are eligible for a UK Government grant for a charging point (this could be for a home charging unit or a charging unit at your place of work).

    Name, address, email, telephone number, vehicle details (including vehicle make and model, vehicle registration number, VIN number, charging unit MPAN number (serial number for every Pod Point metre), vehicle delivery date, vehicle status: new or used, your business address, driving licence details, job title and employer.
    1. Consent (we only make grant applications on your behalf where you have specifically requested for us to do so).

    Account Data

    To enable us to create an account for you (including if you have started the process and need our assistance to complete it).

    Operate a secure website and mobile application and provide the services you expect and want from us based on our contract with you or your employer.

    To maintain backups of our databases.

    Where you have agreed to or when the Grid is at risk of overload (there is a risk that at a certain period the capacity of the electricity network, your home or commercial site is located in, will be exceeded), to turn off your charging unit.

    Name, address, email, telephone number, username, password, signature, vehicle details (such as registration number, VIN number (ID number of your vehicle found on the chassis), charging unit MPAN number (serial number for every Pod Point metre).
    1. Our legitimate interests (to administer properly and securely our products and services).
    2. Performance of a contract with you (to create and manage your account)
    3. Our legitimate interests (to create and manage our business customer accounts).

    Social Media Identifiers

    To respond to a post, complaint or dispute you have raised on social media.

    Your social media name, identifier and any information provided to us by you if you publish or post on our social media platforms.
    1. Our legitimate interests (to read and respond to your posts, queries and complaints directed to us by you).

    Publication and Feedback data

    So that we can read, respond, and take into account your reviews and feedback, and to enable us to publish information that you post on our website or app.

    Your reviews (which may be posted on our website, social media or via Trustpilot or Reviews.co.uk), information that you post on our website, app or through our services.
    1. Our legitimate interests (to read and use customer feedback to inform our strategy and promote our products and services).

    Enquiry data

    To offer, sell and provide relevant services to you and answer any queries you have about our products and services.

    Any data you provide in an enquiry.
    1. Performance of a contract with you.
    2. Our legitimate business interest (to tell you about the various products and services we can offer and to contact you to facilitate you purchasing them and having them installed).

    Payment data

    To allow us to take payment for our products via the method you choose (for online orders on our website, when you top up your mobile account to use a Pod Point charging unit or pay for your charge through our mobile application or directly through the Pod Point charging unit).

    Payment card information and details about your payment method choice. This includes where you have chosen to use the flexible payment options we offer in partnership with Klarna Bank AB (publ).
    1. Performance of a contract with you

    Transaction data

    To allow us to process your purchases, keep proper records of our sales, fulfil our financial and legal reporting obligations, respond to any payment query/complaint or dispute and refund you if necessary.

    Billing address including postcode, date of purchase/payment details, payment amount and payment location.
    1. Performance of a contract with you.
    2. Our legitimate interests (ensuring our financial transactions with customers are managed efficiently; responding to complaints/disputes).
    3. Comply with a legal obligation (our financial and legal reporting requirements, such as tax law requirements)

    Marketing and Communication Data

    To send you newsletters, guides, information about us, updates, and other marketing communications.

    Your contact details, your marketing communication preferences.
    1. Your consent – we only send you direct marketing if you have registered (and therefore expressly agreed) to receive this from us.

    Correspondence Data

    To communicate with you and to keep proper records of the communication we have with you.

    The communication content and metadata associated (if communication is via our website contact form).
    1. Our legitimate interests (to read and respond to any communication from you, and to keep records so we can respond to complaints etc. in the future).

    Photograph and Video Data

    To create promotional material for our business.

    Name, email address, address, photographs, and videos which may include you and/or your family in them.
    1. Your and any third-party included in the photograph or video consent (we will only collect this data where you have signed a release form).

    We also collect, use, and share aggregated data, such as statistical or demographic data, for analysis and reporting purposes. Aggregated Data may be derived from your personal data but, if it is not combined with other data to identify you, it is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

    In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and is therefore no longer Personal Data) for research or statistical purposes. In which case we may use this information indefinitely without further notice to you.

    Please do not share with us another person’s data unless you have obtained their permission and it has been agreed with us beforehand.

    It is important that your Personal Data is accurate and up to date. Please provide us with accurate information and keep us informed if your Personal Data changes during your relationship with us. You can do so by completing the following form on our online help centre: https://help.pod-point.com/s/contactsupport

    3. With Whom we share your data and international data transfers

    Pod Point may share your Personal Data with any member of its group of companies; Group of companies which includes Pod Point’s subsidiaries and holding company.

    Where you use units installed at a Pod Point commercial customer site(s) (i.e., not your home), Energy Usage and Charge Data may be provided to the Pod Point customer in report form. Your employer or your building management company may be able to identify you as the owner of the Energy Usage and Charge Data. Otherwise (for example, during your shop at a supermarket), our commercial customer will not be able to identify you as the owner of this information (i.e., it will not be Personal Data).

    Where the processing of your Personal Data is carried out outside of the UK, appropriate safeguards in compliance with applicable data protection laws have been put in place with the supplier to ensure the safe transfer and processing of your Personal Data.

    Rest assured that the safeguards in place are proportionate to the level of the Personal Data being transferred. Should you wish to be provided with details of such safeguards and information about our Suppliers, please contact us using the details provided in the ‘How to Contact us’ section below.

    On a “need to know” basis and if required to fulfil the contract we have with you, we may also disclose your Personal Data, to:

    • Our carefully selected third-party EV charger installers, suppliers, and other contractors to facilitate the installation and maintenance of your EV charging unit, including pre and post installation services.
    • Technology service providers, such as AWS and Salesforce.
    • Our insurers and professional advisors such as Product Partnership Limited (PPL), a company regulated by the Financial Conduct Authority (FCA) because of the Pod Point’s Appointed Representative (AR) Status we have obtained to provide you with the Klarna payment options on our online ordering experience journey.
    • Any organisations or government departments who may offer funding or grants to you in respect of the services we provide, where you request that we assist you with your application.
    • Auditors and professional advisors such as bankers, lawyers, accountants, and insurers.
    • Marketing affiliates or partners such as Google and Linkedin.
    • Energy tariff providers such as EDF if you have consented to receive marketing information from them.
    • Distribution Network Operators (DNOs), the National Grid (NG) and Utility companies. We may share information such as your charging unit number (MPAN number), your Energy usage data/Charge Data and your full address including postal code with these companies for them to provide Pod Point with data analytics services and for the management and security of the national and your local electrical Grid. It is worth mentioning that using your full address including your postal code and your MPAN number, these companies may be able to identify you hence the information shared with these companies by Pod Point is classed as Personal Data.
    • Any public or regulatory authority, under applicable regulatory code, if we are required by law to provide information about you.
    • Selected third-party service providers to manage our customer relationships.
    • Marketing third parties we have contracted with to help promote our business, products, and services.
    • Prospective sellers or buyers of our business or assets if we sell or buy any part of our business or assets.
    • Payment providers such as Klarna Bank AB (publ), Stripe and Apple Pay to enable you to make payments for the product you would like to purchase or have purchased from us.

    We offer flexible payment options in cooperation with Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden. These payments are made to Klarna: (a) ‘Pay Later 30’; and (b) ‘Pay in instalments’. Further information and Klarna’s user terms can be found here. General information on Klarna can be found here. If you choose to pay for your online order through Klarna, your Personal Data (contact and order details) might be shared, in our online checkout with Klarna Bank AB (publ) to enable them to assess whether you qualify for their payment method and to tailor those payment methods for you. Your Personal Data transferred to Klarna Bank AB (publ) will be handled in accordance with applicable data protection laws and in accordance with Klarnas privacy statement.

    We also use Stripe for payment, analytics, and other business services. Stripe collects and processes Personal Data, including identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and prevention. You can learn more about Stripe and its processing activities via stripe privacy policy at https://stripe.com/privacy

    For information about how Apple Pay uses and processes your Personal Data in reference to your choice to pay for your order with Pod Point using Apple Pay, please refer to Apple Pay privacy notice at https://www.apple.com/uk/legal/privacy/en-ww/

    Finally, we also share data with third parties connected to advertising, retargeting and analytics. Please see our Cookie Policy for more information.

    4. Data Retention

    Your Personal Data will not be kept by us for longer than it is necessary to meet the purpose(s) stated, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements (for example, for tax purposes, by law we keep Contact, Payment, and Transaction Data for six years after you cease being an active Pod Point customer).

    To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

    If you opted out or withdrew your consent to marketing, we will remove you from our marketing database.

    5. Security of your Personal Data

    Pod Point is committed to keeping your personal information safe. Your Personal Data collected for the above-mentioned purposes are only accessible to whom needs to see and use them as part of their job role.

    To prevent unauthorised access, misuse, destruction, loss and alteration of your information, physical, technical, and organisational measures have been put in place (including policies and procedures).

    If you have chosen to create an account on our website or mobile application, your login credentials enable you to access your account. It is therefore your responsibility to keep your username and password confidential and not to share them with anyone.

    When processing your Personal Data, Pod Point makes reasonable efforts to ensure there is a level of security appropriate to the risk associated with the processing of your Personal Data. We cannot guarantee the security of your Personal Data while it is being transmitted from your device to our website. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

    6. Marketing

    If you sign up to receive marketing communications from us (for example, when you buy our products/services you can choose to opt into marketing emails), Pod Point will use your Personal Data to send you these. This consent is kept and stored by Pod Point in your customer record. You can unsubscribe from these communications at any time by using the unsubscribe link available at the bottom of any of the marketing emails and communications.

    If you start to order our products and services on our website but do not complete your order we may use the data that you provided to us during the ordering process to send you marketing emails about our products and services.

    You can also opt out from being sent marketing communications by using the contact details provided in the ‘How to contact us’ section of this privacy notice below.

    You may see adverts for Pod Point elsewhere, for example on social media. We do not direct these adverts at you specifically, but we may direct them at target audiences (for example, an age group).

    7. Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website or mobile application may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

    8. Your rights as data subject

    As per the UK GDPR, the below rights, towards your Personal Data have been given to you. Please note that, Pod Point will aim to fulfil your rights by providing a response within one calendar a month from verifying your request (identifying you as a Pod Point customer). If we are unable to respond to your request or there is a delay in our response, we will let you know with details on when to expect our response.

    To exercise any of your rights listed below, please contact Pod Point using the details provided in the ‘How to contact us’ section of this privacy notice below.

    • The right to be informed: you have the right to be informed about the collection, processing, and use of your Personal Data by Pod Point. This right made it compulsory for Pod Point to provide you with this privacy notice.
    • The right of access: you have the right to access and receive a copy of the Personal Data Pod Point is processing and stores from you, and other supplementary information.
    • The right to rectification: you have the right to have your inaccurate Personal Data rectified or completed if it is incomplete.
    • The right to erasure: you can request for your Personal Data to be erased by Pod Point.
    • The right to restrict processing: you have the right to request the restriction or suppression of your Personal Data. This is not an absolute right and only applies in certain circumstances.
    • The right to portability: this right allows you to obtain and reuse your Personal Data for your own purposes across different services for example where you request for Pod Point to pass your data to your chosen company for a purpose pre-defined and agreed between the company and yourself.
    • The right to object: this right allows you to object to the processing of your Personal Data in certain circumstances. You also have an absolute right to request for your data not to be used for direct marketing (see section 6 above).
    • The right related to automated decision-making including profiling: this right allows you to object for your Personal Data to be used for decisions solely made by a company through automated means (without any human involvement) (see section 8).

    9. Automated decision-making & profiling

    Pod Point does not use automated decision making to provide its products and services to you.

    Pod Point does not undertake profiling.

    10. How to contact us

    This website is owned and operated by Pod Point Limited. We are registered in England and Wales under registration number 06851754, and our registered office and principal place of business is at 28-42 Banner Street, London, EC1Y 8QE.

    Pod Point has appointed a Data Protection Officer who can be contacted for any Personal Data queries, general privacy matters using the below contact details:

    Email: dataprivacy@pod-point.com

    Post: Pod Point Limited, 28-42 Banner Street, London, EC1Y 8QE

    Telephone: 02072474114.

    To exercise the above-mentioned rights given to you by the GDPR, you can also follow the link below and complete the form. Upon receipt of the form, a member of our Data Protection Team will contact you within three business days to verify you and start processing your request:

    Data Request Form: available here.

    You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. However, we would appreciate it if you could give us the chance, in the first instance, to deal with your concern before approaching the ICO.

    The ICO contact details are as follows:

    Information Commissioner’s Office

    Wycliffe House

    Water Lane

    Wilmslow

    Cheshire

    SK9 5AF

    ICO website: https://www.ico.org.uk

    11. Change to the privacy notice

    From time-to-time we may update this notice by publishing a new version. Therefore, to give you the opportunity to review the changes made to the notice, a notification email may be sent to you. Otherwise, it is advisable for you to check this page occasionally to ensure you are happy with the changes.

    Pod Point’s privacy notice publication date is referenced at the beginning of the document. If you would like to be sent previous versions of this notice, please contact us using the contact details provided in the ‘How to contact us’ section above.