Privacy policy
Privacy Statement
Last modified on: 03.10.2022
I. Introduction
1.Who are we?
Blulinc, with its registered office at Laarnebaan 106B, 9070 Destelbergen and company number BE0775.669.111 (hereinafter “Blulinc”, “we”, “us” or “our”) attaches great importance to your privacy and considers it important that your personal data is always treated with the necessary care and confidentiality.
This privacy statement (hereinafter “Privacy Statement“) provides clarification as to why we ask for your personal data and what we do with it. If you still have questions after reading this Privacy Statement, you can of course contact us at any time.
We clarify that this statement applies only to the personal data that Blulinc processes as a data controller. This means that we determine the purpose and means of processing your personal data.
By “processing of personal data” we mean any processing of data that can identify you as a natural person. You can read more about exactly what data is involved in this Privacy Statement. The term “processing” is broad and covers, among other things, the collection, retention, use or dissemination of that data.
For questions regarding this statement or the processing of your personal data, we would like to refer you in the first instance to your known contact person with us. You can also reach us at any time using the information below:
via email:
privacy@blulinc.com
by letter: Blulinc NV, Laarnebaan 106B, 9070 Destelbergen
2.When does this Privacy Statement apply?
This Privacy Statement applies to the processing of personal data through Blulinc’s mobile Application (hereinafter “the App”) and to all activities associated with it or (commercial) relationships arising from it or maintained with it.
This Privacy Statement should be read together with the other terms and conditions applicable to the App. The data subjects (hereinafter “you,” “your”) to whom this Privacy Statement is addressed are the users of the App.
Some data is processed through the use of cookies or similar technologies. For more explanation on this, please refer to our Cookie Statement.
II.Use of personal data
A. When do we collect your personal data?
We collect and process your personal data as a data controller when you use the App and make use of the related services.When you use the App for the first time, the App requests certain personal data from your mobile device (such as device location, device camera access, etc.). You can change these settings in your mobile device settings at any time. Keep in mind that changing this setting may affect the functioning of the App.
B. What personal data may we collect?
Below we clarify what data we may process from you depending on your relationship with Blulinc. This does not mean that we have all the information about you listed below in all cases. After all, this will always depend on the specific situation and your preferences.Creating a Blulinc account
When you wish to use our Services and create a Blulinc account on the App for those purposes, we may process the following data from you:
Your contact information
for example, your name, phone number, e-mail address, address, …
Financial data
for example, financial identification information such as a bank account number, …
Your personal characteristics
for example, your age, …
The characteristics of the car
e.g. type of car, pictures of the car, license plate, …
Your identification information
for example, a copy of your identity card (only to verify your identity, if necessary, when you wish to exercise one of your rights as a data subject on the basis of the General Data Protection Regulation or in the event of the formation of a purchase contract).
Using the App
If you use our App, based on cookies and certain features provided in the App, we process the data below from you:
Your contact information
for example, your name, phone number, e-mail address, address, …
Your electronic identification information:
for example, your IP address, browser type, connection times, location data, preferred language, …
Your identification information
for example, a copy of your identity card (only to verify your identity if necessary when you wish to exercise one of your rights as a data subject based on the General Data Protection Regulation).
Charging
When you want to use a charging station and scan the QR code on the charging station or locate the charging station and use it to charge your car, we process the following data from you:
Financial data
for example, financial identification information such as a bank account number necessary to make payments on the App.
Data about your recharge
for example, start and stop times, your electricity consumption, the ID of the charging station and the location of the charging station.
C. Special categories of personal data
In principle, we will not process special categories of personal data (i.e. data on racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data to unambiguously identify a natural person, health or the sex life or sexual orientation of a natural person) unless they are transmitted to us with your express consent.
D. What are the legal grounds we use to process your personal data?
We process your data only for legitimate purposes where the processing will always be based on the processing grounds listed in the General Data Protection Regulation.We support the processing of personal data on the following grounds:
- The processing is necessary for entering into, performing or terminating an agreement with our clients and in order to provide you with our services.
- The processing is necessary to comply with a legal or regulatory obligation incumbent upon us.
- The processing is based on our legitimate interests which in specific cases outweigh any possible prejudice to your rights and provided specific conditions are met. We are thinking, for example, of sending marketing communications to you as one of our existing or former customers. Due to the nature of the data available and the fact that you are already taking or have taken similar services from us, we assess that any potential prejudice to your rights is very low, while we believe that the information provided may be of interest to you. Where we rely on this legal ground for processing, we will limit the effects it may have on your privacy by giving you the opportunity to immediately and simply stop such processing.
- The processing is based on your consent. This consent is derived, among other things, from the voluntary and direct provision of your data to us by e.g. voluntarily adding it to your Blulinc account.
E. What are the purposes for which we process your personal data?
We use your personal data for the purposes described below. We collect and process no more and no other types of data than those necessary for these purposes. If we wish to process your personal data for a purpose other than that for which the personal data was obtained, we will contact you before further processing of that data.We collect your data for the following distinguishable purposes:
- operational purposes: for example, the optimization of our App, to keep our services user-friendly, for answering your contact questions and requests.
- business purposes: for example, to manage relationships with our customers and to offer or provide our services to you, to inform you about our policies and services, to transmit customer data to business partners in order to provide the services, to bill our customers for the services provided, to communicate with our employees and business partners regarding the provision of our services to you as our customer or our cooperation with you as our business partner;
- commercial purposes: for example, to send marketing communications, to send newsletters or to keep you informed about activities, offers, promotions, etc. or to verify your satisfaction as our customer;
- legal or regulatory purposes: for example, for legal reasons and procedures, to comply with laws and government orders, to meet our internal and external audit requirements, information security or to protect or enforce our rights, privacy, security or property or those of other persons.
F. How long do we keep your personal data?
We retain your personal data no longer than necessary for the purpose for which the data was collected or is processed.Since the period for which data can be retained depends on the purposes for which the data were collected, the storage period may vary in each situation. Sometimes specific legislation will require us to keep the data for a certain period of time. Our personal data retention periods are based on legal requirements and a balancing of your rights and expectations with what is useful and necessary for providing our services. When it is no longer necessary to process your personal data, we will erase or anonymize your personal data. If this is not (technically or practically) possible, for example because your data is stored in backup archives or because we have a limited need for records containing information about data subjects who do not want us to contact them again in the future, we will retain your data but will not process it further and will delete it as soon as this becomes possible.
G. From whom do we receive your personal data?
We obtain personal data only from you directly.
If we obtain your data from external parties, in principle you should already have been informed of the possible data transfer to us by this source itself. In any case, when we obtain your data from external sources (public or otherwise) and we process it in our systems as a data controller, we will inform you about the processing of your data no later than the time of our first contact with you.
H. How do we secure your personal data?
We attach great importance to data security and have taken the necessary physical and appropriate technical and organizational (precautionary) measures with a view to securing your personal data against loss or any form of unlawful processing.
In the event of a personal data breach, we will comply with all applicable notification requirements related to such breach.
I. Where do we store your personal data?
We store your personal data mainly on IT systems in Belgium. However, the management of some of our IT systems is outsourced to third parties with data held in the European Economic Area (EEA). Where we have engaged IT service providers or other business partners located outside the EEA, which means that your data may also be stored outside the above-mentioned countries, we will always comply with the requirements of the General Data Protection Regulation to ensure the adequate protection of your data in these third countries.
J. With whom do we share your personal data?
We will not disclose your personal data to third parties, except when we are required to do so by law, you consent or when it is necessary within the framework of the execution of the agreement, e.g. to the operator of the charging stations.
Where necessary, we use external service providers, so-called “processors,” who, where appropriate, perform certain processing of personal data on our behalf. We will share your personal data with these external service providers only to the extent necessary for the relevant purpose. The data may not be used by them for other purposes. In addition, these service providers are contractually bound to ensure the confidentiality of your personal data by means of a so-called “processor agreement” entered into with these parties.
Specifically, to the extent necessary as specified below, we share your data with the following processors :
- payment service providers such as Apple Pay and STRIPE;
- the processors that assist us in the IT field in carrying out our activities, for the purpose of efficient digital data management, including keeping our files, sending out transactional emails to customers, sending out emails for the purpose of promoting our commercial activities, hosting and managing our App, mailboxes, providing us with insights into how you use our App through the services offered by Google Analytics, etc;
- government bodies or practitioners of regulated professions such as accountants and lawyers, for the purpose of complying with our legal obligations as a company, and the efficient defense of our interests in the context of any legal dispute, as regards the data strictly necessary for this purpose;
The transfer of your data to the parties identified above for the stated purposes is based, as the case may be, on (1) the necessity of this for the performance of the agreement we have with you as our customer, candidate or business partner, or to take action at your request prior to the conclusion of such agreement, (2) our legitimate interests, (3) the necessity of this to comply with a legal obligation incumbent upon us, or (4) your consent.
III.Rights of the data subject
You have various rights regarding the personal data collected about you. If you wish to invoke any of the following rights, please contact us by e-mail or by mail using the contact information provided above.You have the following rights:
- Right of access and copy: If you wish, you may inspect your personal data and obtain a copy of it;
- Right of adaptation or rectification: If you believe that we have incorrect data about you you can let us know and we will amend it for you; you can also amend it yourself in the Customer Portal;
- Right of data sharing (right to oblivion): if you wish, you can ask us to delete your personal data. We may still need to process that data for other purposes;
- Right to restriction of processing: if you believe that we are processing your personal data unlawfully or incorrectly you can also have this processing restricted.
- Right to object: you can also object to the processing of your personal data. If it is marketing then we will stop processing as soon as possible.
- Right to transfer: if you wish to transfer your personal data, please contact us.
In principle, exercising your rights is free of charge. If your request is manifestly unfounded or excessive, we may charge you a reasonable fee in light of the administrative costs incurred by us. However, in the same case, we may choose not to act on your request. You will always be informed of the reasons if applicable. In any case, we will always inform you of the action taken on your request within four weeks (for simple requests) or three months (for complex or multiple requests).
IV.Complaint options of the data subject
Despite our best efforts to protect your privacy and comply with the relevant privacy legislation, you may disagree with the way we collect, use and/or process your personal data.
Of course you can always contact us in that case, but in addition you also have other means of complaint:
You can complain to the supervisory authority, which you can contact using the details below:
| Via letter: | Data Protection Authority Printing Press Street 35 1000 Brussels Belgium |
| Via email: |
contact@apd-gba.be |
| By phone: | +32 (0)2 274 48 00 |
| By fax: | + 32 (0)2 274 48 35 |
You can also, if you should suffer damages, file a claim for compensation with the competent court.
For more information regarding complaints and remedies, we invite you to consult the Data Protection Authority website:
https://www.gegevensbeschermingsautoriteit.be/klacht-en-beroep
.
V. What about links to other websites and social media?
The App may contain references (e.g. via hyperlinks) to other websites provided by other companies or by social media. Blulinc is not responsible for the processing of personal data through those external websites. Nor does this Privacy Statement apply to those websites.
If you share content via social media, your personal data will be visible to visitors to that social media. Blulinc is not responsible for the processing of personal data through those social media. Nor does this Privacy Statement apply to those social media outlets.
VI. Changes
We may unilaterally decide to make changes to this Privacy Statement. In that case, the new version takes effect immediately. The latest version is available on our App at all times. In case of a substantial change to this Privacy Statement relevant to you, we will – to the extent possible – inform you directly. The date this Privacy Statement was last modified can be found at the bottom.