WEBSITE PRIVACY POLICY

Date of Last Revision: 02 August 2024

1. Introduction

Blink Charging UK Limited (“Blink Charging,” “we,” “our,” or “us”) provides this privacy policy (the “Policy”) to inform you on how we process your information, whether you are a visitor to our website, a purchaser of our electric vehicle charging stations and/or operation and management services, or a user of electric vehicle charging stations on the Blink Network. “Blink Network” refers to Blink Charging’s open-platform network of electric vehicle charging stations and vehicle charging applications.

This Policy applies to your use of the Blink Charging website (the “Website”), and to any service offered by Blink Charging and the Blink Charging radio-frequency identification cards (the “RFID Cards”) (each of these services and applications are collectively defined as the “Service”).

Except as explicitly provided herein, this Policy sets out the basis on which any personal data relating to you will be processed by us. Please read this Policy carefully to understand our practices regarding your personal data and how we will treat it. By using or otherwise accessing the Service, you agree to this Policy. If you do not agree to this Policy, please do not access or use the Service.

This Policy is provided in a layered format with specific areas set out below:  

• WHO WE ARE AND IMPORTANT INFORMATION (see section 2)

• DATA WE COLLECT ABOUT YOU AND HOW WE USE IT (see section 3)

• HOW IS YOUR PERSONAL DATA COLLECTED? (see section 4)

• HOW WE USE YOUR PERSONAL DATA (see section 5)

• DISCLOSURE OF YOUR PERSONAL DATA (see section 6)

• INTERNATIONAL TRANSFER (see section 7)

• DATA SECURITY (see section 8)

• DATA RETENTION (see section 9)

• YOUR LEGAL RIGHTS (see section 10)

 2. Important Information and Who We Are

Blink Charging UK Limited (referred to as we, us or our in this policy) is the controller and is responsible for your personal data.  If you have any questions about this privacy policy, please contact us using the details set out below.

 Contact Details

 Our full details are:

• company number:  09444771

• incorporated and registered in:  England and Wales

• registered address:  45 Grosvenor Road, 1^st Floor, St. Albans, AL1 3AW

• e-mail address: support@blinkcharging.com

• telephone number: 0330 111 0076

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. We may change this Policy to reflect changes in the law, our information practices, or the Service features. At the top of our Policy, we will indicate the date of the most recent update. This version was last updated on 02 August 2024. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements, which may be by posting on this page and (where appropriate) through email and/or SMS. By using the Service, you are confirming that you have read and understood the latest version of this Policy.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during our relationship with you.

Third Party Links

This Website may contain links to third-party websites. Please note that these websites and applications have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services.  Please check these policies before you submit any personal data to these websites or use these services. If you provide any third party with your information, we recommend that you review their privacy policies as Blink Charging does not control how they collect, process and transfer your information.

Access to any other websites linked to the Blink Charging Website is at the user’s own risk, and Blink Charging is not responsible for the accuracy or reliability of any information, data, opinions, advice or statements made on these websites. Blink Charging provides these links merely as a convenience and the inclusion of such links does not imply any kind of endorsement.  

Children’s Privacy

The Website and Service are intended for persons licensed to drive and not for children. In the UK, this typically means individuals over the age of 17. Blink Charging does not knowingly collect any data relating to anyone under 17 years old. If you are less than 17 years of age, we request that you do not submit information to us. If we become aware that we have inadvertently collected personal data from children under the age of 13 without parental consent, we will take reasonable steps to delete it as soon as possible as required by applicable law.

3.  Data we collect about you and how we use it

 We may collect, use, store and transfer different types of personal data about you as follows:

• ‘Contact Data’ such as your first and last name, postcode, e-mail address and telephone number.

• ‘Vehicle Data’ such as the brand(s), model(s); vehicle’s vin and registration number(s) of your vehicle(s); and your name(s) for those vehicle(s).

• ‘Device Data’ such as the type of mobile device you use; unique device identifier(s) (for example, your Device’s IMEI number, the MAC address of your Device’s wireless network interface and/or the mobile phone number used by your Device); mobile network information; your mobile operating system; and time zone setting.

• ‘Commercial Data’ such as your transaction data and charging station use data which includes where you are using the Services including details about payment to and from you, your postcode and details of purchases.

• ‘Financial Data’ such as the last four digits of your payment cards, bank details, RFID card, invoice and purchase order history

• ‘Internet, Network and/or Device Activity Data’ such as IP address, unique device identifier, advertising, app identifiers, browsing history, cookies, screen recording of usage, mobile device data or other usage data.

• ‘Location Data’ such as past and current general location, and, if you provide permission, precise GPS location.

• ‘Sensory Data’ such as audio recordings if you call our customer service.

• ‘Marketing and Communications Data’ such as your preferences in receiving marketing from us and our third parties, your communication preferences and communications you send us.

• ‘Profile Data’ such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

We also create, use and share aggregated data, such as statistical or demographic data for various purposes.  In certain circumstances, aggregated data may be (wholly or in part) derived from your personal data (see the ‘Purposes for Which We Will Use Your Personal Data’ tables in section 5) but that aggregated data is not considered personal data in law as it will not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data with the usage data of others in order to calculate the percentage of users accessing a specific feature or Service.  However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data and will treat it in accordance with this privacy policy.

Whilst we do not routinely collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, wand genetic and biometric data), we may collect limited information about your health for the purpose of managing health and safety and any associated claims. We do not we collect any information about criminal convictions and offences. 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How Is Your Personal Data Collected?

We will collect and process the following data about you:

• information you give us.  This is information (including Contact Data, Financial Data, Identity Data, Marketing and Communications Data and Vehicle Data) that you provide to us by filling in forms on the Website or by corresponding with us (for example, by e-mail or chat).  It includes information you provide when you:

  •    register to use the Services and/or App;

  •    purchase Services, including on behalf of your employer (where applicable);

  •    enter a competition, promotion or survey; or

  •    contact us.  For example, when you report a problem with the Services.

• information we collect about you and your device.  Each time you use the Website, we will automatically collect personal data (including Device Data and Usage Data).  We collect this data using Cookies (see ‘Cookies’ in this section 4); and

• Location Data.  We also use GPS technology to determine your current location.  Some of our location-enabled Services require your Location Data for the feature to work.  If you wish to use those Services, you will be asked to consent to your Location Data being used.  You can stop sharing your location at any time by disabling the use of Location Data from within the settings on your Device.

Cookies and other electronic technologies

Like most websites, Blink Charging uses cookies and similar technologies, including web beacons, embedded scripts, and e-tags (together referred to as “cookies,” unless otherwise stated) to provide users an efficient user experience in using the Website. A cookie is a small data file placed on your computer or mobile device by your web browser. It is a tool that stores information about website visits, recognises you and your preferences each time you visit the Website, optimises website functionality, and enables us to provide the Service. Some parts of the Website use cookies to track user traffic patterns.

Blink Charging uses cookies for various reasons, including providing you the Service you have requested, enhancing our Website’s performance, or analysing how users use our Website. Our use of cookies falls into the following categories:

Strictly necessary cookies. These are essential to enable you to move around the Website and use its features. Without these cookies, the Service you have requested cannot be provided.

Performance cookies. These cookies improve how our Website works. They collect information about how users use our Website (e.g., which pages users visit most often, and if users get error messages from web pages).

Functionality cookies. These cookies allow us to remember what choices you make (e.g., your username, language or the region you are in) to provide enhanced, more personal features. The information these cookies collect may be anonymised.

Advertising and marketing cookies. These cookies are used to: send you advertising, and marketing-related material tailored to you and your interests, limit the number of times you see an advertisement, and help measure advertising campaigns’ effectiveness. These cookies are usually placed by advertising networks with the website operator’s permission. These cookies remember that you have visited a website, and this information is shared with other organisations like advertisers. The “interest-based” or “personalised” advertising powered in part by these cookies is usually more relevant to you, but it also generally involves the collection and use of more information about you and your browsing history. There are easy ways to opt out of most or all interest-based or personalised advertising: we describe how to opt out in below.

Online Analytics and Tailored Advertising

Analytics. We may use third-party analytics services such as Google Analytics. These service providers use the technologies described in the “Information We Collect Automatically” section above to help us analyse how users use the Service, including analysing your Website use, compiling reports on Website activity, and providing us with other services relating to Website activity and internet usage. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your analytics information, you may install the Google Analytics Opt Out Browser Add-on for your current web browser.

Tailored Advertising. We and our third-party service providers may use device identifiers and other automated technologies (including cookie identifiers on our Website), along with other collected information, to deliver content or tailor ads when you are on our Service or other devices, apps or websites. These ads may be based, for instance, on the types of websites that you visit over time, the types of apps you have on your device, or de-identified information about you and your likely interests, based on your activities off our Service. Partners that we or others work with to do the above may track your activities over time (including across different apps or websites) by collecting information through automated means, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you.

Manage cookie consent preferences

You can manage your cookie consent preferences and choose to block or allow essential, functional, marketing and analytics cookies. Just click the cookie logo on the home page of our website to access the Privacy Preference Centre to manage your preferences.

You may also control and block the cookies used by the Website by modifying the settings in your browser or on your device that allow you to refuse the setting of all or some cookies. You can also adjust your settings so that your browser blocks all cookies or only cookies from third parties. You can also delete cookies that have already been placed. However, please note that if you use your browser or device settings to block all cookies, you may not be able to access all or parts of our Website. For more information about how cookies can be managed and deleted, please visit http://www.allaboutcookies.org/ or http://www.networkadvertising.org/choices/.

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to do so.

• Most commonly we will use your personal data in the following circumstances:

• where you have consented to the processing;

• where we need to perform a contract we are about to enter (or have entered) with you;

• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

• where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by e-mail or text where we have your consent. You have the right to withdraw that consent at any time by following the instructions in any relevant communication or by contacting us (see section 2 for our full contact details) 

The information about the purposes for which we will use your personal data below is outlined below, with the differences in the lawful basis for processing highlighted on whether you are using the Services as a consumer or in the course of your employment.

Meaning of the ‘Lawful Basis’ outlined above:

• ‘Consent’ means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose.  Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want.  You can withdraw your consent at any time by contacting us (see section 2 for our full contact details) 

• ‘Legitimate interest’ means the interest of our business or a third party.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (see section 2 for our full contact details)

• ‘Performance of contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• ‘Comply with a legal obligation’ means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact and Commercial Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

 6.  Disclosure of Your Personal Data

We will also share your personal data with the third parties below for the purposes set out in the tables above (see section 5)

• With our affiliates; our distributors, resellers, channel partners, Blink Charging station owners

• External third parties, including:

  • Provider of payment services

  • Where you use the Services in the course of your employment, your employer.

  • Customer relationship management (CRM) software

  • Financial accounting system

  • Accounting software

  • Customer service platform

  • Back-office provider

  • Subscription billing system

  • Financial solutions and payment platform

  • Data visualisation software

  • Contactless payment provider

  • Online banking provider  

  • Health and Safety platform

  • Suppliers

• With site hosts when you connect with a Blink Charging station operated by a site host

• in certain circumstances, specific third parties where we have notified you of their identity and you have consented to us sharing certain personal data with them.  For example, when we ask if you would like to participate in studies being conducted by those third parties;

• In the unlikely event of insolvency, bankruptcy or receivership in which your information would be transferred as one of Blink Charging’s business assets;

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may share your information we collect as follows:

At your direction or with your consent, such as when you use our social media features to provide information to Blink Charging users about our Service or when you direct us to share information with third parties such as utility companies.

Where we are legally obligated to disclose information to the government or third parties for the purposes of criminal or fraud investigations, national security, law enforcement or other issues of public importance; and Where we otherwise believe it appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions or any other legal terms governing use of the Service, and/or to protect our rights and property and the rights and property of other users.

 7. International Transfers

The personal data we collect from you may be transferred to, and stored at, a destination outside the UK/European Economic Area (“EEA”) depending on which of our international entities is providing services and where we use service providers located outside the UK/EEA.

Transfers within the Blink Charging Group

We will transfer your personal data between Blink legal entities and offices. Where personal data is transferred to, and stored at, a destination within the UK/EEA, these countries have been deemed to provide an adequate level of protection for personal data. Where personal data is transferred to, and stored at, a destination outside the UK/EEA, we have complied with the need for additional safeguards as set out in legislation.

Transfers to third parties

We will transfer your personal data to third parties within the UK/EEA. Where personal data is transferred to, and stored at, a destination within the UK/EEA, these countries have been deemed to provide an adequate level of protection for personal data.

Whenever we transfer your personal data out of the UK/EEA, we will seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

 8. Data Security

Blink Charging has implemented administrative, physical, and technical security measures to protect your information under our control. All information you provide to us is stored on our secure servers (or those of our third party service providers).  Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using WebSocket technology. You should take steps to keep your information safe (including your password) and log out of your account after use. Where we have provided you, or you have chosen, a password that enables you to access certain parts of our Website, or a Blink Charging RFID Card to access charging stations, you are responsible for keeping your password and Blink Charging RFID Card confidential. You must not share these with anyone or store them in a way that may allow a third party to access them. If that happens, you agree to report it immediately to privacy@BlinkCharging.com. Blink Charging cannot be held responsible for your failure to keep your password or Blink Charging RFID Card secure.

You should update your password periodically to help reduce the risk of unauthorised access to your account with us. When you do, you should strengthen your password with the combination of uppercase and lowercase letters, numbers, punctuation, and other symbols.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

While Blink Charging takes precautions against possible security breaches of its Website and Service, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We cannot guarantee the security of your information while it is being transmitted to our Website or stored in our systems, and any transmission is at your own risk. We have put in place procedures to deal with any suspected personal data breaches and – in the event of a personal data breach – will notify you and any applicable regulator when we are legally required to do so.

 9.   Data Retention

In some circumstances, you can ask us to delete your data.  See your legal rights in section 10 for further information.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

You have the right to:

• request access to your personal data (commonly known as a ‘data subject access request’).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

• request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

• request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where:

  • you have successfully exercised your right to object to processing (see below);

  • we may have processed your information unlawfully; or

  • we are required to erase your personal data to comply with local law.

• Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (if applicable) at the time of your request;

• object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

• request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data’s accuracy;

  • where our use of the data is unlawful but you do not want us to erase it;

  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• request the transfer of your personal data to you or to a third party.  We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;

• withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.

 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to exercise any of these rights, please contact us by email at privacy@BlinkCharging.com or write us at: Blink Charging UK Limited, 45 Grosvenor Road, 1st Floor, St. Albans, AL1 3AW

Your Right to Complain

You have the right to make a complaint about the use of your personal data at any time to the Information Commissioner’s Office, the UK regulator for data protection issues (www.ico.org.uk)

You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note are not responsible for the content of external websites as explained below in Third Party Links)

Or you can write to them at:

Information Commissioner's Office,

Wycliffe House,

Water Lane,

Wilmslow Cheshire,

SK9 5AF