Privacy Policy

1. What is the purpose of this privacy notice?

This privacy notice (hereinafter: "Notice") explains in particular in which cases and why MobilityPlus BV (hereinafter: "MobilityPlus", "we", "us") processes your personal data, with whom your personal data is shared, how long we will keep your personal data and what rights you have regarding the processing of your personal data.

MobilityPlus uses and processes your personal data only in accordance with the General Data Protection Regulation and other relevant national legal requirements. Any reference in this Notice to the "Regulation" means a reference to the Regulation of 27 April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of such data.

2. When does this Notice apply?

This Notice applies when we collect and process your personal data in the following cases:

1. you visit our website (https://www.mobilityplus.be/; "Website") or any of our social media pages (including LinkedIn, Twitter and Facebook);
2. you communicate with us by e-mail, telephone, post;
3. you register for our newsletter or other electronic communication;
4. you represent a customer or supplier of MobilityPlus;
5. you participate in one of our webinars or in a trade show or event at which we are present;
6. you apply for one of our vacancies;
7. we install a charge point at your home or provide maintenance or repair
8. you make use of our digital platform to manage your charge post;
9. you make use of our charging cards to charge your car.

The personal data that we collect in the above cases will be processed for the purposes described below. There are some purposes that are common to all cases. This is clarified in detail below.

When you use our Website, you will notice that we use cookies and similar technologies. These technologies allow information to be placed on your device or collect information that was already on your device. To explain what technologies we use, why we do this and what rights you have, you are kindly referred to our Cookie Notice https://www.mobilityplus.be/cookie-policy

3. Who processes your personal data?

The data controller responsible for processing your personal data as described in this Notice is:

MobilityPlus BV, Poortakkerstraat 91 Bus 401 9051 Ghent, Belgium.

VAT number: BE0649.979.281

e-mail: hello@mobilityplus.be

If you have any questions about the processing of your personal data as described in this Notice, please contact us at the above e-mail address.

MobilityPlus reserves the right to change, modify or revise this Notice at its sole discretion and from time to time. We will notify you of any such changes, modifications or revisions through the Website before such changes, modifications or revisions become effective. If we rely on your consent to process your personal data, you will be explicitly asked, to the extent that the changes, amendments or revisions relate to processing based on your consent, to consent to the changed, amended or revised Notice before it becomes applicable.

The personal data we collect, the reasons why we do so, the parties with whom we share it, and the retention period we apply:

3.1. You visit our Website or any of our social media channels

We collect information concerning your browser, IP address, time of visit and other technical data when you visit our Website or any of our social media channels. We do this to enable your visit to the Website or one of these social media channels and to ensure the security of the Website and the social media channels. For this, we rely on our legitimate interest in providing our Website and social media channels to the public in a secure manner.

Without this personal data, it is not possible to use our Website.

These personal data are only shared with our IT supplier as far as the Website is concerned and with the social media providers as far as these channels are concerned. The social media providers also use this personal data for their own purposes and are in certain cases jointly responsible with us for the processing of your personal data. You will find more information about the processing of your personal data by these providers at the following locations:

1. Facebook: https://www.facebook.com/polic... (We have an agreement with Facebook for those cases where we are jointly responsible: https://www.facebook.com/legal/controller_addendum).
2. LinkedIn: https://www.linkedin.com/legal... (We have an agreement with LinkedIn for those cases where we are jointly responsible: https://legal.linkedin.com/pages-joint-controller-addendum).
3. Twitter: https://twitter.com/en/privacy.

We keep this technical personal data for 24 months.

When you contact us through our social media channels, we process your name and the public personal data related to your profile, data regarding the channel you use and the content of your communication with us. We process these personal data in order to communicate with you and to keep a record of the communications we have made through these channels. For this, we invoke our legitimate interest to be able to communicate with the public through our social media channels and to keep an overview of these for later reference.

Without this personal data, it is not possible to communicate with you through our social media channels.

This personal data is only shared with the providers of the social media channels you use to communicate with us. However, it goes without saying that if you send us a public message, this message will then be shared with all users of the social media channel.

We keep this personal data for 5 years.

3.2. You communicate with us by e-mail, telephone or mail

When you contact us by email, we collect your email address, the content of the email and the metadata associated with the email. When you contact us by phone, we may record your name, phone number and the time, duration and content of the call. However, telephone conversations are not recorded except when specifically indicated at the beginning of the call. When you contact us by mail, we record your name, address and the content of your communication. We process this personal data in order to communicate with you, and we invoke our legitimate interest in being able to follow up in a normal way on communications shared with us.

Without these personal data, it is not possible to communicate with you through these communication channels.

Your personal data will be shared with our IT service provider and with other recipients to the extent necessary to give appropriate follow-up to the communication with you.

We keep this personal data for 2 years or as long as there is a contractual relationship.

3.3. You register for our newsletter or other electronic promotional communication

When you register for our newsletter or other electronic communications, we collect your name and email address. We ask for your consent to use this personal data to send you our newsletter or other electronic promotional communications. You may withdraw your consent at any time. For existing customers whom we wish to send advertising about our own products and services, we invoke our legitimate interest in being able to advertise our products and services.

If you do not allow us to process this personal data, it will not be possible to send you our newsletter or other electronic promotional communications.

We share your personal data only with the service providers who assist us in preparing and sending out mail campaigns. If we wish to share your personal data with other companies, we will ask you for your express permission, which you may withdraw at any time.

We will retain your personal data until such time as you withdraw your consent. For existing customers, we will retain your personal data until such time as you are no longer a customer or you have validly objected to the processing of your personal data for this purpose.

3.4. You represent a MobilityPlus customer or supplier

When you communicate or interact with us on behalf and for the account of a MobilityPlus customer or supplier, we collect your name, contact information, your work or principal, your function and role and your communications and interactions with us. We process this personal data for contract and billing purposes, for customer and supplier relationship management, for internal reporting and administrative purposes. We rely on our legitimate interest in being able to process this personal data in the normal course of business.

Without this personal data, we cannot communicate and interact with your work or client and the conclusion and execution of agreements would become impossible.

This personal data is shared with our suppliers, including IT suppliers, banks, insurance companies, collection agencies (if invoices remain unpaid), accountants, legal service providers and others to the extent necessary to achieve the above purposes.

We will process these personal data for 10 years after our relationship with your work or client has ended, unless we receive earlier notification from your work/client that you have changed position or are no longer employed by/for this work/client. This retention period may be extended if necessary to comply with our legal obligations or in the context of an impending or ongoing dispute.

3.5. You participate in one of our webinars or at a trade show or event at which we are present

When you participate in one of our webinars, we will process your email address, your name, your position and employer if you are participating on behalf of a (potential) customer or supplier, and any interventions you made during the webinar. When you participate in a trade show or event at which we are present, whether or not at our invitation, we will process your name, contact details, your position and employer if you are working for a (potential) customer or supplier, and any other information you provide to us at the event or trade show. We process these personal data on the one hand to enable your participation in the webinar, event or exhibition, and on the other hand to be able to contact you afterwards to discuss possible collaborations. In both cases, we rely on our legitimate interest to process these personal data in order to be able to organize or participate in webinars, events and/or fairs and on our legitimate interest to be able to contact the business contacts we make.

If we wish to take a photograph or record at a webinar, trade show or event where you are visible or, in the case of a recording, audible, we will ask you for your consent in advance. However, we will not ask for your permission if you are only indirectly the subject of a photograph or recording. In this case we invoke our legitimate interest to be able to show atmospheric pictures of the events or fairs at which we were present. You can withdraw your consent at any time.

With the exception of your photograph or recording, the processing of your personal data is necessary to allow you to participate in the webinar, event or exhibition.

Your personal data will be shared with our IT suppliers and any parties who assist us in the organization or participation in the webinar, event or exhibition and, if we take photographs or recordings, with service providers who take these photographs or recordings for us. Subject to your consent, we may also distribute these photos or recordings via our Website and social media channels and, in this case, your personal data will be shared with the parties mentioned in 4.1.

The personal data will be retained for the duration of the webinar, event or exhibition and for as long as it can be usefully used to contact you. Your photo or recording processed with your consent we will continue to process until you withdraw your consent. Your photo or recording processed on the basis of our legitimate interest, we will continue to process for as long as this photo or recording is useful in providing information about the events or trade shows we attended.

3.6. You apply for one of our vacancies

When you apply for one of our vacancies or apply spontaneously, we collect the following personal data to the extent that you have made them publicly available: your name, contact details, your professional data, your level of education and any academic background, your knowledge, skills and expertise and any other information that you yourself have made publicly available via social media channels, have included in your CV and motivation letter or possibly communicated verbally during a job interview. These personal data are processed in order to carry out the selection and recruitment process and, under the conditions described further, to include your profile in our recruitment reserve. For the selection and recruitment process, we invoke the necessity of processing these personal data in order to reach an employment contract with you. However, if you are not retained but we find your profile interesting, or you apply spontaneously, we may wish to include your profile in our recruitment reserve. We do this based on your consent which, in the case of spontaneous application, is evidenced by the fact that you apply. If you were not retained in a selection, we will explicitly ask you if we may include your personal data in the recruitment reserve. You can withdraw the given consent at any time.

Without the processing of this personal data, it is not possible for us to consider your application. Personal data that you have made available through social media channels will only be used to the extent that it is relevant in the context of a recruitment.

Your personal data will be shared with our IT suppliers and any parties who assist us in the organization and execution of the recruitment and selection process and, to the extent necessary, with our legal service providers.

Your personal data will be retained throughout the selection and recruitment process and, if you are recruited, for as long as we process employee personal data as explained in the MobilityPlus Employee Privacy Notice. If you are not retained, we will keep your personal data for at least one more year to safeguard our interests in a possible dispute. You will be part of our recruitment reserve for as long as you do not withdraw your consent and for up to two years after receiving your personal data.

3.7. We install a charge post at your home or provide maintenance or repair

When we come to your home to install, maintain or repair a charging station, we collect your name, contact details, address details, details about the situation in your home (e.g. electricity infrastructure, location of the station, etc.), test and usage details about the charging station, details about your order and all communication with you about it. We process these personal data to be able to perform the installation, maintenance or repair, to be able to do the invoicing and administration for this and to be able to draw up our work schedule. These processes are therefore necessary to be able to execute our agreement with you.

Without the processing of this personal data it is not possible for us to execute our agreement with you.

Your personal data is shared with our suppliers, including IT suppliers, banks, insurance companies, collection agencies (if invoices remain unpaid), accountants, legal service providers and others to the extent necessary to achieve the above purposes, but also with independent technicians who assist us in performing the agreement.

Your personal data will be kept for the entire duration of the agreement and for ten years after its termination.

3.8. You use our digital platform to manage your charging station

When you use our digital platform to manage your charge point, we collect your name, email address, gender, address, telephone number, financial data, username, password, language preferences, use that you make of the platform, technical data relating to the device with which you access the platform, technical data relating to your home installation and any other personal data that you yourself decide to make known to us in the context of your use of our platform. This personal data is used to:

• allow you to register on the platform, to manage your charging station, to provide support and for billing and administration purposes, for which we rely on the necessity to perform our agreement with you;
• to keep the platform safe for you and others, to detect fraud and to provide statistical reporting, for which we rely on our legitimate interest to keep the platform free from malware, illegal or harmful behavior and to understand how it is used;
• to improve and expand our services, for which we invoke our legitimate interest to improve existing services and to be able to develop additional services.

Without the processing of this personal data it is not possible for us to execute our agreement with you.

Your personal data is shared with our suppliers, including IT suppliers, banks, insurance companies, collection agencies (if invoices remain unpaid), accountants, legal service providers and others to the extent necessary to achieve the above purposes, but also with independent technicians who assist us in performing the agreement.

Your personal data will be kept for the entire duration of the agreement and for ten years after its termination.

3.9. You use our charging cards to charge your car

When you use our charging cards, we collect your name, e-mail address, date of birth, gender, address, telephone number, financial data and usage data related to your use of the charging card. This personal data is used to:

• allow you to apply for and use a charge card, to provide support and for billing and administration purposes, for which we rely on the necessity to perform our agreement with you;
• to detect fraud and provide statistical reporting, for which we rely on our legitimate interest in deterring fraudulent use of our charge cards and understanding how our charge cards are used;
• to improve and expand our services, for which we rely on our legitimate interest to improve existing services and to be able to develop additional services.

Without the processing of this personal data, it is not possible for us to perform our agreement with you.

Your personal data is shared with our suppliers, including IT suppliers, banks, payment institutions, insurance companies, collection agencies (if invoices remain unpaid), accountants, legal service providers and others to the extent necessary to achieve the above purposes, but also with independent technicians who assist us in performing the agreement.

Your personal data will be kept for the entire duration of the agreement and for ten years after its termination.

3.10. General purposes for which all the above-mentioned personal data may be processed

1. Reporting and statistics - We process your personal data to generate aggregated statistics which we use for internal reporting and to identify trends, developments and opportunities. This always concerns pseudonymized or aggregated data. We base this on our legitimate interest to investigate, better understand and report on our activities. This pseudonymized data is de-identified and kept indefinitely. We may share them in this form with any party.
2. Legal obligations and legitimate requests - We process your personal data to comply with legal obligations, as well as to comply with a legitimate request from competent officials or representatives of the police, judicial authorities, government agencies or bodies, including data protection authorities, for which we invoke our legal obligations.
3. Mergers and acquisitions - We process your personal data to prepare and carry out business transactions, such as mergers, acquisitions or demergers, for which we rely on our legitimate interest in entering into such transactions.
4. Defense in litigation and proceedings - We process your personal data to defend ourselves in litigation and judicial or other proceedings, as well as to gather evidence and prepare our defense, for which we rely on our legitimate interest in being able to defend ourselves in such circumstances.

3.11. Transfers of your personal data outside the European Economic Area

Your personal data is processed within the European Economic Area and is, in principle, not transferred to countries outside it. Should this change in the future, we will ensure that we have taken the necessary appropriate safeguards and additional measures as required by European Union data protection legislation.

3.12. What guarantees do we offer?

1. We will process your personal data only for the purposes specified in this Notice and will share it for those purposes only with the third parties specified in this Notice.
2. We take appropriate technical and organizational measures to protect your personal data against unauthorized access or theft and against accidental loss, alteration or destruction. We only grant access to your personal data on a need-to-know basis and ensure that anyone who has access to it on our behalf is bound by a contractual or legal obligation of confidentiality. However, you understand that safety and security are only best-effort obligations that can never be guaranteed.

4. Rights of the user

4.1. Right of access

You have a right to obtain from MobilityPlus any information about the processing of your personal data as described in this Notice. When MobilityPlus processes your personal data, you have the right to access this personal data.

4.2. Right to rectification/deletion

Inaccurate or incomplete personal data may be corrected or deleted at any time. It is up to you to correct inaccuracies and incompleteness in the first place if you can manage the data yourself. However, you must, when requesting correction, demonstrate why the personal data is incorrect.

You understand that you are only entitled to have your personal data deleted in the following cases:

• When the personal data is no longer needed for the purposes for which it was collected or processed;
• when you withdraw your consent and there is no other legal basis for processing;
• when objections are made to the processing and there are no overriding mandatory legitimate grounds for processing;
• when the personal data has been unlawfully processed; or
• when the data must be erased in accordance with a legal obligation.

Please note that instead of erasure, you may also request that the processing of your personal data be restricted if and when (a) you dispute the accuracy of that data, (b) the processing is unlawful or (c) the data is no longer necessary for the purposes described above, but you need it to defend yourself in legal proceedings.

4.3. Right to object

You have the right to oppose the processing of personal data, but you must explain the serious and legitimate reasons relating to your particular circumstances that justify such an opposition. This explanation is not necessary if you oppose our processing of your personal data for direct marketing purposes.

4.4. Right to data portability.

You have the right to request a copy of the personal data that you have provided to us digitally with your consent or in execution of a contract in a structured, commonly used and machine-readable format.

4.5. How to exercise your rights

If you wish to make a request to exercise one or more of the rights listed above, please send an e-mail to info@mobilityplus.be for all matters relating to data subject rights. An e-mail requesting the exercise of a right may not be construed as consent to the processing of your personal data to the extent that such processing goes beyond what is necessary to process your request.

That request must clearly state and specify the right you wish to exercise and the reasons for doing so, if required by law. It must also be dated, signed and accompanied by a digitally scanned copy of your valid ID card proving your identity. We ask this in order to prevent unauthorized persons from abusing your rights.

We will promptly inform you of the receipt of this request. If the request proves to be well-founded, we will notify you as soon as reasonably possible and no later than thirty (30) days after receipt of the request, unless the question is complex in which case we will request an extension of time in accordance with applicable law.

If you have a complaint regarding the processing of your personal data by us, you can always contact us at the e-mail address mentioned in the first paragraph of this clause. If you are not satisfied with our response, you are free to file a complaint with the competent data protection authority, namely the Belgian Data Protection Authority (https://www.gegevensbeschermingsautoriteit.be).