Version: January 2023
Preamble
The software product PUMP (hereinafter "PUMP") is provided by 800 Volt Technologies GmbH, Heinz-Sielmann-Ring 37, 14476 Potsdam (hereinafter "we" or "us") as the controller within the meaning of the applicable data protection law.
Within our product, we enable you to plan charging trips, charging on public chargers and process vehicle data provided.
When using the product, we process personal data about you. By personal data is meant all information relating to an identified or identifiable natural person. Because the protection of your privacy when using the Platform is important to us, we would like to use the following information to inform you which personal data we process when you use the Platform and how we handle this data. In addition, we inform you about the legal basis for processing your data and, insofar as processing is necessary to protect our legitimate interests, also about our legitimate interests.
You can download this data protection declaration at any time under pumpapp.co/en/privacy/
1. Information on the processing of your data
1.1 Creation of a user account (registration) and login
We do not offer a sign-up so our users are anonymous to us.
1.2 Vehicle data access & storage
- While connecting your vehicle, we store your vehicle access credentials or the generated API token encypted in our cloud in Germany.
- Resetting your password or deleting your vehicle in PUMP will stop any access to your vehicle in the future.
- While accessing your vehicle we only access the vehicles state of charge and status.
- In peticular, we are not tracking your vehicle position at any time.
- Under no circumstances do we send any other commands to your vehicle.
1.3 Processing of vehicle data
We use the vehicle access data to connect the vehicle with the platform, to collect specific vehicle data and to process it.
With the vehicle access data provided by the user, the service logs on to the interface offered by the respective vehicle manufacturer. The data of the respective vehicle are collected via the interface (hereinafter referred to as "vehicle data") and processed on the platform for display and calculations triggered by the user.
If you decide to delete the vehicle connection from the app, all data associated with this vehicle information and the vehicle information itself are deleted immediately.
Vehicle data is the information made available via the interfaces, in particular
- Vehicle model data
- Vehicle status
- Energy consumption
- Battery information
The processing is carried out exclusively for the purpose of providing the service. This data processing is justified by the fact that the processing is necessary for the fulfillment of the contract between you as a data subject and us pursuant to Art. 6 para. 1 lit. b) GDPR for the use of the platform.
1.4 Carrying out and paying for charging at public charging stations
As part of our service, we enable users to charge electric vehicles at selected public charging stations. These charging transactions are billed directly to the user after completion of the charging process on the basis of the conditions displayed in the app. For this purpose, we use a payment service provider to which we transmit the charging transaction data necessary for billing and receive the required personal data collected by the payment service provider for the purpose of billing. As part of this service, an certain amount is reserved by the payment service provider before the start of the actual charging process, which is released again after the end of the charging process and the successful payment.
1.4 Newsletter
Based on your consent (Art. 6 para. 1 a DS-GVO), we will be pleased to inform you about current news about our product in our newsletter.
To receive a newsletter, you must enter your e-mail address and may enter and send further voluntary information. Once you have submitted your e-mail address, you will receive an e-mail from us to the e-mail address you have provided, in which you must click on a confirmation link to verify the e-mail address you have provided.
Your data will only be stored by us for the purpose of sending our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove your newsletter registration in case of doubt.
You can unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the footer of the newsletter.
2. Sharing and transmission of data
Apart from the cases explicitly mentioned in this privacy policy, your personal data will only be shared without your express prior consent if it is legally permissible or necessary.
2.1 If it is necessary for the clarification of an illegal or abusive use of the platform or for legal prosecution, personal data will be forwarded to the law enforcement agencies or other authorities as well as, if applicable, to injured third parties or legal advisors. However, this only happens if there are indications of illegal or abusive behavior. A transfer can also take place if this serves the enforcement of terms of use or other legal claims. We are also legally obliged to provide information to certain public bodies on request. These are criminal prosecution authorities, authorities that pursue administrative offenses that are subject to fines, and the tax authorities.
Any disclosure of personal data is justified by the fact that (1) the processing is necessary to fulfill a legal obligation to which we are subject pursuant to Art. 6 para. 1 lit. f) GDPR in conjunction with (2) we have a legitimate interest in disclosing the data to the aforementioned third parties if there are indications of abusive behavior or in order to enforce our terms of use, other conditions or legal claims and your rights and interests in the protection of your personal data within the meaning of Art. 6 para. 1 lit. f) GDPR do not prevail.
2.2 In the course of the further development of our business, the structure of our company may change as a result of changes in the legal form, the establishment, purchase or sale of subsidiaries, parts of companies or components. In such transactions, customer information may be transferred together with the part of the business to be transferred. Whenever personal data is transferred to third parties to the extent described above, we ensure that this is done in accordance with this privacy policy and the applicable data protection laws.
Any disclosure of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances as necessary and that your rights and interests in the protection of your personal data do not outweigh the protection of your personal data in the sense of Art. 6 para. 1 lit. f) GDPR.
3. Features used
3.1 Website analysis via Cloudflare
On our website we use Cloudflare Analyitcs provided by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107 USA.
It is a privacy sensitive analytics tool, that doesn’t track you across the web. Cloudflare Analytics does’t collect any personal data and does not use technologies like cookies, localStorage or fingerprinting.
Further information on the use of data by Cloudflare can be found in their privacy policy: www.cloudflare.com/de-de/privacypolicy/
3.2 Newsletter dispatch via Mailjet
The newsletters are sent via "Mailjet", a newsletter distribution platform of the company Mailjet, a simplified joint stock company under French law ("Société par actions simplifiée"), registered with the Paris Trade and Companies Register under number 524 536 992, having its registered office at 13-13bis, rue de l'Aubrac - 75012 Paris
Mailjet uses this information to send and evaluate the newsletter on our behalf. Furthermore, Mailjet may use this information to optimize or improve its own services, e.g. for technical optimization of sending and presentation of the newsletter or for economic purposes to determine from which countries the recipients come. However, Mailjet does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.
The privacy policy of Mailjet can be found here: www.mailjet.com/security-privacy/
The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file which is retrieved from the server of Mailjet when the newsletter is opened. In the context of this retrieval, technical information such as browser and system information, as well as your IP address and time of retrieval are collected. This information is used for technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined by means of the IP address) or the access times.
Statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletters recipients. However, it is neither our nor Mailjet's intention to monitor individual users. The analysis serves us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
3.3 Billing of charging transactions
We use Stripe Payments Europe Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland as a third party credit card payment processing company to collect payment information. If you submit payment information, Stripe will store information such as your debit/credit card number, billing address, phone number, and installed application information in order to process payments. In such circumstances, the third-party provider, and not PUMP, stores your payment information on our behalf acting as a data processor, and in order to process payments to your Wallet inside of the application, they process information about your phone number and installed application information. This data is accessed by PUMP at the end of the charging process for billing and invoicing purposes.
Further information on the use of data by Stripe can be found in their privacy policy: stripe.com/de/privacy.
4. Period of data storage
We will delete or anonymize your personal data as soon as it is no longer required for the purposes for which it was collected or used in accordance with the preceding paragraphs. As a rule, we store your personal data for the duration of the usage or contractual relationship via the platform plus a period of 6 months, during which we keep backup copies after deletion, provided that this data is no longer required for criminal prosecution or to secure, assert or enforce legal claims.
Specific details in this data protection declaration or legal requirements for the storage and deletion of personal data, in particular those which we must store for tax reasons, remain unaffected.
5. Your rights as a data subject
5.1 Right of access
You have the right to obtain from us at any time on request information on the personal data processed by us and relating to you, within the scope of Art. 15 GDPR. To do so, you can make a request by post or by e-mail to the address below..
5.2 Right to rectification
You have the right to ask us to rectify the personal data concerning you without delay if it is incorrect. To do so, please contact us at the addresses below.
5.3 Right to erasure
You have the right, under the conditions described in Art. 17 GDPR, to request us to erase the personal data concerning you. In particular, these conditions provide for a right of erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, opposition or an obligation to erase them under Union law or the law of the Member State to which we are subject. For the period of data storage, see also point 5 of this privacy policy. To exercise your right of erasure, please contact us at the addresses below.
5.4 Right to restriction of processing
You have the right to demand that we restrict processing in accordance with Art. 18 GDPR. This right exists in particular when the accuracy of the personal data is disputed between the user and us, for the period of time required to verify its accuracy, and in the event that the user requests limited processing instead of erasure in the event of an existing right to erasure; also in the event that the data is no longer required for the purposes we pursue, but the user needs it to assert, exercise or defend legal claims, and in the event that the successful exercise of an objection is still disputed between us and the user. To exercise your right to limit the processing, please contact us at the addresses below.
5.5 Right to data portability
You have the right to receive from us the personal data concerning you that you have provided us with in a structured, common, machine-readable format in accordance with Art. 20 GDPR. To exercise your right to data portability, please contact us at the addresses below
6. Right to object
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out on the basis of Art. 6 para 1, lit. e) or f) of the GDPR, in accordance with Art. 21 of the GDPR. We will stop processing your personal data unless we can prove compelling reasons for processing that are worthy of protection, which outweigh your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims.
7. Right to complain
You also have the right to address complaints to the competent supervisory authority. The competent authority in this case is the Brandenburg State Commissioner for Data Protection.
8. Contact
If you have any questions or comments regarding our handling of your personal data or if you wish to exercise the rights mentioned in points 6 and 7 as a data subject, please contact hello@pumpapp.co.
9. Change of this data protection declaration
We always keep this privacy policy up to date. Therefore, we reserve the right to change it from time to time and to update it if changes occur in the collection, processing or use of your data. The current version of the data protection declaration is always available under "Data protection" on our website or within the app.