Privacy Policy and Cookie Notification

Last amendment: 05.07.2023

Introduction

This Privacy & Cookie Policy (hereinafter Privacy Policy) is adopted by Multicharge OÜ (Estonian business registry code 14627725) (hereinafter VOOL)

It is important for VOOL to respect your privacy and to comply with all applicable laws and regulations to protect your personal data. VOOL processes personal data in accordance with applicable law, including Regulation 2016/679/EC of the European Parliament and the European Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. In matters not regulated in the Privacy Policy, VOOL is governed by the applicable legislation.

With this Privacy Policy we want to explain what kind of data we collect if you visit our website www.vool.com, make purchases in our web shop or use our application for operating electric vehicle charging device or for using charging services.

Unless otherwise defined in the Privacy Policy, the terms such as personal data, data subject, data processing, controller and processor are used in the meaning given to them in Article 4 of the General Data Protection Regulation (2016/679/EU; the “GDPR”).

Collection and use of personal data
Processing of personal data is necessary for a performance of a contract with you (including preparations to enter into a contract at your request) or for our legitimate interests. In certain cases, the legal basis for the processing of your personal data is your consent, which you will be asked to give when you visit our website, VOOL application or otherwise communicate with us. The personal data that we collect is used solely for the purposes described in this Privacy Policy. We shall ensure that any personal data processed is not subsequently used for purposes that are not in accordance with the original purpose of the collection of such personal data unless the customer consents to such use.

We collect personal data for the purposes specified below.

User account and application
When you create a user account and use VOOL application for operating electric vehicle charging device or for using charging services or any other services offered via VOOL application we will collect and store the data you provide to us. This data includes:

• name
• e-mail address
• mobile telephone number
• location data and language
• charging history
• billing data and history
  

Collection of such data is necessary to enable users to confirm their identity when creating a user account and logging in to use the profile and use the functionalities of VOOL application. If necessary, we use this data for customer support services.

Purchases
When you purchase a product or service from VOOL, we will record the following data:

• name
• billing address
• payment information
• mobile telephone number
• e-mail address
• purchase history
• product type and serial number
• delivery and installation address.
  

When you purchase a product or service from VOOL, we process your personal data to process the order, finalize and complete the transaction, issue invoices, and arrange the delivery and installation if agreed so. We store your purchase history data to be able to confirm your rights under warranty.

Support inquiries
When you contact our support team, we may store personal data such as:

• customer name
• telephone number
• address
• e-mail address
• location
• diagnostics and meter readings
• type and other data of your vehicle.
  

VOOL may use personal data to customize user support and improve customer service by means of complete data on usage, error messages, etc.

Website

We primarily collect data on the website through “cookies”. Cookies generally do not collect personalized information. You can find more information about cookies below.

We collect data on the website for statistics, for evaluating the efficiency of a user’s visit, for compiling reports to the website operators about activities on the website, and to improve the user experience of website visitors. Cookies are used to collect data with your consent unless the use of cookies is necessary for the operation of the website. Specifically, we may use the data we collect for the following purposes:

• to maintain, manage, develop, personalize, and expand our website;
• to collect statistics, so that we can provide better services and/or offers, and understand and analyze the behavior of website visitors;
• to prevent fraud and protect our website;
• to improve service quality and provide more efficient browsing solutions;
• to develop and improve new products, services, or functionalities;
• to study trends and evaluate the efficiency of our advertising campaigns.
  

Giving consent, on which the processing is based, is a voluntary act. We retain your personal data for the duration of the consent. You have the right to withdraw your consent at any time. In such case we will stop processing your data as soon as consent is withdrawn.

Third party service providers

VOOL discloses personal data only to the extent and in the form necessary to fulfill the purposes listed in the Privacy Policy. VOOL may disclose personal information to authorized persons and controllers who need access to the data to provide services to us (such as website administration and development services).

VOOL generally ensures the processing and storage of data in the territory of the European Union. However, VOOL may also use authorized processors, whose servers are located outside the European Union. VOOL ensures the comprehensive security of your personal data by implementing the protection measures required by law if necessary.

We use third-party service providers such as:

1. Contractors and companies that support us on specific aspects of our business such as IT, accounting and legal advice;
2. Delivery service providers;
3. Installation and maintenance service providers;
4. Warranty handling services;
5. Payment processors;
6. Other providers of services necessary to fulfil our contractual obligations towards the customers.
   

We may transfer information about your vehicle, personal details and information about your transactions to the charge point operators to activate the charge point, to handle any issues related to the use of charging services and invoicing.

We may disclose your contact details and other relevant data we have recorded about you to a supplier if you order external services.

If you have consented to electronic marketing, we also use the following types of external service providers:

• Ad networks, such as Google and Facebook
• Agencies, such as marketing agencies, statistics agencies and analytics agencies

Your contact details and other relevant data we have recorded about you may be disclosed to these service providers. We use this type of service provider to provide you with relevant ads, offers, content and recommendations and to perform analytics in order to improve and further develop our services. We also measure how well we succeed in this using, among other things, questionnaires.

Public authorities, etc.
In special cases, personal data may be disclosed to a relevant public authority or other agencies where required by law.

Cookies

www.vool.com uses “cookies”. A cookie is a text file stored onto a user’s device when they visit a website. Cookies are used to set and store preferences, regional settings, service usage options, and more.

If you wish, you can disable the use of cookies in your browser settings, but in this case the service offered to you may be disrupted.

Cookies are divided into persistent and session cookies. Persistent cookies remain on your personal computer or mobile device even after you close the browser or computer. Session cookies, however, are deleted as soon as the browser is closed.

Cookies are divided according to their purpose:

• Necessary cookies. Session cookies, the purpose of which is to enable you to use the services offered on our website. These cookies help to authenticate users and prevent the malicious use of user accounts. Without these cookies we will not be able to provide you with the services you request.
• Notification cookies. These cookies indicate whether users have accepted the use of cookies on the website.
• Functionality cookies. These cookies allow your browser to remember the choices you make when using the website, such as saving your login details or language preferences. The purpose of these cookies is to provide you with a more personal experience and to prevent you from re-entering your preferences.
  
  

Retention and deletion of personal data

We shall not process your personal data for longer than necessary. In each particular case, the data retention period depends on the exact nature of our relationship, the legitimate interest of VOOL and the statutory basis (retention of records, retention of accounting documentation, expiration of legal requirements, etc.).

In certain cases, it may be necessary to anonymise the personal data instead of deleting it. Anonymisation refers to removing all identifying or potentially identifying characteristics from the datasets that are kept.

Your rights

We are dedicated to ensuring that all data subject rights arising under applicable law are always guaranteed to you. In particular, you have:

1. the right to withdraw consent for processing your personal data at any time. Withdrawing your consent 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;
2. the right to access the personal data that we process about you;
3. the right to request that we rectify any inaccurate personal data about you;
4. the right to request that we erase your personal data and/or restrict processing of your personal data if we do not have valid legal basis for processing;
5. the right to receive your processed personal data in a structured, commonly used and machine-readable format and have the right to transmit your personal data to another controller;
6. the right to object to the processing of your personal data.
   

If you believe that your rights have been infringed, you may contact and lodge a complaint to the supervisory authority applicable for your jurisdiction (Data Protection Inspectorate in Estonia, address Tatari 39, Tallinn 10134, [email protected] or other competent authority in your jurisdiction).

Changes to this Privacy Policy

We periodically need to update this Privacy Policy in order to provide correct information about how we process your personal data. We will inform you separately in the event of significant changes. You consent to the new Privacy Policy by continuing to use VOOL´s products and services.

If you have any questions about this Privacy & Cookie Policy or if you have any concerns about how we use your personal or if you want to exercise your rights as described above, you may contact us via e-mail [email protected].