Easee AS (organisation no. 920 292 046) (“Easee”) collects personal data in connection with product sales and provision of charging services, creation of user profiles in the Easee app/cloud solution/Easee portal, provision of customer support and newsletters, and in connection with recruitment processes. Easee is the data controller for the processing of your personal data, which means that Easee determines the purpose and means for the processing of personal data.
Address: Easee AS, Grenseveien 19, 4313 Sandnes
2 PERSONAL DATA PROCESSED, PURPOSE AND LEGAL BASIS
Easee processes personal data about private customers, contact persons with our business customers, suppliers and other collaborating partners, subscribers to our newsletters, users of Easee’s website who have accepted cookies, application and cloud solution and others who contact Easee, e.g., by using the contact form on Easee’s website. If you apply for a vacant position in Easee, we will process your personal data as part of considering your job application.
Easee collects your personal data in various ways, such as from the information you submit in connection with a purchase of our products or when you register a user profile, from our website, from your use of the Easee app or Easee portal, from correspondence with you via telephone/email/the contact form on our website and in connection with our collaboration with suppliers, business customers or other partners, where we receive your personal data directly from you or from your employer or client. If you apply for a vacant position at Easee, we may collect personal data from the information and references provided by you in your application.
Please note that you are not obliged to provide personal data to Easee. However, without submitting your personal data, you will not be able to access and utilise Easee’s app and cloud solution, and Easee will be unable to provide you with customer support or respond to your inquiries.
Easee processes personal data for the following purposes and legal basis:
- Web shop sales, where name, contact information, credit card and payment information etc. are processed. The legal basis for such processing is Art. 6 (1) lit. b GDPR, since the processing is necessary for the performance of a purchase agreement entered into with you when you made a purchase from us, including to deliver your product and invoice the agreed purchase price.
- Offering and administration of Easee’s app and cloud solution in your Easee cloud account, where name, phone number and email address of private owners and administrators of a charging station or other products and users with access to a product are processed. Further, the address of and technical information about a site, the products installed on the site, consumption or usage history, customers’ purchase history, serial number, customer number, name and ID of key chips, the approximate location of the product and diagnostics data are processed. If a product is connected to a WiFi network, the network’s SSID and password are processed.
The purpose of the processing is to allow users to gain access to products and installations requiring internal authentication, to administrate installations and charging stations and other products, to enable users to see the product history for an installation, to enable users to see their own charge history, to be able to look up and manage user’s access to a site or product and to enable users to log into the Easee app. The app uses the same login and database as Easee’s cloud solution, and your contact information is connected to the sites and products you have access to.
The personal data we require when you register a user profile is necessary to confirm your identity and prevent your user profile from being misused or duplicated.
The legal basis for the processing is Art. 6 (1) lit. b GDPR, since the processing is necessary to fulfil an agreement with you relating to the use of Easee’s interfaces and cloud solution or an agreement entered into with you when you purchased our product, as well as Art. 6 (1) lit. f GDPR based on our legitimate interest in IT and data security and providing good customer service, e.g., by offering you the opportunity to update your personal data in the Easee app.
- Customer support, where personal data such as product number, customer name, address, location and other personal data included in support requests are processed. By interconnecting various non-sensitive personal data such as the abovementioned, Easee will be able to provide customised customer support. The legal basis is Art. 6 (1) lit. b GDPR, where the processing is necessary for performance of a contract with you. This processing of your data otherwise occurs on the basis of Art. 6 (1) lit. f GDPR, based on our legitimate interest in providing you the best possible customer support.
- Respond to other inquiries we receive, where we process name, email address and/or phone number and any personal data included in the inquiry or a complaint. The legal basis of the processing is Art. 6 (1) lit. f GDPR, based on our legitimate interest to answer and handle inquiries or complaints.
- Administration of our relations to business customers, suppliers and other partners, where name and contact information for contact persons (e.g., employees) with our business customers, suppliers and other partners are processed, in addition to personal data contained in contracts, ongoing commercial correspondence, invoices, minutes of meeting etc. The legal basis of the processing is Art. 6 (1) lit. f GDPR, based on our legitimate interest to administer our relations to business customers, suppliers and other partners, including to communicate with our contact persons.
- Provision of newsletters, where name and email address are processed for the purpose of sending you our newsletters, provided that you have consented to receive newsletters. If you have given consent to the processing of your data as described above for the provision of newsletters, the legal basis is Art. 6 (1) a GDPR (Consent). You may withdraw your consent at any time through the Easee cloud or by contacting us using the contact details provided in this policy.
- Improvement of Easee’s services, where personal data contained in technical analyses, logs and information on the use of the Easee app or Easee portal are processed for the purpose of generating statistics and analyses in order to improve our services and enhance the user experience, as well as ensuring the stability in our services. Personal or technical data from your devices used for such purposes are aggregated and anonymized, such that you may not be identified as an individual person based on the statistics or analyses generated as a basis for the improvement of our services.
Please note that some of our products are equipped with position sensors enabling us to identify where the product is installed. Even though you have not provided us with your address in the user profile, we will be able to identify the products’ position through their cellular connection. This information is for safety reasons and will never be used for other purposes than to carry out troubleshooting and to improve our products.
The legal basis for the abovementioned processing is Art. 6 (1) lit. f GDPR, where our legitimate interest is to optimize and ensure the stability of our services.
If you are located in Germany and have given consent to the processing of data from position sensors as described above, the legal basis is Art. 6 (1) a GDPR (Consent).
- Recruitment for vacant positions, where we process CV, school reports, your application, certificates, references (which you provide) and other information you may provide. The consequence of not providing such information is that we may not consider your application or offer you a position in Easee. The personal data are collected from the applicant or from the references provided. The legal basis for such processing is Art. 6 (1) lit. b GDPR, since the processing is necessary to enter into a contract with you based on your request. By applying for a position in our company and sending us documentation, we consider you to request our assessment of the provided documentation, to carry out interviews and call your references with a view to enter into an employment agreement. If you have given your consent to store your applicant data after a recruitment process for longer than a year for potential future vacancies, the legal basis is Art. 6 (1) a GDPR (Consent). You may withdraw your consent at any time by contacting us using the contact details provided in this policy.
- Compliance with statutory requirements and legal obligations, such as compliance with statutory obligations under the applicable accounting legislation and orders from public authorities. In this case, the legal basis of the processing is Art. 6 (1) lit. c GDPR.
- Ensuring the rights of Easee or third parties, to establish, exercise or defend legal claims we believe to have, or that are directed towards us by customers, suppliers, partners, other third parties or public authorities. The legal basis of the processing is Art. 6 (1) lit. f GDPR based on our legitimate interest to establish, exercise or defend legal claims for the enforcement of our rights or the rights of third parties.
3 RETENTION PERIOD
Easee will store your personal data as long as it is necessary to fulfil the purposes for processing as defined above and will as a main rule delete personal data within three years after termination of the contract for use of Easee’s app and/or cloud solution or upon the individual user’s request.
Emails from customers that are sent to our support email address will be stored up to three years from the date the matter was resolved.
If the legal basis for the processing of personal data is consent, Easee will cease the processing of personal data if the consent is withdrawn. You may withdraw your consent at any time.
As regards personal data about job applicants, the personal data will be stored during the recruitment process. If the applicant is not employed in Easee, the personal data will be deleted within six months from the position was filled, unless the job applicant has consented to a further storage period.
However, please note that continued storage of personal data may be necessary due to statutory obligations to which Easee is subject, e.g., storage for accounting purposes, or due to Easee’s legitimate interests, e.g., for the purpose to establish, exercise or defend a legal claim.
Anonymised information, i.e., information that cannot be linked to a natural person, may also be subject to continued storage.
4 DISCLOSURE OF PERSONAL DATA
Easee will only disclose personal data to third parties to the extent Easee has legal basis for such disclosure.
Easee uses data processors to collect, store or otherwise process personal data on our behalf, including in relation to our hosting services etc. The relationship to such suppliers is governed by a data processor agreement, which among other things ensures confidentiality and information security for your personal data.
Your personal data may be subject to processing or storage outside the EU/EEA. In such cases, Easee will ensure that the personal data is subject to appropriate safeguards, by means of entering into the EU Standard Contractual Clauses for such transfers or transfers to countries approved by the EU Commission. Please contact us if you require further information.
Easee may disclose personal data to public authorities to comply with statutory requirements or orders from public authorities, e.g., to comply with obligations under the applicable accounting or tax legislation. The relevant public authorities will be data controller for the personal data disclosed in such instances.
Easee values your privacy rights and has taken reasonable steps to protect the users’ privacy, including by implementation of physical, technical and organisational measures, to prevent loss, alterations, theft and unauthorized access to information stored and otherwise processed.
6 OWNERS AND ADMINISTRATORS OF PROFESSIONAL CHARGING SITES
Please note that when you use a professional charging site, your historic log and user data relating to the charging session will be processed by the owner or administrator of that charging site. The user data contains personal data such as name, Easee key alias, email address and phone number.
Such data are usually processed for invoicing and for statistical and technical purposes, including ensuring charging stability and similar. The relevant professional charging facilities are the data controller for their processing of such personal data. Please contact the charging facilities for further information on their processing of your personal data.
7 LINKS TO THIRD PARTY WEBSITES, SERVICES AND SOCIAL MEDIA PLATFORMS
8 YOUR RIGHTS
As a data subject, you are entitled to obtain access to the personal data we process about you, request that Easee updates or corrects your personal data and/or withdraw any consent to processing. In some circumstances, you are also entitled to request that your personal data is erased, request restriction of processing or object to processing and/or request data portability. In order to utilise your rights, you may contact Easee by using the contact information stipulated in section 1 above.
You are also entitled to lodge a complaint with a supervisory authority if you believe that Easee’s processing of your personal data is contrary to relevant data protection laws. In Norway, the supervisory authority is Datatilsynet.
9 AUTOMATED DECISION MAKING
We do not intend to use any personal data collected from you for any automated decision-making process (including profiling).
In case of changes in the processing of personal data that require your consent, we will collect your consent prior to initiating such processing.
Last updated: 26.03.2021