Privacy Notice

Last updated: May 2018

Please read this privacy notice (“Privacy Notice”) carefully as it describes our collection, use, disclosure, retention and protection of your personal information. This Privacy Notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it: (a) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics, direct marketing, and maintaining automated back-up systems or for the detection or prevention of crime)

1. Who we are
This Privacy Notice applies to all products, and services offered by The London Electric Vehicle Company Ltd (a company registered in England with VAT registration number GB 157318403 and whose registered office address is Li Close, Ansty Park, Coventry, CV7 9RF), but excludes any products applications or services that have separate privacy notices which do not incorporate this Privacy Notice

Our website is powered by G-Forces Web Management Limited (“GForces”), our third-party web services provider. GForces is committed to ensuring that data is processed in accordance with applicable data privacy laws, and is kept secure. GForces is certified to the standard of ISO27001 (an international standard for information security). GForces uses Amazon Web Services, Inc. as its cloud platform provider. All data processed by GForces is stored on Amazon’s web servers in the EEA.

2. How we collect information
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

• register to use our websites, applications or services; this may include your name (including business name), address, email address and telephone number. We may also ask you to provide additional information about your business and your preferences;
• place an order using our websites, or services; this may include your name (including business name), address, contact (including telephone number and email address) and payment details
• complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, enter any competitions or prize draws, download publications or participate in any other interactive areas that appear on our website or within our service
• interact with us using social media
• provide your contact details to us when registering to use or accessing any websites, or services we make available or when you update those details; and
• contact us offline, for example by telephone, fax, SMS, email or post.
We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies- www.levc.com/site/cookies-policy/
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

3. How we use your information
To the extent permissible under applicable law, we use your information to:

• provide any information and services that you have requested or any services that you have ordered;
• provide, maintain, protect and improve any products, services and information that you have requested from us;
• manage and administer your use of products and services you have asked us to provide
• manage our relationship with you (for example, customer services and support activities);
• monitor, measure, improve and protect our content, website, and services and provide an enhanced, personal, user experience for you;
• undertake internal testing of our website, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual;
• provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
• contact you to see if you would like to take part in our customer research (for example, feedback on your use of our products and services);
• to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
• deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our products and services;
To the extent permitted by applicable law, we retain information about you after if you cease business with LEVC or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

Our website, applications (including mobile applications) and services may contain technology that enables us to:

• check specific information from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
• obtain information relating to any technical errors or other issues with our website, applications and services;
• collect information about how you and users use the functions of the features of our website, applications and services; and
You can manage your privacy settings within your browser or our applications and services (where applicable).

In addition to the purposes described in this section 3, we may also use information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). Sections 4 and 5 of this Privacy Notice provides further details on how we will do this.

We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and to meet our legal and regulatory obligations generally.

Mobile data
You can configure our mobile application’s privacy settings on your device but this may affect the performance of that mobile application and the way it interacts with our applications and services.

Data analytics and benchmarking

We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include:

• deliver advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of services;
• carry out research and development to improve our services, and products
• develop and provide new and existing functionality and services (including statistical analysis, benchmarking and forecasting services); and
• provide you with location based services (for example location relevant content) where we collect geo-location data to provide a relevant experience.
Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living individual.

You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at GDPR@levc.com to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.

4. Marketing
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you. We may also share your information with our group companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you. We or they may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites, applications or services, using any preference centres we give you access to or by sending us an email to GDPR@levc.com. You can also unsubscribe from any email marketing using the links provided in the emails we send to you

5. Additional Details

Providing us with information about others
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

If you visit our website
When someone visits our website, LEVC collects standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). These are stored against unique ids (which are strings of numbers). LEVC collects this information for the legitimate business purpose of monitoring the number of visitors to the various parts of the site, the general geographic location of visitors and engagement levels, which in turn enables it to make improvements to its websites and services, and provide business intelligence. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

LEVC also uses Google Analytics to collect standard internet log information and details of visitor behaviour patterns, which are stored against unique ids (i.e. strings of numbers). We collect this information for the legitimate business purpose of monitoring website traffic and engagement levels, which in turn enables us to make improvements to our website and the way we sell our cars and services. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

If you use our enquiry forms
When you submit information using an online form, LEVC processes the data collected and stores it for 31 days for the legitimate business purpose of enabling us to access the information and deal with your request (it is then kept for a further 14 days in LEVC’ routine back-ups for business continuity purposes). We collect the following information:

If you enter your post code, LEVC stores the first part of it (e.g. ‘ME14’ or ‘SW1’) and links it to standard internet log information already collected (it is used for the same purposes as that information, as outlined above).

If you use our LiveChat service
We use a third-party provider, Gubagoo Inc.to supply and support our LiveChat service. If you use the LiveChat service we will collect your name and email address if you provide this and any other personal information that you volunteer to us. This is used for the legitimate business purpose of handling customer enquiries in real time and then following up. This data is stored by Gubagoo for 2 years to enable us to access the information and deal with your enquiry. Gubagoo stores the information in the US under the EU-US privacy shield framework. Please see Gubagoo’s privacy policy for more information on how they use your data. https://www.gubagoo.com/about/policy.]

6. Your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
• the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).
If you request a copy of your information you may be required to pay a statutory fee.

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the LEVC Data Retention Policy or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

To help you exercise the rights that data privacy laws give you and control your personal information you can do the following:
• See your data
You can ask to see any personal information that we hold (known as a “subject access request”). If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. By emailing us at GDPR@levc.com with subject “see my data”, we will attend to your request. Please note if you request a copy of your information you may be required to pay a statutory fee.

• Transfer your data
By emailing us at GDPR@levc.com with subject “transfer your data”, you can ask us to provide your data to a third party.

• Delete your data
By emailing us at GDPR@levc.com you can ask us to delete the information we hold about you by using the subject “delete your data”.

• Change your data
If we do hold information about you, you can also ask us to correct any mistakes by emailing us at GDPR@levc.com with subject line “Change your data”.

• Marketing Preferences
On the “marketing preferences” link, you can tell us how you would like us to send you marketing information, or ask us to stop marketing to you entirely. http://www.theelectrictaxi.co.uk/update-marketing-preferences/

Any data collected through the email and marketing preference link is stored for 31 days for the legitimate business purpose of enabling us to access the information and deal with your request (it is then kept for a further 14 days in LEVC’ routine back-ups for business continuity purposes).

7. Further information
If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to us at Sales and Marketing Department, LEVC, Li Close, Ansty Park, Coventry, CV7 9RF), or send an email to GDPR@levc.com.