This Privacy Policy applies to AQUA SUPERPOWER LIMITED, whose registered office is at Highland House, Mayflower Close, Chandlers Ford, Eastleigh, Hampshire, United Kingdom, SO53 4AR and whose company number is 13246216; and any related bodies corporate (we, us, our);
The Policy explains how we process Personal Data (defined below) that is regulated by the General Data Protection Regulation (EU) 2016/679 and the law(s) implementing the GDPR in our jurisdiction and complies with their requirements. It applies in respect of all Personal Data processed by us, including the Personal Data of clients, member businesses and suppliers.
We may update this Privacy Policy from time to time. The most current version will be posted on our website https://www.aqua-superpower.com where this will be updated. It will be effective from the date of posting. It is your responsibility to check our website from time to time in order to determine whether there have been any changes.
The kind of Personal Data we collect
Personal Data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (Personal Data).Sensitive data is Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation (Sensitive Data).We only collect data that is necessary for its intended purposes. The kinds of Personal Data we collect and hold includes:
- For users of our app or website, contact information such as name, postal address, email address and telephone number.
- Mandatory information is marked with an asterisk in forms. Your current location is collected when you use our Start a Charge or Map features, but not stored. If you are using the AQUA network for a single charging transaction through our Guest Access, the categories of data collected for Guest Access are:
- Your email address to enable delivery of the Charging Session receipt;
- Your payment card details to pay for the Charging Session and any other requirements as set out on our app or website
- For our suppliers and service providers, names and contact details of individuals working for those suppliers and service providers, who we deal with;
- For other individuals, name, contact details and any other information relevant to our interactions with you.
How we collect Personal Data
3.1 Personal Data generally
We collect Personal Data about you for the following reasons: (1) the collection is necessary for us to provide our services; (2) it is in our legitimate interest to collect this data for the purposes of providing the services; (3) the collection is necessary for us to comply with our legal obligations or applicable law; or (4) we have consent, where applicable or required under law.
We will generally collect your Personal Data from you directly. There are however, circumstances in which we collect Personal Data from third party individuals or business entities. Where we collect Personal Data from a third party, we will handle that information in accordance with this Privacy Policy and any obligations we have to that third party. If you provide to us Personal Data about another person, we are relying on you having addressed all relevant consents, notifications and other requirements to enable us to process the Personal Data for our purpose of collection.
3.2 Sensitive Data
We will only collect, use and disclose Sensitive Data about you where you have provided your explicit consent to the collection of that information, or where we are required or authorised by law to do so, or where necessary for reasons of substantial public interests as permitted by local data protection laws. In providing any consents to the collection or handling of Personal Data (including Sensitive Data), you consent to us collecting, holding, using and disclosing the information you provide in accordance with the terms of those consents and this Privacy Policy.
3.3 If your Personal Data is not provided
If you do not provide us with your Personal Data when requested, this may limit the assistance we are able to provide to you, including assistance we are contracted to provide on behalf of a third party. For example, we may not be able to provide the product and/or service you may have requested and may not be able to handle enquiries in connection with those products and/or services.
3.4 Cookies
Our website uses a technology called “cookies” and web server logs to collect information about how the website is used including, where available, your IP address, browser type and the geographical location of your computer. We also use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices), administer our site and manage your account. Google Analytics doesn’t collect information that identifies a visitor to our site. All the information that is collected is anonymous and is only used to improve how our site works. We do not allow Google to make any attempt to establish the identities of any users of our site. For details about how we use cookies, please see our Cookies Policy.
How we use and disclose Personal Data
4.1 General purposes
We collect, hold, use and disclose Personal Data about individuals for a variety of business purposes. Theseinclude, without limitation, to:
- Monitor and evaluate the performance and security of our website and any other platform or application we may offer, including to:
- Administer our site
- Improve our site to ensure that content is presented in the most effective manner
-Allow you to participate in interactive features of our services when you choose to do so
- Analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices)
- Improve your online experience
- Facilitate the provision of our products and/or services to our clients;
- Facilitate the provision of such other products and/or services that we or others may offer from time to time and provide information about their availability, features and benefits;
- Work with and procure goods and/or services from our suppliers and service providers;
- Conduct audit, accounting, financial and economic analysis of our business operations;
- Respond to enquiries or investigate and resolve complaints;
- Protect our legal rights, investigate suspected fraud or other misconduct, or assist law enforcement agencies; and
- Comply with our legal and regulatory obligations.
We may also use and disclose Personal Data we collect for other purposes that are permitted, required or authorised by applicable law, such as:
- Purposes which you would reasonably expect and which are related (and, in the case of Sensitive Data, directly related) to the primary purpose of collection of Personal Data; and
- Any other purposes for which you have given your consent.
4.2 Marketing
We will only use or disclose your Personal Data for the purposes of direct marketing (e.g. in relation to productsand/or services we may offer from time to time) where we have your consent or we are otherwise permitted bylaw to do so. You are free to opt out from receiving marketing communications from us, by:
- Following the “opt out” process indicated in a marketing communication you have received;
- Emailing us at enquiries@aqua-superpower.com at any time requesting that your name and email address be removed from our marketing lists; or
- Following such other process that is made available for this purpose from time to time.
4.3 Disclosure of Personal Data
In order to perform activities in connection with the purposes described in this Privacy Policy, we may make Personal Data available to other persons or entities, or disclose it to them, including:
- Our suppliers and service providers, including those to whom we outsource certain of our information technology functions (e.g. cloud service providers). We authorise our suppliers and service providers to use or disclose your Personal Data only as necessary to provide us with supplies or perform services on our behalf, or to comply with legal requirements. We require suppliers and service providers by contract to safeguard the privacy and security of Personal Data they process on our behalf;
- Any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of our assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of ours;
- Other related bodies corporate;
- Government, regulatory, judicial or law enforcement authorities;
- Accountants, insurers, auditors, lawyers and our professional advisers; and
- Any other third parties notified to you at or around the time we collect your Personal Data (together, the Required Recipients).
We disclose this Personal Data for the following reasons: (1) the disclosure is necessary for us to provide our services; (2) it is in our legitimate interest to disclose this data for the purposes of providing our services; (3); the disclosure is necessary for us to comply with our legal obligations or applicable law; or (4) we have consent, where applicable or required under law.
Where we transfer your Personal Data outside the EEA or the United Kingdom, we have rules and steps put in place to make sure your personal data is kept safe and protected. Usually this means we’ll have standard contractual clauses approved by the European Commission in our contracts with parties outside the EEA, or we will rely on European Commission adequacy decisions.
How we hold Personal Data
We hold Personal Data both electronically and in paper form. We maintain administrative, technical and physical safeguards designed to protect Personal Data from misuse and loss, and unauthorised access, modification and disclosure. We will process your Personal Data for as long as is necessary for the purpose(s) for which it is collected and processed. Unless the law requires otherwise or we need the Personal Data to establish, exercise or defend a legal claim, we take reasonable steps to destroy or permanently de-identify Personal Data if it is no longer required.
5. Your rights to your Personal Data
As provided by applicable data protection law, the following rights may apply for personal data collected, used and disclosed by us:
- Access: You have the right to be told about how your personal data is processed, and have access to such personal data.
- Correction: Where your personal data is incorrect, you may request that we rectify the personal data we hold. Please take care to ensure details provided to us are kept up to date.
- Portability: In some cases, you can request that your personal data we hold is provided to you in a structured, machine-readable format, and can require us to transfer your personal data to another data controller.
- Right to be forgotten: You may have the right to require us to erase personal data concerning you.
- Right to restrict processing: In some cases, you may require us to restrict the processing of your personal data.
- Right to object: In some cases, you may have right to object to the processing of your personal data.
- Withdrawal of consent: You may withdraw your consent (in cases where we rely on consent) at any time. If consent is withdrawn it may have consequences such as we may no longer be able to provide certain services or communications. To exercise these rights, please contact us using the details in the Contact Us section below. Please include sufficient details so we can understand the nature of your requests. We may need to request personal data in order to verify identity. In some cases we may respond that a request will not be actioned where permitted or required under law.
6. Data retention time
For customers with an AQUA account, we keep your personal data for the term of your contract with us, and we ensure it’s been deleted from our systems within three months of you providing us notice to terminate your account. If your account remains inactive for a period of five consecutive years, we will assume you have provided us notice to terminate your account with us. If you use Guest Access, your email address will be retained for 24 hours to enable customer service enquiries.
7. Enquiries and complaints
If you wish to make an enquiry or complaint to us regarding privacy matters, you should contact us in writing using the contact details at the end of this Privacy Policy. We will endeavour to respond to your enquiry or complaint promptly. Please include sufficient details so that we can understand the nature of your enquiry. We may need to request personal data in order to verify your identity. You also have the right to lodge a complaint with the competent data protection supervisory authority.
8. Third party sites
Please remember that when you use a link to go from our website, platform or application to another website, this Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which are linked to our website, platform or application is subject to that website’s own rules and policies. We are not responsible for the content or the conduct of the organisations accessed via links to such third party websites.
9. Contact us
You may contact us in relation to privacy matters at: 124 City Road, London, England, EC1V 2NX
Email: enquiries@aqua-superpower.com
All correspondence attention: CTO Privacy Policy Dated: September 2023