COMMITTED TO PRIVACY
At Electromaps, we are aware of the importance of privacy for all of our users, and we undertake to respect applicable regulations regarding data protection at all times. Therefore, we would like to be transparent and make sure that our users always have access to all of the pertinent information regarding the data processing we perform.
We always try to offer the best services to all of our users, and we are constantly evolving our platforms. Therefore, whenever the evolution of the services or the deployment of new services might mean that we change the way in which we process personal data or we process it for new purposes.
You can write to us at the address indicated above, for the attention of the 'Departamento Jurídico', or you can email us at firstname.lastname@example.org.
OUR PRIVACY POLICIES
At Electromaps, we currently process data in different relationships with our users, not only with users who register to use our application or our services, but also users who simply want to receive information from us and subscribe to our newsletter.
The following information is given for individual processing tasks, which are independent of each other:
Your data will be processed by Electromaps, S.L., with corporate tax ID no. B66513524 and registered address at Calle Foc, 68, 08038 Barcelona (hereinafter, 'Electromaps').It will also be processed by Wall Box Chargers, S.L.U., the parent company of Electromaps, S.L., with corporate tax ID no. B66542903and registered address at Paseo Castellana, no 95, 28046 Madrid (hereinafter, 'Wallbox').
Purposes of the processing performed by Electromaps, S.L.U.
To manage your user account and provide you with access to the services.
To send you communications with information relating to our services, to the creation of your account, regarding the functioning of the services, reminders or incidents, and in relation to changes in the terms and conditions of our services.To allow you to use our payment systems for electric vehicle chargers operated by third parties with whom we have agreements in place.
To offer you information and support in managing any query or consultation that you might send us via any channel.
To discover usage habits for electric vehicle charging services when our payment systems are used (Electromaps key or app), or using geolocation services, to improve our services, and also to discover the areas of usual affluence of our users where there are no charging points.
To run satisfaction or other surveys about our services or e-mobility services.
If you give your consent, to send you our newsletter, and marketing information, offers, promotions or any other relevant information about Electromaps or third parties, in relation to our services, that we consider might be of interest to you. This information may be sent via digital channels or social media, or other third-party services.
Legitimate grounds for processing your data.
For registration on our web portal or in the app and use of our services, we will process the data, in general, to comply with our contractual obligations to users, fulfill any applicable legal obligations or in our legitimate interests.
If you connect with us via any channel, using forms on our portal, email or social media, we will process your data based on our legitimate interest in providing you with the appropriate response.
We will also process data on usage habits for EV charging services based on our legitimate interest in improving our services and our fleet of electric vehicle chargers. Geolocation data will be used for this, too, but only if you give you consent for us to do so.For the purpose of advertising via digital channels, or any other advertising that requires it, we will process data based on your consent, which you may revoke at any time.
Purposes of the processing performed by Wall Box Chargers, S.L.U.
Wall Box Chargers, S.L.U. processes some of your personal and usage data, in relation to both the Electromaps app and web portal, in order to improve its own products and services, discovering EV user needs by analyzing your EV charging service usage habits, including geolocation data.In addition, to use the above information to offer users offers, promotions, surveys, etc., including via digital channels.
Legitimate grounds for processing your data.
Wall Box Chargers, S.L.U. will process your data based on its legitimate interest in improving its products and services, through analysis of the use made by users of Electromaps services.. Wallbox will only process geolocation data if the user has provided their consent for it to be used.
In addition, as long as you have provided your consent when registering, Wallbox may send you marketing communications, including via digital channels. You may revoke your consent at any time, without that affecting any consent given to Electromaps.
In general, Electromaps does not share your personal data with any third party or provide access to the same for any purpose.Without prejudice to the above, depending on the service used by the user, we might need to share your data with the provider of a particular service, based on our contractual obligations (e.g., if you use our app or our payment methods to use third-party chargers that require the user to be identified in order to do so).If any data is communicated to third-party companies, you will be informed of this before the data is shared.
Learn more and exercising your rights.
You can write to us at the address indicated above, for the attention of the 'Departamento Jurídico', or you can email us at email@example.com.
You can exercise your rights to access, rectification, erasure, objection, restriction and portability at the same addresses.In general, any consent may be revoked via your profile, the link in our marketing communications, or by contacting us at the above addresses.
You may also request further information and exercise your rights before Wallbox, or contact your DPO concerning the processing done by Wallbox, by writing to us at Carrer Foc 68, 08038, Barcelona, Spain, or by e-mail at firstname.lastname@example.org
2. TYPE OF DATA PROCESSED, PURPOSE OF PROCESSING YOUR DATA, STORAGE DEADLINES AND LEGITIMATE GROUNDS
Electromaps offers various services to its users, for which, personal data may be processed for different purposes.
We will provide information on each of them below and they will apply depending on whether you request or sign up for each service:
To access our main service, involving information on different EV charging points located on the map and, in certain cases, the hiring of charging services at them, you need to create a user account.
To do so, you need to provide the following necessary data:
- Identification data: username, email, password.
- Geographic data: country and ZIP code.
- Identification data for the user's device (device identifiers, such as identifiers for the use of push notifications, if they have been accepted by configuring the device).
If you were a subscriber to our newsletter before you registered as a user of our services, we may incorporate into your user profile any information we have previously collected about you, in particular about your interests and preferences, as described in the profiling sections of both privacy policies.
As a registered user, you can access all of the information on charging points, and also add new charging points that had not been identified, or change or add more information regarding the different points if it is incorrect or inaccurate, as well as adding photos or comments regarding them.
Therefore, personal data will be processed only to provide you with access to the web portal or the app, and to identify you when you perform any of the above actions.
The data linked to your user account will be stored for as long as you have that account. Electromaps may delete user accounts due to a breach of the terms and conditions applicable to the website or app, or if a user no longer uses the account (e.g., because a reasonable time has passed since your last login). A user can also delete their account at any time. You may change or delete any data that is not required for maintaining your user account by accessing your profile and making any changes you like.
This processing is performed based on the contractual obligations accepted by the user when registering, by which, Electromaps undertakes to provide access to the services and the user to use them in accordance with the terms and conditions.
USE OF THE SERVICES
During the use of our services, we may process additional data regarding our users, generally as necessary to provide these services.
In this regards, some charging points may require payment from their users. Some of these points are associated with Electromaps, so they can be activated by using our app or an 'Electromaps Key Fob' purchased via our online store (shop.electromaps.com).
If you use our app to activate or pay at charging points, we will ask for your payment data in order to charge the amount to your Electromaps virtual wallet. This payment data is managed solely and exclusively by our payment methods provider, so Electromaps will never have access to your credit card data, only to the outcome of the transaction.
If you charge via our app, we may also process the following information:
Billing data, which may include:
- Identification data: Given name and surname;
- Contact data: Telephone number and postal address;
- In the case of legal entities, the company's business name and tax ID number;
Consumer habits based on the charging information provided by each charging point (e.g., charging time, energy charged, etc.);
Base on your use of our services, we may also process other personal data, such as:
- Favorite chargers, which will be saved to your profile;
- We may optionally request information about your vehicle, including make, model, and technical features, such as engine capacity, battery capacity, or whether it is self-drive.
- Comments that you may include regarding each charging point;
- Photos that you may include at each charging point;
- Other personal information that you may include on your profile;
- Any other information that you may provide us with on a form or via any other channel you use to connect with us.
If you accept them, we may send email communications or push notifications regarding the working of services, automated reminders (e.g., push notifications based on your usual vehicle charging times), incidents that may arise, or any other information we have to communicate to you. Under no circumstance will these be marketing communications and they are separate to the consent users give to receiving advertising.
Data on usage of our services may be stored for as long as you have a user account on our web portal or app, although some of it, especially when relating to your usage of charging points or your consumer habits will be regularly deleted and updated on a regular basis in periods of six months.
For the use of some of our web portal or app services, we may ask our users for geolocation data. Use of this information will always depend on how you have set up your device, whether you are using a mobile device or the web app. You may also provide the geolocation information at various intervals, depending on your device:
- Never ask before sharing with the application in use, or always, which will provide us with information about your location at all times, even while the application is in the background.
- Likewise, you may provide information on your 'exact' or 'approximate' location, which will give us more or less precise data.
In practice, as regards personal data processing, the settings you choose will not have any special effect on your privacy, as we only process your personal location data when you use the app to search for a charging point, update your information, add comments or photos, or, especially, if you make a payment or activate at charging point via our app.
In accordance with the above, geolocation data is used for two main purposes:
- To manage your location on the map, in order to help you find nearby chargers. Whenever you wish to use our charging point location service, we will be able to locate you on the map and show you the nearest charging points. As this is a basic feature of our services, this information will be processed based on our contractual obligations.
- To discover your electric vehicle usage habits and charging needs, as long as you use our charging point booking and activation resources or our route planning service. We do not continuously track your location, but specific stops and charging points. We can thus detect areas where our users frequently stop but where there are no charging points and look for ways to partner with nearby specialist companies, stores or establishments to have them install more charging points to satisfy the interests of our users in relation to the placement of new charging points. In addition, this information will allow us to assess your needs in order to offer you our own or third-party services, so it will be used for promotional and advertising purposes, to provide you with relevant information, offers, promotions, etc. Remember that we may discover certain information regarding your location without having to use geolocation services, if you use our app to activate or pay at a charging point, because we know where it is located.
In general, geolocation data for providing your location on the map so that you can locate nearby charging points is processed temporarily while you are checking the map. Some of this information may be stored for a longer period of time to run statistics on your electric vehicle usage and your charging needs.
The use of geolocation is totally optional and is based on your consent, and you may use our services without having to provide us with this information. If you do not consent to the use of geolocation data, you must find your location on the map manually.
Information on your usage habits and charging needs, which allows us to generate a user profile, as described further on, will always be processed based on our legitimate interest in improving our products and services, understanding the needs of our users, and providing information that is always relevant and adapted to our users.
ADVERTISING AND PROMOTIONAL PURPOSES
As long as you give your consent, we may use all of the above data for the purposes of advertising via digital channels.
These communications will include the Electromaps informational newsletter, marketing information that may be sent in relation to our own products or services, including our online store shop.electromaps.com.
They may also include information from third parties with which Electromaps has commercial agreements in place. In these cases, the communications will always be sent by Electromaps, and these third parties will not have access to your personal data at any time, unless you provide it directly to these third parties after receiving the communication.
These third parties are always related to the transport and e-mobility sector and may be companies from the sectors of finance, publishing, technology, home, remote sales, consumer goods, leisure and travel, insurance, energy and water, and more.
Furthermore, Wallbox, as the independent data controller for your personal data, may use it to send its own marketing communications regarding its products and services.
All communications sent by either company may be personalized based on the user profile generated through your use of the service, as described above and specifically expanded in section 3, below, on user profiles.
In general, when we mention our marketing communications or newsletters, we are referring to emailing the address you have provided us with. However, in a broader sense of online marketing, we can also use other tools now to communicate with our users via different channels, such as social media, instant messaging apps (e.g., Facebook, Twitter, WhatsApp or Telegram), and even SMS.
At Electromaps, we use these services to ensure that the interaction with our user community allows us to reach everyone, including through the use of social media, as a less intrusive channel than email.
We always share the least information possible when using these services, and it is information that is in the possession of Electromaps and is also likely to be in the possession of the social network or third-party applications. Email addresses and telephone numbers are usually used for this. The social network or application uses this information to verify whether the user has an account on their own platform, allowing us to create what is called a 'personalized audience' with users who have registered with Electromaps and also have an account with that social network or app.
This creates a group of users for the pertinent social network or app, to which we do not have direct access, i.e., we know the volume of people in the group, and some statistical information, but we cannot see their identity. The social network or app allows us to display advertising directly to this group and allows us to directly communicate with our users via that social network or app.
This type of activity may be performed via various channels, especially social media such as Facebook (Custom Audience), Twitter (Tailored Audiences) or Google (Customer Match), and we only use it for users who have agreed to receive advertising from Electromaps.
In addition, these social networks or applications allow us to share the same user data to find or identify what are called 'similar audiences', i.e., users who have a profile similar to Electromaps users on that social network or in that app, but who are not Electromaps users.
This type of activity is especially performed on social media channels such as Facebook (Lookalike Audience), Twitter (Tailored Audiences) or Google (Similar Audiences). In this case, as we are not having a direct advertising impact on our own users, we use basic data (email or telephone number) from all users, including those who have not agreed to receive advertising from Electromaps.
In relation to data provided to these third parties, as mentioned above, only your email or telephone number will be communicated. And the shared data is encrypted, guaranteeing the confidentiality and security of the same. The entire process is protected via the tool provided by the platform itself, which will allow it to identify you in its database.
In any case, as this is advertising via third-party social media or apps, your settings in relation to receiving advertising from these social networks or apps will prevail. In other words, even if you have agreed to receive marketing communications from Electromaps when registering for any of our services, you will never receive it via these social networks through the above services if you have not agreed to have your data processed for advertising purposes by that network or app. We therefore recommend that all users who do not wish to receive advertising via third-party social media or platforms restrict this in their user profile or available tools, and that they check the terms and conditions of the privacy policies for each platform.
The data required for sending you marketing communications or communications for advertising purposes will be processed for as long as you have a user account for the portal or app and have not revoked your consent for this processing, as long as you provided it in the first place. In any case, rejecting or objecting to receiving marketing communications will not involve the deletion of any data, as it is part of your profile, but it will prevent us from using it for this purpose.
The use of advertising services via third-party social networks or apps is based on our legitimate interest in improving our method of communication with our users and ensuring its effectiveness, in the most transparent and least intrusive way possible. You may object to us using your personal data for these services, and set up your user profile on each third-party social network or app and establish your own communication preferences.
Remember that, in any case, you may see Electromaps advertising on social media, as they allow us to show advertising to users without previously sharing any personal data. In these cases, whether you see this advertising will depend solely and exclusively on your user profile settings on that social network or in that app.
3. DO WE PROFILE OUR USERS? ARE DECISIONS AUTOMATED?
Yes, at Electromaps, we do profile our users to understand how you use our services and determine what your needs may be in the future.
These profiles are purely for marketing purposes so that we can adapt our marketing communications to our users, so they are never based on solely automated decisions, as we ourselves determine the conditions for the segmentation. In this regard, they do not have any legal or similar effect on users. We only use them, therefore, to segment the recipients of our communications based on your use of the app.
For example, based on the information you provide us or your use of the services, we may send you personalized information as follows:
- Information on own or third-party promotions, draws, or contests;
- Launch of own or third-party products, adapted to your vehicle's features (power, battery capacity, charging capacity, etc.);
- Information on new charging points near your usual stopping locations, or expansion of existing charging points;
- Own or third-party information, promotions or discounts at usual charging points (e.g., if you usually use charging points belonging to certain providers);
- Satisfaction or other surveys about our services or e-mobility services.
Under no circumstance will this profiling prevent users from exercising any right, or accessing a product or service, or decrease their capacity for hiring or arranging the same.
The information from these marketing profiles or segmentation is stored for as long as users use our services and have a user account. There is no defined storage time, as the profile is dynamic and is updated periodically, depending on the use made of the services, the portal or the app, and no historical data is stored.
This profiling is performed based on our legitimate interest in ensuring that our users only receive information that you might find useful, avoiding, for example, information on geographical areas or products that is not pertinent to your characteristics.
In accordance with the above, to assess that legitimate interest, we have weighted interests and analyzed benefits to us as the data controller, and benefits for third parties, and concluded that our legitimate interest in relation to the processing prevails over the interests, rights and freedoms of users.
You may, at any time, request more information about the weighting of the legitimate interest by contacting the addresses provided in this policy.
We would also like to remind you that you are entitled to object, at any time, to any processing performed based on legitimate interest.
5. DO WE TRANSFER DATA INTERNATIONALLY?
In general, we try to always process personal data within Europe or the European Economic Area, ensuring compliance with the GDPR by both ourselves and our service providers, who process data on our behalf and under our instructions.
Nonetheless, as a company that provides its services globally, we may need to process data in other countries, which may, or may not, provide the same guarantees as the GDPR. If it were necessary to transfer data internationally to countries that do not comply with those guarantees, we undertake to always do so ensuring that it is protected under the pertinent safeguards, which may include (i) standard clauses approved by the EU, (ii) third-party certificates, (iii) binding corporate regulations, or (iv) any other valid mechanism in accordance with legislation or approved by the competent authorities.
6. DATA STORAGE
Without prejudice to the different deadlines for personal data storage for each of the processing instances, we can store it blocked for an additional period of time as long as it is necessary for defending or exercising our rights and obligations, or fighting any claim that may be brought by a user. Data will therefore be stored up to the deadlines allowed by each applicable piece of legislation, for example:
- Up to 3 years for matters relating to the processing of your personal data, or any matter relating to protecting the rights of users and consumers;
- Up to 5 years for personal claims or actions brought in the civil arena;
- Up to 6 years for fulfillment of our tax obligations; or
- Up to 10 years if legislation regarding anti-money laundering or counter-terrorist financing applies to the user.
In any case, we will only store the information that is necessary in each case, deleting any that is not at the above deadlines.
7. HOW CAN YOU EXERCISE YOUR RIGHTS?
Electromaps and Wallbox undertake to protect your privacy and the confidentiality of your personal data, and we will therefore provide you with an appropriate response when you seek to exercise your rights. You can exercise your rights by contacting us at the postal addresses or emails provided in section 1, 'Basic Information', and duly identifying yourself and clearly stating the object of your request.
In particular, you may exercise the following rights:
- Right to access: you have the right to request access to the personal data we are processing and also obtain information about our processing;
- Right to rectification: you have the right to request the correction of your personal data when it is inaccurate, incomplete or obsolete;
- Right to erasure: you can ask us to delete your personal data when you consider that processing it is unnecessary or unlawful;
- Right to restriction of processing: you have the right to request the restriction of processing of your personal data;
- Right to data portability: you have the right to receive a copy of the personal data you have provided to us, in a structured, commonly used format that can be read by an automatic device, and to transmit it to other processors;
- Right to object: you can ask us to stop processing your data on a legal basis relating to you or if it significantly affects you, unless the processing is necessary for reasons of public interest;
- You have the right to object to automated processing of your data, including processing for profiling purposes, if you have consented to this, and it affects you legally or significantly;
Should Electromaps or Wallbox fail to respond to a query regarding the exercising of your rights, you have the right to file a complaint with the Spanish Data Protection Agency via the link www.aepd.es, by phone at 901 100 099 or by writing to Spanish Data Protection Agency, Calle Jorge Juan no. 6, 28001 Madrid.