Privacy Notice

This privacy notice includes important information about your personal data.

1. About this Privacy Notice

1.1 This privacy notice provides information about how Pod Point Limited (“Pod Point”, “we” or “us”) collects and uses your personal data when you visit our website, use our app, products, and services, participate in promotions and surveys or otherwise interact with us.

1.2 This privacy notice applies to our website and app users, home charger users and public charger users.

1.3 This privacy notice explains what personal data are processed about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, options you have regarding your personal data and where to obtain further information about this.

2. Controller

2.1 Pod Point Limited is the controller of, and responsible for, your personal data.

2.2 Pod Point Limited is incorporated in England with registration number 0685174 and with its registered office at 222 Gray’s Inn Road, London, WC1X 8HB.

3. Contact

3.1 If you have any questions about this privacy notice you can contact us using https://help.pod-point.com/s/contactsupport

4. Children

4.1 Our website, app, products and services are not intended for children and Pod Point does not knowingly collect the personal data of children.

5. Types of personal data we collect about you

5.1 Personal data means any information about an individual from which that person can be identified.

5.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Account Data

· Contact Data

· Energy Usage and Charge Data

· Enquiry Data

· Feedback and Review Data

· Grant Application Data

· Location Data

· Marketing and Communication Data

· Payment Data

· Social Media Identifiers

· Technical Usage Data

· Technical Data

· Transaction Data

6. Aggregated data

6.1 We collect, use, and share aggregated data such as statistical or demographic data which is not personal data as it does not directly or indirectly identify you. For example, we may aggregate individuals' Technical Usage Data to analyse general trends in how users are interacting with our app to help improve our service offering.

7. How is your personal data collected?

7.1 We use different methods to collect data from and about you, including:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by email or phone or otherwise. This includes personal data you provide when you:

(a) Purchase our products or services.

(b) Register to use our app.

(d) Request we send you marketing.

(e) Enter a competition, promotion, or survey.

(f) Give us feedback or contact us.

Automated technologies or interactions. As you interact with our website and app, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. When you use your charger, we will automatically receive Energy Usage and Charging Data.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including:

(a) Analytics providers such as Google.

(b) Social networks such as LinkedIn and Facebook.

7.2 Contact and Transaction Data is collected from providers of technical, payment and delivery services.

7.3 Identity and Contact Data may be collected from publicly available sources or received from your building manager or employer for the provision of access to chare points at your home and workplace.

8. How we use your personal data

8.1 The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the legal bases described below.

Performance of a contract with you. Where we need to perform the contract, we are about to enter into or have entered into with you.

Legitimate interests. We may use your personal data where it is necessary to pursue our legitimate interests, for example to manage our business and communicate with you. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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.

Legal obligation. We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent. We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

9. Purposes for which we will use your personal data

9.1 We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where applicable.

Category of data	Purpose(s)	Types of data	Lawful basis
Account Data	To enable us to create an account for you. Operate a secure website and app and provide the services you expect and want from us based on our contract with you, your building manager or employer. To maintain backups of our databases. Where you have agreed to or when the electricity grid load 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, will be exceeded), to turn off your charging unit.	Name, address, email, telephone number, username, password, signature, vehicle details, VIN number, charging unit, MPAN number, Pod Point serial number.	Our legitimate interests (to administer properly and securely our products and services). Performance of a contract with you (to create and manage your account) Our legitimate interests (to create and manage our business customer accounts).
Contact Data	To create an account for you on our systems or app. To verify your identity when you contact us to discuss your account or charger. To respond to your queries, complaints, or disputes. To update about your order. Arrange the installation of charger(s). To keep you updated about your order and installation. Process your grant application. For our analysis and reporting purposes. To send you newsletters, product information, guidance, and marketing communications. Where you have agreed to or when the electricity network is at risk of overload (there is a risk that at a certain period the capacity of the electricity network, at your location will be exceeded), to turn off your charging unit.	Name, email address, telephone number, home, or business address.	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 and exercise our rights under a contract with our commercial client where you represent them). 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. Consent (where you have requested, we send you information, newsletters, or other marketing).
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 app and for you to benefit from many of our smart charging features. To share with network operators for grid load management. We also use this data for our internal analysis and reporting purposes, load management, to inform our product and service development.	The amount of energy drawn through the chargers, chargers used, charger location, charge time (start and end), amount of charge, length of charge, socket size, speed, and cost of charge. Half hourly meter energy use data.	Our legitimate interests (to provide you with information about the use of your charger; to improve our products and services and grid load management). Performance of a contract with you (where we have obligations to provide you with this information).
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.	Performance of a contract with you. 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).
Feedback and Review Data	So that we can read, respond, and consider your feedback and reviews, 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 provide through our services.	Our legitimate interests (to read and use customer feedback to inform our strategy and promote our products and services).
Grant Application Data	To make grant applications on your behalf or support you in making the application where you are eligible for a 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.	Consent (we only make grant applications on your behalf where you have specifically requested for us to do so).
Location Data	To show you the result of your online or app search about the nearest Pod Point charging units to your location.	Geographical location	Our legitimate interests (to direct you to our charging units when you want to use them).
Marketing and Communication Data	To send you newsletters, guides, information about us, updates, and other marketing communications.	Your contact details, your marketing communication preferences.	Your consent – we only send you direct marketing if you have registered (and therefore expressly agreed) to receive this from us.
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 app 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.	Performance of a contract with you
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.	Our legitimate interests (to read and respond to your posts, queries and complaints directed to us by you).
Technical Usage Data	To carry out analytics to determine the success of our website and app features. To enable us to improve our website and app to better fit your needs. To build and improve our website and app, including providing functionality, analysing performance, fixing errors, keeping it secure and improving usability and efficiency.	IP address, MAC address (device ID used to access our website, app, 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.	Our legitimate interests (to maintain and improve our website, app, products, and services; to build and manage our network security).
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 or complaint or dispute and refund you if necessary.	Billing address including postcode, date of purchase, payment details, payment amount and payment location.	Performance of our contract with you. Our legitimate interests (ensuring our financial transactions with customers are managed efficiently; responding to correspondence). Comply with a legal obligation (our financial and legal reporting requirements, such as tax law requirements)

10. Aggregated data

10.1 Aggregated data may 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 website 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 notice. We collect, use, and share aggregated data such as statistical and demographic data for business, marketing, and research purposes.

11. Updating your personal data

11.1 It is important that your personal data is accurate and up to date. Please let us know if personal data is inaccurate or if your personal data changes by completing this form https://help.pod-point.com/s/contactsupport.

12. Sharing your personal data

12.1 To enable the operation of its business Pod Point shares your personal data within its group companies which includes Pod Point’s subsidiaries and holding company, Pod Point Group Holdings plc.

12.2 Where you use public chargers installed at Pod Point commercial customer sites, such as those provided by your building manager or employer, Energy Usage and Charge Data may be provided to the Pod Point commercial customer in report form. Your building manager or employer may be able to identify you. When you use other public chargers, such as those at a supermarket carpark, our commercial customer will not be able to identify you.

12.3 To fulfil our agreements with you and to provide our service we may disclose your personal data to our service providers in the following areas:

(a) Delivery and logistics providers.

(b) Charger installation and maintenance providers.

12.4 We may share your personal data with professional advisors such as Product Partnership Limited, a company regulated by the Financial Conduct Authority who support our appointed representative status to enable you to use Klarna regulated lending to purchase our products.

12.5 We may share your personal data with payment providers such as Klarna Bank AB (publ), Stripe and Apple Pay to enable you to make payments for our products and services.

12.6 Where you request our assistance, we may share your personal data with organisations or government departments that may offer funding or grants in respect of our products and services.

12.7 We may share your personal data with our professional advisers, bankers, and insurers along with any third-party services providers we use in our business operations, such as for customer relationship management or as well as with prospective sellers or buyers of our business or assets.

12.8 We may also share your personal data with energy tariff providers, such as EDF, where you have agreed to participate in a service or product we offer together with them.

12.9 We may share details of your charger serial number, meter point access number, address and postcode with Distribution Network Operators, the National Grid and utility providers to enable them to provide Pod Point with data analytics services and enable the management and security of the national and your local electricity supply.

12.10 We will share your personal data with any public or regulatory authority if required to do so by law.

12.11 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 at https://www.klarna.com/uk/term.... 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 Klarna’s privacy notice https://www.klarna.com/uk/priv....

12.12 We 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.

12.13 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....

12.14 We also share data with marketing partners, such as Facebook, Google, and LinkedIn and third parties connected to advertising, retargeting and analytics. Please see our Cookie Policy for more information.

13. International data transfers

13.1 Whenever we transfer your personal data out of the United Kingdom, we enable a similar degree of protection is afforded to it as it would benefit from in the United Kingdom by ensuring at least one of the following safeguards is implemented:

(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

(b) Where we use certain service providers, we may use specific contracts approved by the United Kingdom data protection authorities which give personal data the same protection in other jurisdictions as it has in the United Kingdom.

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

14. Data retention

14.1 Your personal data will not be kept by us for longer than it is necessary to meet the purposes detailed above, 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).

14.2 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.

15. Security of your personal data

15.1 To prevent unauthorised access, misuse, destruction, loss and alteration of your information, physical, technical, and organisational measures are in place appropriate to the level of risk associated with the processing of your personal data.

15.2 However, we cannot guarantee the security of your personal data whilst it is being transmitted from your device to us.

15.3 Where we have given you (or where you have chosen) a password that enables you to access our products and services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

15.4 We have 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.

16. Marketing and cookies

16.1 If you sign up to receive marketing communications from us, such when you buy our products or services you can choose to opt into marketing emails, we will use your personal data to send you these. 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.

16.2 You can opt out from being sent marketing communications by contacting us using https://help.pod-point.com/s/contactsupport.

16.3 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.

16.4 We use cookies and other tracking technologies to distinguish you from other users of our website to remember your preferences and improve your experience. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

17. Your legal rights

17.1 Under data protection law you have the following rights:

• Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) If you want us to establish the data's accuracy.

(b) Where our use of the data is unlawful, but you do not want us to erase it.

(c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

(d) You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

17.2 If you wish to exercise any of these rights, please contact us using this form https://help.pod-point.com/s/contactsupport.

17.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

17.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

17.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

18. Complaints

18.1 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the United Kingdom regulator for data protection issues www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using dataprivacy@pod-point.com.

19. Changes to the privacy notice and your duty to inform us of changes

19.1 We keep our privacy notice under regular review. This version was last updated on 8 April 2024.

19.2 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 your relationship with us, for example a new email address.

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