HOW YOUR PERSONAL INFORMATION MAY BE USED
Use of personal information under UK data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy. An explanation of the scope of the grounds available can be found here.
The main uses of your information are:
Customer Support and Marketing - to respond to enquiries and to bring you news and offers.
ZPN® uses your personal data for customer care and for personalised communications of ZPN® product and service information, with your consent where necessary. For these purposes, ZPN® may transmit this data to authorised distributors or agents and other authorised companies.
In order to ensure that you receive relevant and personalised communications, we will use some of your data to create an individual customer profile and we may share your personal data between ZPN® companies, authorised distributors, agents and other suppliers of ZPN® branded products and services where relevant. This may include data you have provided to these companies, or which is generated by your use of ZPN® products, for example, contact details, preferences, customer history, vehicle usage data, app usage and online behaviour.
ZPN® Sales & Services – to process your sale, configure and supply charging services electric vehicles
ZPN® will obtain Contact Details, Site Configuration Details, Vehicle Technical Information and Sales and Services Information when you engage with us as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your contract.
This information may be accessed by ZPN® or its agents to troubleshoot technical or other issues relating to the delivery of these services.
The above-mentioned controllers may also receive limited Vehicle location information during the maintenance process which will be used only in accordance with location information safeguards.
EVIE™ – to provide and perform digital services in the vehicle.
ZPN® receives information from these digital services, such as:
The ZPN® Electric Vehicle Information Exchange [EVIE] protocol may collect Contact Details, Vehicle Location Information as well as Device and Service Usage information which ZPN® use in accordance with the detailed service descriptions for each element of the services set out in the EVIE services policy.
ZAPME™ APP – to provide digital and charging services relating to the vehicle through a mobile device.
Compliance with legal requests for your information – to comply with our legal obligations to law enforcement, regulators and the court service.
We may be legally required to provide your information to law enforcement agencies, regulators, courts and third party litigants in connection with civil or criminal proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or we may notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Legal grounds for processing of your personal information
The use of your information set out above is permitted under UK data protection law on the basis of these principal legal grounds:
• Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time through the ZPN® Information Centre
1. on 0800 000 0000 (calls are free of charge plus your phone company's access charge)
2. or sending an email to firstname.lastname@example.org
3. or by writing to us at: ZPN®, THE PROVING FACTORY, GIELGUD WAY, COVENTRY CV2 2SZ
• Where necessary to enter into or perform our contract with you
• Where we need to use it to comply with our legal obligations
• Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting ZPN® business and tailoring news to your information supplied, research and development of electric vehicle related products and services, detecting fraud and criminal activities).
There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it to you as soon as possible after becoming aware of the new basis.
Third parties to whom we may transfer your data
Personal information which we collect may be transferred to or accessed by third parties on our behalf, with your consent where necessary. The types of third parties apart from ZPN® are:
• Marketing and research companies who run and manage marketing and research campaigns
• Event companies who run and manage sponsored events
• ZPN® customer support
• ZPN® distributors or agents who provide services to you
• IT providers who provide us systems and services for customer support
• Card Payment Services providers who operate payment platforms
• Logistics and courier companies who may transport items to you
• Companies who provide transport to you or offer you mobility services (e.g. private hire drivers)
• Law firms who provide legal advice to us (e.g. where there is a customer dispute)
This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement. ZPN® may also transfer your personal information to a third party without your consent if it is in its legitimate interest or if there is a contractual obligation to do so. For example, ZPN® may pass on your personal details to a third party debt recovery agent if you fail to make the payments.
Who may we share your information with
ZPN® is a multi-national company. Your personal information may be accessed by our staff, agents or contractors from a country outside the European Economic Area (EEA) for any of the purposes set out in this policy. These countries may have in place data protection laws which may be of a lower standard than in the EEA. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.
Certain countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing essentially equivalent protection to EEA data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.
How do we collect your personal information
These are the main ways we collect your information:
If you contact us directly via our websites or via our customer hotlines to request information about our products and services.
If you buy a product or service directly from us
If you reply to our direct marketing campaigns
If your contact details are transferred from authorised centres or other third parties
If your vehicle data (incl. vehicle identification number) is transferred to ZPN® while you are having your vehicle charged or you are charging it at home
If other ZPN® legal entities or business partners transfer your personal data to us
If we acquired your personal data from other sources, for example social media sites
If you give information on behalf of someone else you must ensure that you have their permission and that they have been provided with this information before doing so.
If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian
How do we keep your information safe
We use technical and organisational security measures including encryption and authentication tools to protect your personal information, against manipulation, loss, destruction, and access by third parties.
Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:
Tightly restricted access to your data on a “need to know” basis and for the communicated purpose only
Transferred collected data only in encrypted form
Highly confidential data stored only in encrypted form
Firewall protection and IT systems to prohibit unauthorised access e.g. from hackers
Permanently monitored access to IT systems to detect and stop misuse of personal data.
If you have a personal password which enables you to access certain parts of our website or any other portal, app or service we operate, do not forget your responsibility for keeping this password confidential. We ask you not to share your password with anyone.
What information may be collected about you
The following types of personal information about you may be collected:
Information you provide us about your interests
Including the type of vehicles you are interested in
Website and Communication usage
How you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies (our Cookies Policy).
Sales and Services Information
How long do we keep your information
We retain your information only as long as is necessary and only for the purpose for which we obtained them. We restrict access to your information to only those persons who need to use it for the relevant purpose.
Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised or destroyed securely.
Use for marketing: We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for.
For example, used to perform a contract: In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus six years to deal with any queries or claims thereafter.
EVIE and ZAPME APP: We set out how long we retain Charging location and Device Information in relation to each charging service provided in the relevant service descriptions.
Where claims are contemplated: In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.