Data protection is a priority for SWARCO Smart Charging Ltd that operate the ChargePlace Scotland network. SWARCO Smart Charging Ltd is registered in England and Wales with company number 14479077, having its registered office at 1 Maxted Corner, Maxted Road, Hemel Hempstead Industrial Estate, Hemel Hempstead, England, HP2 7RA

Please read this Customer Privacy Notice carefully to understand when we may collect personal data, how and why we use it, the legal basis of this use, and your rights with respect to the processing.

Please note that SWARCO Smart Charging Ltd operates the ChargePlace Scotland network on behalf of Transport Scotland. Transport Scotland is responsible for the processing of your personal data in relation to your use of the ChargePlace Scotland network. Please see the “Who do we share your data with?” section below for more on this. We recommend that you read the Transport Scotland privacy notice here.

Personal data we may collect

Through your use of this website, the mobile app and/or your purchase of products or services offered by ChargePlace Scotland we may collect, store and process the following data about you:

• Contact and Identity Information: details of how to contact you, e.g. title, name, address, email address, telephone numbers, any other information you choose to divulge as part of a query.
• Property Information: details of a property / location, e.g. address, availability of off-street parking.
• Vehicle Information: details of a vehicle, e.g. make, model, registration number, year of manufacture.
• Any other personal information that you provide to us during a phone call relating to your enquiry.
• Marketing Preference Information: details of your consent for us to send marketing materials, preferred channels.
• Payment Information: details of payment card, e.g. card number, expiry, cardholder and details of payments to and from you and other details of products and services you have purchased from us.
• Cookies Information: information about website visits, interactions.
• Customer Services Information: recording/reporting of faults, issues with the charging network, your feedback on the services offered by ChargePlace Scotland.
• Usage Data: details of electric usage from a charging unit.

When do we collect your personal data?

If you decide to contact us, you will be invited to provide Contact and Identity Information that will allow us to handle your enquiry effectively. Our legal basis in processing this data is legitimate interest, namely our desire to respond to your enquiry. We need the information you provide to do so effectively, and judge that this is how you would expect us to use the information supplied. If you contact us by phoning our Customer Service team, your call, and therefore your personal data, may be recorded. Our legal basis in processing this data is legitimate interest, namely for training and monitoring purposes.

If your enquiry relates to potential purchase of products or services from us, you will be invited to provide additional personal data needed for us to handle your enquiry effectively. This may include Property and/or Vehicle Information. The processing of such information is necessary for the purposes of taking steps prior to entering into a contract with you.

If you decide to purchase goods or services from us, we will collect Contact and Identity Information and Payment Information so we can execute the transaction. Our legal basis for processing this data is that the processing is necessary for the purposes of performing a contract with you.

If you call us to discuss any faults found with the charging network or if you have another issue or query, we will record your information against your account. This is so that we can track the fault and ensure that it has been managed in a way that is appropriate to the fault found. The legal basis for this processing is that the processing is necessary for the purposes of performing a contract with you.

We may use your personal information (including your Contact and Identity Information) for the purpose of conducting market research and analysis to improve our systems and processes for our customers and to contact you to ask if you would like to participate in surveys from time to time. Participating in any survey is entirely voluntary and you can opt-out of doing so at any time, including in advance, by contacting our Data Privacy Team using the details provided below in the ‘Queries and Complaints’ section. Our legal basis for processing such data for this purpose is our legitimate interest in improving our services.

If you decide to provide us with Marketing Preference Information indicating consent for us to send you marketing information, we will retain this data and use it along with the associated Contact Information to deliver information about products and services we feel may be of interest to you. Our legal basis for processing data under these circumstances is consent.

If you decide to visit our website, we may process Cookies Information, including information which may be deemed personal data. On your first visit to such website we will alert you to our use of cookies to manage and control your interaction with the site. We offer you information about cookies used and provide you with a means of controlling which types of cookies are permitted. We are entitled under the law to use cookies which are strictly necessary for the operation of the website, but for all other categories of cookies we will seek your permission. Acceptance of cookies (other than the strictly necessary cookies) is completely voluntary. We provide more information about the use of cookies in the relevant cookie policy on our website. Our legal basis for processing is consent.

You may only provide us with the personal data of another person if you have previously obtained that person’s consent to the processing of their personal data, have informed them of our identity as a data controller and of the nature of the processing taking place. Records must be retained by you as evidence of this consent and provided to us on request.

Where we are processing your data based on your consent, you can withdraw this consent at any time. We provide simple ways of doing this where we can (e.g. cookie consent form, unsubscribe links in emails). In any instance you can ask for your consent to be withdrawn by contacting us through the channels provided in the “Queries and Complaints” section below.

How long do we keep your information?

SWARCO Smart Charging Ltd operates a clear retention policy to ensure personal data is kept only for so long as is necessary for the purpose for which such information is collected, after which we make it non-identifiable or delete it.

The actual length of time data is retained will depend on the purpose for which it was collected. For example, in the case of Contact Information relating to an enquiry not resulting in any further agreement between us we will delete personal data six (6) months after the date of our last contact. In the case of personal data from recorded calls, we will delete these calls after four (4) months.

Who do we share your personal data with?

We contract with third parties to host the servers supporting our websites and provide services in relation to other aspects of our operations and it may be necessary to share your personal data with these third parties in connection with the purposes set out in this Customer Privacy Notice.  Any third-party provider we appoint must act in accordance with our written instructions when processing your personal data and must protect your personal data in line with the contractually required security measures. If we will store or transfer your personal data to a third-party provider based outside the European Economic Area, we will have safeguards in place to ensure your personal data is adequately protected and a copy of these safeguards will be available on request.

For more information about any third party service provider and the personal information shared with them please contact our Data Privacy Team using the details provided below in the ‘Queries and Complaints’ section.

We will not share your data with third parties for marketing purposes unless we have your express consent to do so.

We may disclose your personal data to any member of the SWARCO AG goup where necessary in connection with the purposes set out in this privacy notice. Where personal data is transferred within the SWARCO Group, we do this under a comprehensive, flexible, and global compliance framework which implements appropriate measures and safeguards to ensure that your personal data is protected in accordance with applicable data protection laws.

We may also disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements; or
• To protect and defend the rights, property or safety of ChargePlace Scotland, its customers, staff, suppliers or others; to comply with applicable law or co-operate with law enforcement; or to enforce its terms or other agreements.

Your personal data may also be disclosed to a third-party debt collection agency in order to collect outstanding payments from you on our behalf. You will be notified before we do this in accordance with our terms and conditions.

Insofar as you are a member of the ChargePlace Scotland network:

• Transport Scotland is the data controller responsible for the processing of your personal data in relation to your use of the ChargePlace Scotland network.
• We may provide your personal data to Transport Scotland in our capacity as data processor on their behalf.
• We recommend that you read the Transport Scotland privacy notice to find out more about how they handle your personal data, here.

Changes to our Customer Privacy Notice

We may make minor changes to our Customer Privacy Notice in the future and will post these to this page on our website. If we make any significant changes, we will take additional steps to inform you.

Your rights relating to Personal Data

You have certain rights in relation to your personal data which we aim to uphold as follows. Please note that rights are not absolute and are subject to certain qualification and exceptions.

• Right to be informed: You have the right to receive clear, transparent and understandable information about how we process your personal data. Our Customer Privacy Notices, including this one, aim to meet this need.
• Right to access: You can ask us for a copy of personal data we hold about you.
• Right to rectification: You can ask us to correct any error you identify in personal data we hold about you.
• Right to erasure: You can ask us to delete data we hold about you. We will do so unless we have a compelling reason to retain (e.g. legal requirement, prevention of fraud).
• Right to restrict processing: You can ask us to stop using your personal data.
• Right to data portability: You can ask us to provide your personal data in a form suitable for use by another organisation.
• Right to object: You can object to our processing of your personal data where we are doing so under the legal basis of legitimate interest.

If you would like to contact us in connection with exercising any of these rights, please do so by contacting our Data Privacy Team using the contact details provided in the “Queries and Complaints” section below.

Queries and Complaints

If you have questions or concerns in relation to our handling of your personal data or this Customer Privacy Notice, please contact our Data Protection Team as follows:

• By email at admin-cps@swarco.com
• By post at 1 Maxted Corner, Maxted Road, Hemel Hempstead Industrial Estate, Hemel Hempstead, England, HP2 7RA; or
• By phone at 0141 648 0750.

If you are within the European Union (“EU”), you also have the right to raise a privacy concern with the data protection authority established in the relevant EU country. Contact details for each EU data protection authority can be found here.

Website Links

Our website has different sub-sites for various businesses, products and services, which may also have their own privacy notices. Please read these if you visit our sub-sites.

Our website/mobile app and the Public Authority Networks website may contain links to third-party sites. This Customer Privacy Notice does not apply to those third-party sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these sites or their policies.