Global Privacy Policy 6

Greenlots Privacy Notice

We respect the privacy of everyone who uses Greenlots products and services, visits the Greenlots website, or downloads and registers the Greenlots App. Our Privacy Notice describes what personal information we collect, how and why we process it, with whom we share it, and your rights and choices when it comes to your personal information.

Together with this notice, supplementary notices may contain further information to reflect local practices and legal requirements.

If you would like to receive this Privacy Notice in an alternative format (for example in larger print) or If you have any questions about our processing of your personal information which are not answered by this notice, please contact us at support@greenlots.com.

Changes to this Privacy Notice

This Privacy Notice may be changed over time. Any changes will become effective when we post the revised Privacy Notice on Greenlots website or App. This Privacy Notice was last updated on May 27th, 2019.

Special Notice for Customers Under 16

Greenlots does not intentionally collect personal information of those under 16 years old. If you are under 16 years old, please do not send us your personal information (i.e., your name, address and email address). If you are under 16 years old and you wish to ask a question or use the Greenlots Website and/or App in anyway which requires you to submit your personal information , please have a parent or guardian do so on your behalf.

Greenlots DOES NOT SELL YOUR DATA

Greenlots will not sell or otherwise provide your personal information to third parties, and will only make it available to third parties involved in the performance of the service agreed with you. Our employees and any third parties utilized by us are contractually obligated to protect the privacy and confidentiality of your information.

What personal information do we collect?

We collect information directly from you.

When you create a Greenlots EV driver account profile, we will ask for your name, e-mail address, password, phone number, type of EV owned, your contact preferences, and information necessary for answering any security questions. If you decide to become a user of our App, RFID card program, or mobile payments, we may ask you to provide further personal information necessary for the performance of such services and/or authentication such as type of vehicle, information on your driving preferences, date of birth (if collected), license plate number, vehicle location, communications preferences, and mobile number.
When you use one of our EV charging stations, we collect your name, email, phone number and address. For EV drivers who use a BC Hydro labelled charger in British Columbia, please review the Privacy Policy of BC Hydro (available on the BC Hydro website) to understand how your personal data is processed by BC Hydro.
When you register a charge card with us through a program, such as ChargeUp or EZ Charge, we collect your email, vehicle make and model, VIN, name, address, phone number, and credit card information.
When you use your credit card to pay for charging on Greenlots-networked chargers, please be informed that a third-party payment provider will process your payment. Greenlots will not store your credit card data.
If you choose to enter a promotion or contest, we will gather information necessary for participation and awarding you with any reward if confirmed, and to provide you marketing offers if you have agreed to receive these as part of your participation.
When you sign up to receive our newsletters or other publications, we will collect your name and contact information so that we can send these to you.
When you participate in one of our EV Charging Programs, we will collect your business name, address, name, email, phone number, and bank account ACH details.
If you are a user of our Greenlots SKY™ EV Charging Network Software we will collect your name, email address, business address, and phone number.
If you register a charging station with us, we will collect your name, email address, business address, phone number, and charging station location.
We will collect information about how and where you use or purchase our services and products. Such information may include electronic device information, credit card information, any discounts applied to your purchases, IP addresses, log information, browser type, and preferences, location information, online identifiers to enable cookies and similar technologies. Your purchase history includes data regarding (i) specific products you buy, (ii) the total amount of your purchases per transaction, (iii) the time and place of the purchases you make, (iv) the payment method/type of card used, and (v) anonymized or masked credit or debit card numbers, including payment methods embedded in the App (such as mobile payment option).
When you visit our website, information is automatically collected by the technology platforms providing the experience. For example, your web browser or mobile device may share certain data with Greenlots as those devices interact with our website. This data includes device ID, network access, storage information and battery information, cookies, IP addresses, referrer headers, data identifying your web browser and version, web beacons and events.
When you apply to work for Greenlots, we will collect your contact details, resume, and any other information you elect to provide us. We use these details to evaluate your application and to communicate with you regarding that open role.
If you are a Business Customer, Supplier or Investor, we collect personal and business contact information to manage the business relationship and concluding transactions.

On what basis do we process your personal information?

The personal information covered by this Privacy Notice is processed:

with your explicit consent;
to fulfill our obligations under contract or to stake steps at your request prior to entering into a contract;
where it is necessary to conclude a transaction (such as payment information);
where it is necessary for us to comply with a legal obligation; or
for legitimate interests of Greenlots, such as for marketing and promotional purposes, for providing you with offers tailored to your preferences, for the purposes of detecting and investigating fraud, and for responding to security threats.

Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent. Where you choose not to provide us with information set out above for the purposes of using our app or participating in a program, this may affect your ability to fully interact with us.

Where we provide you with marketing or promotional offers, you can change your preferences for receiving such offers at any time. For more information, see “My data” below.

For what purposes do we process your personal information?

We process personal data covered by this Privacy Notice for the following purposes:

Greenlots processes your personal information for the purposes of:

providing you the products and services that you requested;
maintaining and promoting contact and our relationship with you;
sending administrative information or notices to you, such as changes to our terms, conditions and policies;
account management, including account verification (i.e., ensuring that only you or someone you have authorized can access your account and information);
customer service and development;
performance and analysis of market surveys and marketing strategies;
detecting or preventing fraud if you use a mobile payment function;
data analysis, for example, understanding which products and services are of most interest to our users; and
audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.

Sanctions Screening: To facilitate compliance with legal and regulatory obligations, we carry out screening on our customers, business partners, and on individuals associated with our existing and potential business counter-parties. This screening takes place against publicly-available or government-issued sanctions lists and media sources. This screening includes individuals such as customers, directors, officers, sole traders, shareholders and key stakeholders of our current and potential counter-parties. The purpose of this screening is to enable us to protect our assets and employees/contractors, and specifically to ensure that we can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements. This screening does not result in any automated decision making.

With whom will you share my personal information?

Your personal information may be shared with any company that is a member of the Greenlots Group of companies, which includes our parent company, Royal Dutch Shell plc, where necessary for internal administrative purposes, corporate strategy, auditing and monitoring, sanctions screening, and research and development. (For more information on how your personal information will be used for sanctions screening, please see the “For what purpose do you process my personal data” section of this Privacy Notice.)
Your personal information may also be shared with our group of companies to determine whether you have purchased any other products and services from other members of our Greenlots Group.
We may also share your personal information with our group companies where they provide products and services to us that help us to provide products and services to you as our customer.
Your personal information may be shared with authorized agents, wholesalers, licensees, professional advisors, service providers, and contractors of Greenlots.
With your consent, your personal information may be shared with authorized third-party companies that may supply products and/or services to users of Greenlots, such as apps and EV charging programs.
Your personal information may be shared with a competent public authority, government, law enforcement, regulatory or fiscal agency, or as permitted by relevant state or federal law.
Your personal information may be shared as necessary or appropriate to enforce our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Your personal information may be shared with any person to whom Greenlots proposes to transfer any of its rights and/or duties; including in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

We do not share your personal information with third parties for the purposes of direct marketing by them to you, unless you provide your consent.

Shell Single View of the Customer

With the aim of ensuring you have a seamless experience with the Shell group and depending upon the nature of your engagement with Shell, we combine information gathered from the sources referred to above to create a personal profile of you. This enables you to interact with different Shell companies more easily and ensures we have the most up-to-date information about you in order to better develop services and products and to tailor offers relevant to your specific interests.

Please note, however, you can control how Shell uses this information. You can opt-out of having your personal data combined in this way. For further details please refer to the section below: ‘Your rights in relation to your personal data’.

Transfers of personal data

Where the personal information has been transferred to companies within our Group of companies or to authorized third parties located outside of the United States of America, we take organizational, contractual, and legal measures to ensure that your personal data is exclusively processed for the purposes mentioned above, and that adequate levels of protection have been implemented to safeguard your personal data.

Communication and marketing – my choices

Consistent with your choices, you may receive offers that are tailored toward your preferences based on your use of our services, your purchase history, your participation in promotions, surveys, and your use of our website and app.

We may send service updates and notifications to existing users of our app or other services to update you about any relevant changes, or to provide you with any notifications in connection with your use of the app (including for the proper functioning of the Shell Apps) or other services.

You may receive pertinent offers and communications by different channels, and you may update your preferences or unsubscribe as described under “My data” below.

Transaction security and preventing, detecting and investigating fraud

When you use a mobile payment app to purchase products (if available in your market), you may be asked to provide additional personal details to complete the transaction. We may use the personal data you provide to prevent, detect and investigate fraud, and to enforce the terms and conditions of the mobile payment app.

We may share information with service providers involved in mobile payments, including but not limited to your IP address, device ID, or unique identifier, device type, geo-location information, connection information (e.g., wi-fi), and mobile network information.

My data

We aim to keep our information as accurate as possible. Regardless of which US State you are resident in you can request:

access to your personal data;
correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a transaction);
that you no longer receive marketing communications;
that the processing of your personal data is restricted; and/or

that you receive personal data that you have provided to Greenlots, in a structured, digital form to be transmitted to another party, if this is technically feasible.

How to exercise your rights

If you would like to opt out of marketing communications, request access to, correction or deletion of your personal data, or request that the processing of your personal data be restricted, please either-

follow the instructions in applicable communication;
log in to your Greenlots driver account profile to change your data or communication preferences;
email support@greenlots.com; or
call us at +1-855-900-7584

The request must:

provide enough information for us to be able to verify you are the person whose personal information we hold or are an authorised representative of that person;
describe your request in enough detail so that we can properly locate the personal information the request or request relate to.

We cannot respond to your request unless we can verify your identity or authority to make the request. If possible, this can be done by making the request via your password protected account or in the relevant Greenlots App. If not, we will aim to verify your identity based on personal information we already hold about you. If we need to request further information from you in order to verify your identity, we will only use that personal information for the purposes of identifying you or that you have authorized the request.

We will respond to your request consistent with applicable law.

Who can I contact if I have a query, concern or complaint?

If you have any issues, queries, or complaints regarding the processing of your personal data, please contact us at support@greenlots.com.

Without prejudice to any additional rights you may have in line with local law, you may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands – Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague at privacy-office-SI@shell.com.

Security of your personal information

We have implemented technology and policies with the objective of protecting your personal data from unauthorized access and improper use. In particular, we use encryption and apply authentication and verification processes for access to our services, and we regularly test, assess and evaluate the effectiveness of our security measures. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Who can I contact if I have a query, concern or complaint?” section above.
If you communicate with us through social media

If you choose to interact with Greenlots services such as our Website, App or content through social media such as LinkedIn, Facebook, Instagram, and/or Twitter, your personal data (such as your name and the fact that you are interested in Greenlots) will also be visible to all the visitors of your personal webpage on LinkedIn, Facebook, Instagram, and/or Twitter, according to your privacy settings on the social media services. Greenlots is not responsible for the processing of such personal data or the privacy policy of such social media websites.

When you communicate with us through social media (for example, when you post a comment, upload media, send a personal message or become a fan of us by clicking the “Like” button), we may receive personal data about you (such as your user name, profile photo, your hometown, your email address, and your gender). We will use the data received from social media in accordance with this Privacy Notice.

How long we retain your data
We retain personal information for as long as needed or permitted for the purpose(s) for which it was obtained, and consistent with applicable law, and will be deleted or rendered anonymous (such that it will no longer be possible to identify you) in our systems:

(1) without undue delay upon you requesting that your account profile is deleted; OR
(2) within 3 years for all subscribed services after our last interaction with you or your last participation in a promotion; OR
(3) in relation to financial transactions, (including those made through the Greenlots App, your personal data will be held for 10 years from the transaction.

Cookies and similar technologies

Greenlots uses cookies and similar technologies that collect and store information when you visit our website or use our app. This is to enable Greenlots to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits, and identify these when you return so that we can improve your experience. You can control and set your cookie preferences by adjusting your browser settings.

California consumers*

*For the avoidance of doubt these provisions apply to all consumers whose personal information is processed by Greenlots regardless of the State or Country you are resident in. These rights are without prejudice to any additional rights you may have in line with local law.

In relation to your rights please see the section above entitled Your rights in relation to your personal data.

As stated above, we do not sell your personal information.

We do not and will not discriminate against you for exercising any of your rights explained in this Privacy Notice regardless of whether the California Consumer Privacy Act applies to you including:

denying you access to goods and/or services;
charging you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
providing you a different level of goods and/or services;
suggesting you may receive a different price or rate for goods and/or services or a different level of quality of goods and/or services.

The categories of personal data gathered about you during the preceding 12 months are those listed above under ‘What personal data do we process about you? Collection of information’ but only to the extent this is relevant to you.

The categories of third party to whom we have disclosed your personal data during the preceding 12 months are those listed above under Who will we share your personal data with? but only to the extent this is relevant to you.

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