Privacy Policy.
I. Introduction
1. In addition to its online and web services, GreenFlux Assets B.V., Amsterdam, Netherlands (hereinafter referred to as "GFX") also provides a mobile Charging APP to its customers and users, the "CHARGE ASSIST APP".
The CHARGE ASSIST APP provides various functionalities and tools for locating charging stations and handling charging processes in the eMobility sector and may be downloaded onto mobile devices (so-called smart devices).
In this Privacy Statement for the CHARGE ASSIST APP, we explain who we are, how, when and for what purposes we process your personal data in connection with the provision and use of our related SERVICES via the CHARGE ASSIST APP, including information how you can exercise your right to privacy, and any other information that may be relevant to you. This Privacy Statement may be amended from time to time. We will inform you of any significant changes that affect the use of your personal data. You will find the current version under the link Privacy statement within the CHARGE ASSIST APP.
In addition to this Privacy Statement for mobile APPs, the currently applicable (general) Privacy Statement of GFX shall apply, which can be found at www.greenflux.com/privacy.
2. Please note that the language versions and/or translations of the Data Privacy Statement provided are for convenience only. In the event of a dispute over interpretation, the English text shall always take precedence.
II. Who is responsible for your personal data? / Which Supervisory Authority is responsible for us?
Controller | Data Protection Supervisory Authority |
---|---|
GreenFlux Assets B.V. Email: info[at]greenflux.com | Autoriteit Persoonsgegevens autoriteitpersoonsgegevens.nl |
III. Which data is processed for the download of (mobile) APPs?
1. When downloading our APPs from the relevant APP stores (e.g. Apple App Store or Google Play), certain personal data required for the download will be transferred from your smart device to the respective APP store.
2. In particular, the e-mail address, the username, the customer number of the downloading account, the individual smart device identification number, payment information in the case of APPs to be paid as well as the time of the download will be transmitted to the APP Store.
3. GFX has no influence on the collection and processing of this data. This data collection and processing is conducted exclusively by the APP store selected by you. GFX is not responsible for this collection and processing; the responsibility for this data processing for the download of APPs lies solely with the respective operator of the APP store.
IV. Which data is processed when using the GFX CHARGE ASSIST APP?
The scope of the processing of personal data by GFX in connection with the provision of the GFX CHARGE ASSIST APP depends on the services and functionalities used via the respective APP. If the user does not actively close the APP, it will continue to run in the background unless the user's smart device closes it, e.g. for reasons of system maintenance.
In general, GFX only collects and processes personal data insofar as this is necessary (i) for the fulfilment of the contract or provision of the agreed services and functionalities between the APP user and GFX (Art. 6 (1) lit. b GDPR) or (ii) if data is necessary for the functioning of the APP under legitimate interests and the interests of the user in the protection of his/her personal data do not prevail (Art. 6 (1) lit. f GDPR).
Depending on the respective use and the services or functionalities provided via the APP, the following types of data may be processed:
1. To Login/registration/authentication
The GFX CHARGE ASSIST APP’s functions to a limited extent without registration or login. Without a registration, the data cannot be assigned by GFX to a person or user.
If the user wishes to use extended functionalities of the GFX CHARGE ASSISST APP, an authentication via registration and activation of the respective user is required for security reasons. The completion of registration process requires the User's consent to this Privacy Statement.
After successful registration, the user can log in to the GFX CHARGE ASSIST APP with their respective login data and use the extended functionalities. After a certain time of inactivity, a logout may take place automatically. The User must then login again to use the extended functionalities.
2. (technical) Device information required for providing provide our services.
For the provision of our mobile APP's and/or the provision of the services and functionalities available via the APP's, the collection and processing of device information is required. In particular, the following device information may be processed to provide our services and functionalities:
- IP address | |
- device style and device name. | - time zone difference to GMT. |
- device-specific settings (e.g. browser, operating system, version status language). | - content of requirements (requested service / functionality). |
- APP settings. | - transferred data volume. |
- APP features. | - notification whether data exchange was successful / complete. |
- date and time of request. | - crash APP / error message. |
3. Data which is provided / entered by the user.
If users provide data in the context of using the GFX CHARGE ASSIST APP and/or store or upload data in the APP, GFX processes this data in connection with the respective provision of the services and functionalities.
For a registration, data are required such as first name and surname, password as well as optional information such as mobile phone number, landline phone number, birthday, job position and/or charging card number, depending on the respective data fields available.
Furthermore, information on Charging Processes as well as data such as photos, PDFs or other documents and information can be added, which the user voluntarily provides or uploads via his/her smart device while using the APP.
The legal basis for such processing is Art. 6 (1) lit. b GDPR (performance of contract). The provision of such data is voluntary. If data essential for the provision of the offered services / functionality are not provided, there may be possibly restrictions / limitations on services provided.
4. Location data / navigation data / GPS data of the GFX CHARGE ASSIST APP
The GFX CHARGE ASSIST APP only collect and process location data if the user has authorised / grant access to the location data in his/her smart device. The authorisation is automatically requested in the course of the installation of the mobile APP via the operating system and can be subsequently changed again via the settings within the smart device after installation - depending on the respective smart device.
Location data will only be used by GFX CHARGING APP if this is necessary to fulfil the respective services and/or functionalities of the APP (e.g. stop and service point finder, tour processing, etc.).
Location data is processed within the mobile APP on the user's smart device and can be transmitted to the GFX as part of the GFX CHARGING SERVCIES for visualization purposes (track & trace) and/or tour management purposes. In addition, GPS information is used for the support of tour charging and alarms.
5. Retrieval of / access to „data and information provided by the GFX CHARGE ASSIST APP
Via the GFX CHARGE ASSIST APP, we may offer retrieval of or access to data from central GFX CHARGE Services. This can include, for example, access to tour data, order and delivery documents regarding Charging Processes and/or, the customer addresses.
The scope of the access possibilities depends on the respective service and/or the respective functionalities of the APP as well as on the access authorisations granted to the user by the customer. Legal basis for the processing is Art. 6 (1) lit. b GDPR.
6. Analyses for the purpose of system security / protection against system breakdowns
The GFX CHARGE ASSIST APP uses Firebase, an analysis and monitoring tool. The service provider is Google Inc. Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for the European area. GFX only uses Firebase for crash analysis and related analysis of APP usage on an anonymous or aggregated basis; such analyses are used by GFX exclusively for the purpose of improving / maintaining the GFX CHARGE ASSIST APP. The legal basis is Art. 6 (1) lit. f GDPR (legitimate interests); the legitimate interest lies in ensuring system security and improving the GFX CHARGE ASSIST APP in this respect. As far as the service provider Google also processes data in the USA for the aforementioned purposes, this currently takes place on the basis of a Data Privacy Framework certification1 as well as the so-called standard contractual clauses of the EU Commission (Art. 46 (2) and (3) GDPR). Further information from Google on data protection at Firebase can be found at firebase.google.com/terms/data-processing-terms.
V. Who has access to your personal data?
For the provision of our APP services, we sometimes involve third party service providers who may act on our behalf as part of the service provision. These service providers may come into contact with personal data in the course of providing the service and constitute third parties or recipients within the meaning of GDPR. Where necessary, corresponding Data Processing Agreements (DPA’s) are in place (Art. 28 GDPR). As far as an involvement outside of a Data Processing takes place, we ensure that this occurs exclusively in accordance with the requirements of the GDPR and only if there is a corresponding legal basis.
We use the following service providers for the GFX CHARGE ASSIST APP:
Firebase (Google) | Keycloak (https://www.keycloak.org/) |
VI. What rights are users entitled to under the GDPR and how can these rights be asserted?
You have the right of access, rectification, and/or erasure of personal data. In addition, you may also have the right of restriction of processing concerning your personal data, the right to object to processing as well as the right to data portability.
To exercise these rights please contact our Data Protection Officer (see above). You also have the right to file a complaint with a data protection supervisory authority about the processing of your personal data by us.
VII. How can you contact us?
If you have any questions about the way we process your personal data, please read this Privacy Statement first. For additional questions or complaints, please contact:
GreenFlux Assets B.V.
Joan Muyskenweg 22
1096 CJ Amsterdam
The Netherlands
privacy[at]greenflux.com
1 https://www.dataprivacyframework.gov/list