Privacy policy.

1 Introduction

Please read this privacy policy carefully as it contains important information on:

• who we are
• how and why we collect, store, use and share your personal information
• your rights in relation to your personal information under the EU data protection regime and introduced by the GDPR (Regulation 2016/679)
• how to contact us or supervisory authorities in the event you have a complaint.

2 About us

When we say “we“, “us” or “our” in this privacy policy, we mean Osprey Charging Network Ltd.  For the purposes of this privacy policy, we are the “controller” of personal information collected from use of the website www.ospreycharging.co.uk.

You can contact us by email at [email protected], or in writing at Osprey Charging, 3rd Floor, Martin House, 5 Martin Lane

Data Protection Officer: [email protected]

3 Personal information we collect about you

We may collect and use the following personal information about you:

• your name and contact information, including email address and telephone number and details about your occupation (when provided by you)
• information to enable us to check and verify your identity, e.g. your date of birth
• your car make, model and registration plate (when provided by you) and other information about your car and its status (exchanged between your car and our chargers), including but not limited to battery size, state of charge and car MAC address.
• your billing information, transaction and payment card information albeit this is encrypted via our payment services provider
• your contact history, purchase history and saved items, and location data relevant to which chargers you have used and when (when you use our Osprey app via your phone)
• information from accounts you link to us, including Instagram, X, LinkedIn or TikTok
• information about how you use our website and app and how you interact with email marketing campaigns
• your responses to surveys, competitions and promotions
• information from any enquiry you make to us

4 How your personal information is collected

We collect most of this personal information directly from you – by telephone, text or email and via our website and app. However, we may also collect information:

• from publicly accessible sources, e.g. any public social media account information
• from cookies on our website and app—for more information on our use of cookies, please see our cookies policy
• from your car through information exchanged between the car and our chargers (such information will be transmitted to us by the relevant charge point manufacturer) for authentication and charging purposes (including for the introduction of autocharge)
• from advertising networks or analytics providers

5 How and why we use your personal information

We will only collect and use your personal data if one of the following legal reasons applies:

• for the performance of our contract with you (which includes providing you with charging services) or to take steps at your request before entering into a contract;
• to comply with our legal and regulatory obligations;
• for our legitimate interests (when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests) or those of a third party (for example, helping to resolve charging issues with a particular car manufacturer); or
• where you have given consent.

The list below explains what we use your personal information for and our legal basis for doing so:

• we use personal information in order to provide you with the services you have requested from us (including vehicle authentication and charging session management), to process payments and to respond to any enquiries or complaints you may make to us and generally manage our relationship with you. This is necessary for performing our contract with you, complying with our legal obligations and for our legitimate interests;
• we may use personal information to send relevant direct marketing communications to you about new services, products, promotions, news and events. We will not send marketing communications to you unless you have consented to this. Further information about marketing is set out in ‘Promotional Communications’ below;
• we may use personal information as required for our legitimate interests to understand how customers use our services and to develop and grow our business. For example, it is in our interests to run competitions and prize draws to promote our services and related products and this may involve processing the personal information of competition entrants. We may also use your data to run incentive programmes for use of our services. Specific details of these programmes will be provided before enrolment; and
• we also have business interests in understanding how users use our services and respond to different parts of our website and app in order to identify areas for improvement, analyse how effective the location of our chargers are and how effective our website and app are. To do this we analyse the information about how you use our chargers, our website and app.

6 Promotional communications

We may use your personal information to send you updates (by email, text message, in-app / push notifications, telephone or post) about our services and products, including exclusive offers, promotions or new services and products.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). We will ask for your consent to send you promotional communications.

We will always treat your personal information with the utmost respect and never sell

it to other organisations outside the group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us at [email protected]
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services and products in the future, or if there are changes in the law, regulation, or the structure of our business.

7 Who we share your personal information with

We routinely share personal information with:

• companies within our group;
• partners who provide space for our charging stations (however any data they receive from us is anonymised or metadata which does not identify you directly);
• third parties we use to help deliver our products and services to you, e.g. payment service providers and charge point manufacturers;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts; or
• third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. For example, we may share information about suspected fraudulent activity on your account with the Police.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8 Where your personal information is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

9 How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is reasonably necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly; and/or
• to keep records required by law.

We will not retain your personal information for longer than reasonably necessary for the purposes set out in this policy including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

10 Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• with our offices outside the EEA;
• with your and our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing to you.

In such cases, we only will transfer your data to contacts in countries approved by the European Commission as providing an adequate level of data protection.

If you would like further information please contact us.

11 Your Privacy Rights

Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact us in writing, with details allowing us to confirm your identity.

– Access: you may request access to a copy of your personal information.

– Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.

– Rectification: you may ask us to rectify any inaccurate information we hold about you.

– Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.

– Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.

– Object: you may object to our processing of your personal information.

– Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

If you are not happy with the way in which we process your personal information, or the way in which we handle any request by you to exercise your privacy rights, you may make a compliant to the ICO by visiting their website at https://ico.org.uk/concerns/or on 0303 123 1113

12 Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13 Changes to this privacy policy

This privacy notice was last updated on 14th November 2024.

We may change this privacy notice from time to time—when we make any substantial or material changes, we will announce this on our main website homepage.

14 Do you need extra help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘About us’ above).