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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”):
 

Category of Data Subject

Description

User of the Application

The following personal data is collected and processed about you when you use the Application:

·         IP address.

·         Email address.

·         Language preference.

·         Profile picture.

·         Information about the device you use (brand, version, language, and time zone).

·         Information about your behaviour as a user of the application (the time you spend and the features you use).

·         Information about your consumption.

·         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 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:

Category of Data Subject

Description

Distributor’s representatives, agents or employees

ENOVATES may process and store your personal
data when you contact it by phone or by email or when you give your business
card to its employees or representatives during an event. Moreover, ENOVATES may
collect your personal data when it is available on the website of your
company.

The type of personal data collected and used is
the following:

·        
Your first name and last name.

·        
Your telephone number or mobile phone number.

·        
Your email address.

·        
The name of your company.

·        
The registered office of your company.

·        
Your function in the company.

Supplier’s representatives, agents or employees

ENOVATES may process and store your personal
data when you contact it by phone or by email or when you give it your
business card to its employees or representatives during an event. Moreover,
ENOVATES may collect your personal data when it is available on the website
of your company.

The type of personal data collected and used is
the following:

·        
Your first name and last name.

·        
Your telephone number or mobile phone number.

·        
Your email address.

·        
The name of your company.

·        
The registered office of your company.

·        
Your function in the company.

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

Category of Data Subject

Description

Potential distributors’ and suppliers’ representatives, agents or employees

ENOVATES may process and store your personal data when you contact it by phone or by email or when you give your business card to its employees or representatives during an event. Moreover, ENOVATES may collect your personal data when it is available on the website of your company.

The type of personal data collected and used is the following:

·         Your first name and last name.

·         Your telephone number or mobile phone number.

·         Your email address.

·         The name of your company.

·         The registered office of your company.

·         Your function in the company.

 
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:
 

Category of Data Subject

Description

Participants to the CHARLIE program

You provide the following personal data to ENOVATES by filling in the form communicated to you to register as participants to the CHARLIE program:

·         Your first name and last name.

·         The name of your company.

·         Your address.

·         Your phone number.

·         Information about your electricity installation/consumption and your vehicle.

 
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:
 
 

Category

Purpose

Personal Data

User of the Application

To execute its obligations in accordance with the Terms of Use of
the Application

·        
The data about your consumption.

Supplier’s representatives, agents or employees

To negotiate.

·        
Your first name and last name.

·        
Your telephone number or mobile phone number.

·        
Your email address.

·        
The name of your company.

·        
Your function in the company.

To conclude agreements with your company.

·        
Your first name and last name.

·        
The name of your company.

·        
The registered office of your company.

·        
Your function in the company.

To send you orders.

·        
Your first name and last name.

·        
Your email address.

·        
The name of your company.

·        
The registered office of your company.

To communicate regarding the orders that it
sent you.

·        
Your first name and last name.

·        
Your telephone number or mobile phone number.

·        
Your email address.

To pay your invoices.

·        
The name of your company.

·        
The registered office of your company.

Distributor’s representatives, agents or employees

To negotiate.

·        
Your first name and last name.

·        
Your telephone number or mobile phone number.

·        
Your email address.

·        
The name of your company.

·        
Your function in the company.

To conclude agreements with your company.

·        
Your first name and last name.

·        
The name of your company.

·        
The registered office of your company.

·        
Your function in the company.

To send you some offers.

·        
Your first name and last name.

·        
Your email address.

·        
The name of your company.

·        
The registered office of your company.

To process your orders.

·        
Your first name and last name.

·        
Your email address.

·        
The name of your company.

·        
The registered office of your company.

To deliver the products your ordered.

·        
Your telephone number or mobile phone number.

·        
The place of delivery.

To provide you with L3 Support and access to
the HelpDesk.

·        
Your first name and last name.

·        
Your email address.

·        
Your technical issues with the product.

·        
Address of the place where the support has to
be provided.

To send you invoices and to process your
payment.

·        
Your first name and last name.

·        
Your email address.

·        
The name of your company.

·        
The registered office of your company.

To communicate with you regarding the orders
that you sent and regarding the products that ENOVATES delivers.

·        
Your first name and last name.

·        
Your function in the company.

·        
Your telephone number or mobile phone number.

·        
Your email address.

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

Category of the Data Subject

Purpose

Personal Data

Users of the Website

To obtain statistics regarding the use of its Website.

·         Online identifiers such as cookie data.

 

Users of the Application

To enable you to log in via your Google account

·         Your IP address.

·         Your email address.

·         Your language preference.

·         Your profile picture.

To enable you to log in via your Apple account

·         Your IP address.

·         Your email address.

·         Your language preference.

·         Your profile picture.

For direct marketing purposes

·         Your email address

Participants to the CHARLIE program

To provide you with the charging stations to test, to provide support and to contact you in order to receive feedback.

·         Your first name and last name.

·         The name of your company.

·         Your address.

·         Your phone number.

·         Information about your electricity installation/consumption and your vehicle.

 

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:
 

Category of the Data Subject

Purpose

Personal Data

Visitors of the office

Ensure security and safety among the office

·         Your first name and last name.

·         The name of your company.

·         Your email address.

·         The date of your visit.

·         The person you visit.

·         Your license plate.

·         Your picture (optional).

Users of the Website

Ensure the good functioning of the Website

·         Cookie Data.

Users of the Application

Track errors and report crash

·         Your IP address.

·         Your email address.

·         Information about the device you use (brand, version, language, time zone, etc.).

For statistical purposes and to improve the Application

·         Information about the device used (brand, version, language, and time zone).

·         Information about your behaviour as a user of the application (the time you spend and the features you use).

·         Information about your consumption.

Ensure the good functioning of the Application

·         Cookie Data.

Supplier’s representatives, agents or employees

Inform you by email about ENOVATES’ presence during an exhibition or event.

·         Your first name and last name.

·         Your email address.

·         The name of your company.

Manage ENOVATES’ internal database (CRM) system and for business development purposes.

·         Your first name and last name.

·         The name of your company.

·         Your function in the company.

·         Your email address.

·         Your telephone number/mobile phone number.

Distributor’s representatives, agents or employees

Inform you by email about updates regarding ENOVATES’ products.

·         Your first name and last name.

·         Your email address.

·         The name of your company.

Inform you by email about ENOVATES’ presence during an exhibition or event.

·         Your first name and last name.

·         Your email address.

·         The name of your company.

Manage ENOVATES’ internal database (CRM) system and for business development purposes.

·         Your first name and last name.

·         The name of your company.

·         Your email address.

·         Your function in the company.

·         Your telephone number/mobile phone number.

Potential distributor’s representatives, agents or employees

Inform you by email about ENOVATES’ presence during an exhibition or event.

·         Your first name and last name.

·         Your email address.

·         The name of your company.

Manage ENOVATES’ internal database (CRM) system and for business development purposes.

·         Your first name and last name.

·         Your email address.

·         The name of your company.

·         Your telephone number/mobile phone number.

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

Category of Data
Subject

Purpose

Personal Data

Supplier’s representatives, agents or employees

Maintain appropriate business records, comply
with requests from governmental agencies, supervisory bodies or fiscal
authorities and retain documents for liability purposes.

·        
Your first name and last name.

·        
Your email address.

·        
The name of your company.

·        
Your function in the company.

·        
The registered office of your company.

Distributor’s representatives, agents or
employees

Maintain appropriate business records and
comply with requests from governmental agencies, supervisory bodies or fiscal
authorities and retain documents for liability purposes.

·        
Your first name and last name.

·        
Your email address.

·        
The name of your company.

·        
Your function in the company.

·        
The registered office of your company.

 
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)

 
 
 
 
 
 
 
 
 
 
 
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