1. Important information and who we are
1.1 Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how GRIDSERVE processes the personal data that it collects when you –
• use this website, the self-service portal, and/or any mobile apps operated by GRIDSERVE,
• use a GRIDSERVE EV Charging Facility to recharge your electric vehicle,
• visit one of our Electric Forecourts®,
• lease an electric vehicle through GRIDSERVE.
It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data, and the rights you have relating to that use.
As our products and services are aimed primarily at drivers of electric vehicles this website is intended to be used by persons over 18 years of age; it is not intended for children and we do not knowingly collect data relating to children.
1.2 What is personal data?
Personal data means any information from which an individual can be identified, either directly or indirectly. It does not include data where the identity has been removed (anonymous data).
1.3 Data Controller
In this Privacy Notice whenever we use the words ‘GRIDSERVE’, ‘we’, ‘us’, or ‘our’ we are referring to a group of companies comprising GRIDSERVE Sustainable Energy Limited a company incorporated and registered in England and Wales at Thorney Weir House, Thorney Mill Lane, Iver, SL0 9AQ with company number 10977981, and each of its subsidiary companies registered with the Information Commissioner’s Office as a data controller (all of which have their registered office at the same address). Each company performs a different service as set out below, but they may share certain internal functions (such as HR and IT), so when you interact with GRIDSERVE your data may be collected by, and/or shared among, a number of these companies to provide you with the relevant service. Each company acts as a Joint Controller of your personal data and this Privacy Notice covers the data processing activities of all the companies.
GRIDSERVE SUSTAINABLE ENERGY Limited (ICO Reg. No. ZA775429)
The parent company of the below entities.
GRIDSERVE UK OMM Limited (ICO Reg. No. ZA775428)
The company which is engaged in leasing electric vehicles either via the GRIDSERVE website or at one of our Electric Forecourts®.
GRIDSERVE Car Leasing Limited (ICO Reg. No. ZB212211)
A subsidiary of GRIDSERVE UK OMM Limited which is also engaged in leasing electric vehicles either via the GRIDSERVE website or at one of our Electric Forecourts®.
GRIDSERVE EMEA DEPC Limited (ICO Reg. No. ZA775427)
This company employs GRIDSERVE staff and is registered with the ICO for the purpose of processing employee data.
GRIDSERVE Electric Hubs Limited (ICO Reg. No. ZB334588)
The company which operates the GRIDSERVE electric vehicle chargers not situated in one of our Electric Forecourts® or part of the Electric Highway® network.
Braintree Electric Forecourt Limited (ICO Reg. No. ZA775432)
The company which operates the Electric Forecourt® in Braintree, Essex.
Norwich East Electric Forecourt Limited (ICO Reg. No. ZB331062
The company which operates the Electric Forecourt® in Postwick, Norwich.
The Electric Highway Company Limited (ICO Reg. No. ZA021417)
The company which operates a network of GRIDSERVE electric vehicle chargers situated mainly in motorway service areas.
1.4 Contact Details
We have appointed a Data Protection Compliance Officer who is responsible for overseeing our use of your personal data and the contents of this privacy notice. If you have any questions about this privacy notice, how we use your data, or if you wish to exercise any of your legal rights (as set out in section 7), please contact the Data Protection Compliance Officer using the details set out below.
Email address: firstname.lastname@example.org
Postal address: Data Protection Compliance Officer
GRIDSERVE Sustainable Energy Limited
Thorney Weir House,
Thorney Mill Road,
Iver, SL0 9AQ
If you have a complaint about how we use your data, and we are unable to resolve it, you have the right to raise the matter with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters (www.ico.org.uk).
1.5 Your responsibilities
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
1.6 Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for the ways in which they may use your personal data. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Basics
It’s important that you read the full Privacy Notice to understand what information we hold, how we may use it, and what your rights are – but if you don’t have time to read it all now, here’s a quick summary:
• We collect information that is either personal data (information about you) or non-personal data (such as web pages accessed).
• We collect information about our customers, individuals who visit our sites or premises, website visitors, and employees.
• We collect information to provide services or goods, to provide information, for administration, research, analysis and for the prevention/detection of crime.
• We only collect the information that we need in our quest to provide the best possible service.
• We do our very best to keep personal information secure. For example, we use a secure internet connection whenever we collect personal data online.
• Information is stored by us on cloud computers located in the UK. In addition, we may process your data in other countries both within and outside the European Economic Area but only where the processing is controlled by appropriate contractual arrangements.
• We never sell your data, and we will never share it with another company for their own marketing purposes.
• We only share data where we are required by law or with carefully selected partners who do work for us. All our partners are required by their contract or terms of service to treat your data as carefully as we would, to only use it as instructed by us, and to allow us to check that they do this.
These are the basics, but don’t forget to come back later and read the full Privacy Notice (below), so you’ve got all the details you need.
Full Privacy Notice
3. The data we collect about you
3.1 Information we collect
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name(s), last name(s), username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone number(s).
• Financial Data includes bank account and payment card details, and income details.
• Transaction Data includes details about payments to and from you and details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and/or GRIDSERVE apps.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Surveillance Data images captured by CCTV (and similar surveillance systems) at our premises are classed as personal data if the individuals in the images can be identified, therefore if you have visited one of our premises where CCTV is operating we may have recorded an image of you which will also record the date and time you visited the location and other details such as the make, model and registration number of your vehicle.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your preferred method(s) of communication.
3.2 Aggregated Data
We 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 as it 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. 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.
3.3 Sensitive Data
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 or offences (except where the commission of an offence may be captured by our CCTV system).
3.4 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have entered into, or are negotiating, with you, then if you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us.
3.5 How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your Identity, Contact and/or Financial Data (as defined above) by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes personal data you provide when you:
a. apply for, or purchase products or services from GRIDSERVE;
b. apply for any third-party products or services through GRIDSERVE;
c. create an account on our website;
d. subscribe to our service or publications;
e. request marketing to be sent to you;
f. enter a competition, promotion or survey; or
g. give us feedback or contact us.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
CCTV and similar surveillance systems: If you visit any of the sites where our services are available we may collect images through our use of CCTV (or similar technology) which we may use to protect our assets (or the assets of third parties such as other customers) and to ensure the safety and wellbeing of visitors and staff.
Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
• Analytics providers (such as Google) – some of which are based outside the EU.
• Advertising networks and search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
3.6 How we use your personal data
We will only use your personal data where there is a need for us to do so which cannot be fulfilled in any other way and the law allows us to. Most commonly, we will use your personal data for the following purposes:
• Where we need to in order to perform the contract we have entered, or are about to enter, into with you.
• To resolve a query relating to the supply of goods or services by us to 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.
• Where we need to in order to comply with a legal obligation.
We do not currently use any automated decision-making technology or conduct profiling of the personal data that we collect.
3.7 Lawful basis
Data protection law requires the processing of personal data to be ‘lawful’ and this means it must be undertaken on one of six grounds set out in the legislation. We only use four of these to process personal data, the four we use are set out below and which one we use will depend on which is the most appropriate taking into account the purpose(s) for which, we are processing your data.
Legitimate Interests: means our interests (or the interests of a third party) in conducting and managing our business to enable us (or the third party) to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact (both positive and negative) on you 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).
Performance of a 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, for example we may be required to share CCTV footage with the police to enable them to investigate if a criminal offence has been committed.
Consent: means where you have explicitly agreed to the use of your data for a specific purpose. Generally we do not rely on consent as a legal basis for processing your personal data except to send marketing when we will generally get your consent (although consent is not always necessary, see Section 4 below).
3.8 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send marketing emails or text messages;
• after we have obtained your explicit consent, or
• where we have obtained your email address in the course of providing, or negotiating the provision of, goods or services and the email/text message relates to similar goods or services provided by us. You will be informed, and given the opportunity to object to, this use of your Contact Data at the time it is collected.
You have the right to withdraw your consent at any time, you can do this by clicking the ‘unsubscribe’ link which will be in every marketing email we send or by contacting us using the details in 1.4 above.
5. Disclosure of your personal information
5.1. Sharing your data
We may share your personal data with the parties set out below for the purposes set out in 3.6 above.
Internal Third Parties – other companies in the GRIDSERVE Group acting as joint controllers or data processors.
External Third Parties – Such as third-party service providers (subject to a contract which controls how they use your data), professional advisers acting as data processors or joint controllers (including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services), HM Revenue & Customs, regulators (e.g. Financial Conduct Authority (FCA)) and other authorities acting as data processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We may transfer your personal data outside the European Economic Area (EEA) but whenever we do we will ensure that it is either to a country where the laws provide an equivalent level of protection for your personal data or where this is not the case we will put in place appropriate safeguards, such as binding contracts which incorporate terms approved by the ICO, to ensure that your data is adequately protected and your personal data rights are maintained.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know; they will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you if a breach which presents a risk to your rights and freedoms occurs.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, and, where relevant, for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements (in which case it may be retained for up to six years). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the purposes for which we process your personal data (and whether we can achieve those purposes through other means), the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, and the applicable legal, regulatory, tax, accounting or other requirements.
9. Your legal rights
You have a number of rights under data protection laws in relation to your personal data which are set out below. You will not have to pay a fee to exercise any of these rights, we may however 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. 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; if this is the case, we will notify you and keep you updated.
The rights you have in relation to your personal data are:
Right of access (commonly known as a ‘Data Subject Access Request’): You have the right to obtain confirmation as to whether or not we are processing your personal data and if we are to be provided with certain information to enable you to check whether we are lawfully processing it and to receive a copy of the personal data we hold.
Right to rectification: If the data we hold about you is inaccurate or incomplete you have the right to ask us to correct, or add to, the data, though we may need to verify the accuracy of the new data you provide to us.
Right to erasure (commonly known as Right to be Forgotten): This enables you to ask us to delete or remove personal data but only if 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.
Right to restrict processing of your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Right to request the transfer of your personal data to you or to a third party: We will provide to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to data processed by automated means which you initially provided consent for us to use, or where we used the information to perform a contract with you.
Right to Object: you have the right to object to processing of your personal data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes, including profiling.
Right not to be subject to automated decision making: In some circumstances you have the right not to be subject to a decision based solely on automated processing (including profiling) if that processing has legal, or similarly significant, effects. As stated in 3.6 above we do not currently undertake any automated decision-making or profiling of personal data.
Where we are relying on consent to process your personal data you also have the right to withdraw consent at any time. 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.
If you wish to exercise any of the rights set out above, please contact us using the details in Section1.4. 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.
This notice was last updated on 1st July 2022