Privacy Policy.

1. GENERAL

1.1 ENOVATES NV (with company number 0833.089.547 and registered office at Brandstraat 13, 9160 Lokeren, Belgium; hereinafter, “ENOVATES”) respects your privacy and undertakes its best efforts to keep secure your personal data.

1.2 This Privacy Policy is meant to help you understand what information ENOVATES collects about you, why it collects it and how you can update, manage, export and delete your information. This Privacy Policy shall apply to visitors of ENOVATES’ office, users of the Website, users of the Application, distributors’ representatives, agents or employees, suppliers’ representatives, agents or employees and potential distributors’ or suppliers’ representatives, agents or employees (hereinafter, the “Data Subjects”).

1.3 Any personal data will be collected by ENOVATES in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, the “GDPR”) and the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data.

1.4 This Privacy Policy applies in addition to the Terms of use of the Website, to the Terms of use of the Application, to the Terms of Sales, to the Cookie Policy and to any other agreement you concluded with ENOVATES.

2. WHAT PERSONAL DATA IS COLLECTED BY ENOVATES?

2.1 ENOVATES collects and stores the following personal data when you visit its office:

Category of Data Subject	Description
Visitors of its office	You provide the following information to ENOVATES by filling in its visitors register at the front desk of its office: ·         Your first name and last name. ·         Your company’s name. ·         Your email address. ·         Your license plate. ·         The date of your visit. ·         The person you visit. ·         Your picture (optional).

2.2 ENOVATES collects and processes the following personal data when you use its website www.enovates.com (hereinafter, the “Website”):

Category of Data Subject	Description
User of the Website	You provide the following personal data to ENOVATES by filling in the form available on the Website in order to contact ENOVATES: ·         Your name. ·         Your email address. ·         Your message.
User of the Website	The following personal data is collected and processed about you when you’re using the Website: ·         Online identifiers such as cookie data. Please read the Cookie Policy if you want to know more about the data that ENOVATES automatically collects from you when you use the Website.

2.3 ENOVATES collects and processes the following personal data when you use its mobile application “My-Enovates” (hereinafter, the “Application”):

 

2.4 ENOVATES collects, processes and stores the following personal data when it does business with you, namely when it negotiates or concludes agreements with you and when it ensures the performance of such agreements:

2.5 ENOVATES collects, processes and stores the following personal data to potentially do business with you:

 

 

2.6 ENOVATES collects, processes and stores the following personal data when you participate to its earlier adopting program (CHARLIE) to test the charging stations:

 

 

3. WHAT IS ENOVATES’ PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

 

3.1 ENOVATES collects, processes and stores your personal data for the performance of the contract concluded with you or your company, namely, to comply with its obligations under such contract. Such legal basis is used for the following purposes and categories of personal data:

 

 

 

3.2 ENOVATES asks you to actively indicate your consent to ENOVATES’ use of your personal data for the following purposes:

 

 

 

If the processing of personal data is based on your consent, you have the right to withdraw your consent at any time, without this affecting the legality of the processing on the basis of the permission before your withdrawal. You can inform ENOVATES of such withdrawal by sending an email to privacy@enovates.com.
As users of the Application, you can always withdraw your consent to log in via your Google/Apple account by following the steps described in the procedures below:

• Google Account:
  1. Visit https://myaccount.google.com/security with your Google account.
  2. Identify the tile with third-party apps and services.
  3. Click “See all connections” to manage your current connections.
  4. Click a specific connection to edit it.
  5. Revoke access by clicking “Delete all connections that you have with eNovates Cloud Application”. Confirm and close.
  6. You’ve now deleted every connection to Google with the Application. 

• Apple Account:

1. Navigate to https://account.apple.com/account/manage/section/security
2. Click on sign in with Apple
3. Click on “My-Enovates User App”
4. Click on “Stop using Sign in with Apple”

3.3 ENOVATES has a legitimate interest in processing your personal data when it uses your personal data for the following purposes:

 

 

3.4 ENOVATES must process your personal data to comply with legal obligations for the following purpose:

 

 

4. TO WHOM DOES ENOVATES SEND YOUR PERSONAL DATA?

4.1 In order to fulfil the purposes mentioned in Article 3, ENOVATES may collect your personal data through to the following recipients or communicate it to them:

(a) Third party service providers who provide certain services to ENOVATES under the terms of an agreement, such as IT services providers (error and bugs tracking, statistics, support, hosting, cloud, etc.), provider of the CRM tool, provider of the HelpDesk, provider of the visitor registration, authentication service provider and provider of the accounting tool.
(b) Competent authorities to whom ENOVATES would be legally obliged to disclose information in the context of legal proceedings or to detect technical and/or security problems, and
(c) In the event ENOVATES changes its corporate structure by changing its legal form, merger, acquisitions and sales, the contracting company(ies).

4.2 In principle, ENOVATES undertakes not to transfer your personal data outside of the European Economic Area. However, in limited circumstances, it might be possible that ENOVATES uses third party service providers that are established outside the European Economic Area and might therefore transfer your personal data outside of the European Economic Area. In such cases, ENOVATES will implement adequate safeguards (and, where necessary, supplementary measures) to ensure that your personal data is afforded a level of protection which is essentially equivalent to the level of protection guaranteed within the European Economic Area.

5. HOW DOES ENOVATES PROTECT YOUR PERSONAL DATA?

5.1. ENOVATES takes appropriate technical and organisational measures to prevent unnecessary retention and unauthorised access of your personal data. However, be aware that no system is ever completely secure.

5.2. Among others, the following safeguards have been put in place by ENOVATES:

(a) Firewall
(b) Antivirus
(c) Regular update of passwords
(d) Encryption and anonymisation

6. HOW DOES ENOVATES STORE YOUR PERSONAL DATA AND FOR HOW LONG?

6.1 The personal data that ENOVATES collects from you is transferred to a data-server hosted in the European Union.

6.2 ENOVATES undertakes to not retain your personal data for longer than is strictly necessary for the purposes for which it was collected or received. Retention periods differ depending on the type of processing activity and the purpose for which the personal data was collected.

6.3 In order to comply with this obligation of storage limitation, Enovates has identified a specific storage period for each personal data. These storage periods have been defined in its Storage Policy. Once the period specified in the Storage Policy expired, Enovates undertakes to delete the corresponding personal data.

6.4 If your data has been collected to prepare or perform a contract or other agreement with ENOVATES, this personal data is retained for the duration of the contractual relationship plus 10 years, in order for ENOVATES to comply with its legal obligations (such as accounting and tax obligations), or to resolve a dispute.

7. WHAT ARE YOUR DATA PROTECTION RIGHTS?

7.1 ENOVATES provides you with the following tools so that you have full control over your personal data.

7.2 Right of access. You have a right of access to your personal data. To exercise your right of access, you can send an email to privacy@enovates.com. Personal data that ENOVATES has collected about you will be sent to you by replying to your email.

7.3 Right of rectification. You may, at any time, ask ENOVATES to complete or modify your personal data if you find them to be incomplete, incorrect or obsolete.

7.4 Right to object. You have the right to object to ENOVATES processing your personal data. The exercise of this right of objection is only possible in one of the following two situations:

(a) when the exercise of this right is based on ENOVATES’ legitimate interests; or
(b) when the exercise of this right is intended to prevent the data collected by ENOVATES from being used for commercial prospecting purposes.

7.5 Right to erasure. You have the right to request ENOVATES to erase your personal data as soon as possible, in particular when:

(a) the personal data is no longer necessary for the purposes for which they were collected or otherwise processed;
(b) you withdraw your consent on which the processing of your data is based;
(c) your data has been unlawfully processed by ENOVATES;
(d) your data must be erased in order to comply with a legal obligation under EU or Belgian law.

Please note, however, that even if you exercise your right to erasure, ENOVATES may retain certain information about you where it is required to do so by law (such as tax and accounting legislation) or where it has a legitimate interest to do it.

7.6 Right to restriction. You may request ENOVATES to restrict the processing of your personal data, if:

(a) you contest the accuracy of your personal data, for a period enabling ENOVATES to verify the accuracy of the personal data;
(b) the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead;
(c) ENOVATES no longer needs your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
(d) you objected to processing pursuant to Article 7.4 pending the verification whether the legitimate grounds of ENOVATES override yours.

7.7 Right to portability. You also have the right to receive the data you have provided to ENOVATES, in a structured, commonly used and machine-readable format, and have the right to transmit (or request the transmission of) that data to a controller other than ENOVATES where the processing of your data is based on consent or on the performance of the contract or where the processing is carried out by automated means.

7.8 To exercise the rights mentioned in Articles 7.2 to 7.7, you may contact ENOVATES by sending an email to the following email address: privacy@enovates.com. ENOVATES undertakes to reply within a reasonable period of time to any request relating to the exercise of the aforementioned rights. This period shall not exceed one (1) month from receipt of your request, unless ENOVATES decides to exercise its right to extend this period, which shall be a maximum of two (2) months.

8. BREACH

8.1 In the case of a personal data breach, ENOVATES shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with GDPR, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

8.2 ENOVATES shall communicate at least the following in this notification: (i) the nature of the personal data breach; (ii) the name and contact details of the data protection officer; (iii) the likely consequences of the personal data breach; and (iv) reasonable measures taken to mitigate its possible adverse effects.

9. AMENDMENTS TO ENOVATES’ PRIVACY POLICY

9.1. ENOVATES may occasionally make amendments to this Privacy Policy. Therefore, ENOVATES encourages you to periodically review this Privacy Policy for the latest information on its privacy practices.

9.2. If ENOVATES makes any material changes to this Privacy Policy, ENOVATES will notify you in accordance with applicable law prior to the amendments becoming effective.

10. CONTACT

10.1 Any question about the present Privacy Policy or privacy practices can be sent to ENOVATES by:
• Email: privacy@enovates.com
• Post: Brandstraat 13, 9160 Lokeren (Belgium)

10.2 You are also entitled to request further information or lodge a complaint with the Belgian Data Protection Authority:
• Email: contact@apd-gba.be
• Post: Rue de la Presse 35, 1000 Brussel (Belgium)