JOLT Charge Limited (registered company number 13633536) (“JOLT/we/us/our”) is committed to protecting the privacy of our customers’ personal and credit information. This policy sets out the ways in which we collect, hold, use and disclose personal information (including credit-related information) when you use our services, our “website” at https://joltcharge.com/uk, or our “mobile application” or “app”. This policy applies to JOLT and JOLT Charge Pty Limited, who are the controllers.
Our website, app and our services are not intended for children under the age of 16 and we do not knowingly collect data relating to children.
It is important that you read this policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements other notices and privacy policies and is not intended to override them.
This policy applies to our customers, those who visit our website or app and those who apply to work with us (whether as an employee, worker or contractor).
What is personal information?
When we refer to “personal information” or “personal data”, we mean information from which that person can be identified. This information may include information or an opinion about you. The personal information we hold about you may also include credit-related information. It does not include data where the identity has been removed (anonymous data).
How do we collect personal information?
We only collect information that is relevant to our business relationship with you. This information is received directly from you or from other sources who you have approved giving us information.
When you apply to work with us, we may collect personal data from you, recruitment agencies, your referees, background check providers and credit reference agencies.
If we collect personal information from someone else, we will take reasonable steps to ensure that you:
- have been informed that we have collected that information;
- understand the purposes for which we have collected that information;
- and are aware how we might use that information or disclose it to other people.
Your telephone calls to us may be monitored or recorded for internal training purposes.
App Permissions
When you use our app, we may also collect location data from you. However, we will only collect location data with your consent. Our app can use GPS, Wi-Fi and mobile network information technology to determine your current location, which enables us to provide a better service to you (for example by telling you about a local charge point). We may also require use of your camera so you can interact with QR codes on our Chargers.
What personal information do we collect?
If you are a customer or visitor to our app or website, the personal information we collect about you may include:
- Name and preferred username;
- Email and Mailing address;
- Billing address;
- Telephone number;
- Password;
- Bank account and payment card details;
- Vehicle make, model, and registration number;
- Details about payments to and from you and other details of services you have purchased from us;
- Purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Information about how you use our website, services and/or app. When you use a charge point, we will keep a record of the details of that usage, including the date, time, location and duration of the usage and any other details of the services we may provide to you; and
- Your preferences in receiving marketing from us and our third parties and your communication preferences.
When you use our website or mobile application, we may collect information about your location or activity, including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used and other user location information.
We do not 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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you are applying to work with us, the personal information we collect about you may include:
- The information you have provided to us in your curriculum vitae and covering letter;
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, gender, employment history, qualifications; and
- Any information you provide to us during an interview.
We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your website usage data to calculate the percentage of users accessing a specific website feature. 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 which will be used in accordance with this privacy policy.
Why do we collect personal information and how do we use it?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into 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.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message (which also includes where you have given us your personal details on expressing an interest in our services or signing up, and have not opt-ed out). We may also get your consent to place non-essential cookies on your device. You have the right to withdraw consent at any time by contacting us.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
We collect personal information for the purposes of:
- Providing services to you – we do this in order to perform our contract with you and to comply with our legal obligations;
- To install our app – your consent, which you provide when you choose to download our app;
- Managing our business relationship with you – we do this in order to perform our contract with you, comply with our legal obligations and our legitimate interest of providing you with a high level of service and to understand how we can improve;
- Direct marketing – we will collect your prior consent when sending direct marketing to you;
- Researching and planning for improvement of our products and services – we carry this out when in our legitimate interests of improving our business;
- To administer and protect our business, our website and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) – this is necessary for our legitimate interests of running our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise. We also carry out this processing to comply with our legal obligations;
- To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you: we either do this with your consent, or where we do not require your consent we do this for our legitimate interests that are to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy; and
- Complying with our legal and regulatory responsibilities, including for fraud prevention.
If you are applying to work with us, we will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role;
- Carry out background and reference checks, where applicable;
- Communicate with you about the recruitment process;
- Keep records related to our hiring processes; and
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract of employment with you.
When you apply to work with us, we may also process the following sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
If we require personal information about you for a specific purpose that is not set out above, we will let you know that purpose at the time the information is processed for that new purpose.
How do we collect your personal information?
We will collect your personal information directly from you. This could include when you use our website, app, services or correspond with us.
Where we need to collect personal information 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
When might we disclose personal information?
We may disclose your personal information to achieve the same purpose for which it was collected. Apart from the purposes above, we do not give your information to any other person or company outside our related companies.
We might also disclose personal information about you:
- within our corporate group and subsidiary companies;
- on a confidential basis to our agents, contractors and external service providers;
- to entities that assist us to provide our services to you;
- if we are otherwise permitted or required to do so by law, government and law enforcement agencies or regulators;
- to investors, agents or advisers, trustees, rating agencies, or any entity that has an interest in your finance or our business;
- to entities to whom we outsource some of our functions or that provide information and infrastructure systems to us;
- to associated business and other organisations (unless you tell us not to) and their agents for the purpose of marketing their products and services to you;
- to third party debt collection agencies;
- to law enforcement agencies or third parties that may be involved in any parking or traffic contravention;
- in other circumstances where you have first consented to the disclosure.
International Transfers
We share your personal data within the Jolt group. This will involve transferring your data outside the UK, including to Australia. Additionally, some of our external third party suppliers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by either transferring your personal data to a country that is deemed adequate under UK law or we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Website traffic information
Because of the way web communication standards work, when you arrive at or leave our website, we automatically receive the web address of the site that you came from or are going to. We also collect information on the pages of our website you visit while you are on our website, the type of browser you use, and the times you access our website. We use this information as it is our legitimate interests to try to understand our customers’ preferences better and to manage the load on our servers, to improve our service and your experience with us. However, for cookies which are not strictly necessary for the operation of our website or App, we will obtain your consent, as we explain further below.
Our use of cookies
We use cookies, pixels, pixel tags, tracking links and other third party-technologies (known collectively as “cookies”) to collect information about your use of our website, app and to customise your experience of our services. Cookies are small files of data that reside on your computer or phone and allow us to recognise you as a JOLT customer (or a visitor of our website) and keep track of your visits and activity on our website to provide several features, such as;
- Remember your customised settings, such as your location, and your sign-in details;
- Customise landing page experiences based on your account activity;
- Analyse traffic on our website;
- Track your behaviour when using our website and services to deliver content and advertising which is relevant to your interests;
- Track the success of promotional material and advertising campaigns;
- Show you interest-based and customised advertising;
- Promote trust and safety;
- Prevent fraudulent conduct;
- Enhance the security of our website and service.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website or app. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
- Analytics cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website or app when they are using it. This helps us to improve the way our website and app works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website or app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Purpose | Duration |
| Google Analytics ‘_ga’; _ga_<container-id> | These cookies enable us to recognise you when you return to our site and distinguish you from other users so that we can track things like the number of unique users on our site and the average session duration. | 2 years |
We share cookie information with third-party partners with whom we work with to provide services to you.
We also allow approved third-party partners including Braintree and LinkedIn to set cookies or other third-party technologies to collect data when you utilise JOLT’s services. These third parties may use the data collected from these cookies or other third-party technologies (along with other information they may hold about you, including information from cookies on other webpages) to show you interest-based advertisement on sites across the internet, deliver you with personalised content, measure the effectiveness of their advertising, or perform services on behalf of JOLT. Third parties may store and distribute data obtained from cookies or other third-party technology in data centres and systems around the world including outside of the UK. You may encounter cookies from other businesses when using our services on websites we do not control. For example, if you view a web page related by someone else or use an application developed by another business, there may be a cookie placed by that web page or application.
You are free to opt-out of receiving cookies and interest based-ads from us and third parties if your browser or browser add-on permits. To locate instructions to opt-out of cookies specific to your browser, select the “help menu” on your browser. You can access information about opting out from receiving targeted advertisements by visiting; the NAI website opt-out page here: http://www.networkadvertising.org/choices/, the DAA opt-out page here: http://www.aboutads.info/, and/or the EDAA opt-out page here: http://www.youronlinechoices.eu/. Opting out of cookies may interfere with your use of our website and JOLT services. If you opt-out of cookies you may encounter interference with your use of our website and services.
Storing and retaining personal information
We store personal information in electronic or hardcopy form (or both) and use industry-standard levels of security to prevent unauthorised access to that information.
Personal information is only accessible to our staff or to authorised service providers with incidental access to supply their services to us.
We do not retain any of your information longer than is required for the business relationship with you or for legal purposes. When we are informed, we will keep the personal information we hold accurate, complete and up to date.
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.
Anonymity
Where it is lawful and practicable, we endeavour to de-identify the personal information we collect about you.
Direct marketing
We may use your personal information from time to time to inform you about our current and future services, including contacting you by phone, email, SMS (if you have consented (which also includes where you have given us your personal details on expressing an interest in our services or signing up, and have not opt-ed out) or by post. If you have consented to analytics or targeting cookies, this might also affect the content of marketing you receive from us. You can request that you do not receive direct marketing communications by contacting us by email at [email protected] or by simply clicking “unsubscribe” or “STOP” to any emails or SMS offers or electronic marketing you may receive. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up-to-date. During our relationship with you, we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will rely on you to ensure the information we hold about you is accurate or complete.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:
- Request access to your personal data. 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), where we may have processed your information unlawfully or where 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.
- 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.
If you wish exercise your data protection rights, please contact us using the details in this policy. 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.
You will not have to pay a fee to exercise your data protection 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 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.
Queries and complaints
If you have any queries or complaints about the way we collect, use, hold or disclose personal information, please contact us. We will use our best efforts to respond to your query or request as quickly as possible.
For the avoidance of doubt, this policy does not apply to our employee records (except in relation to recruitment). If you would like more information about this policy or the information we hold, please contact:
The Privacy Officer
JOLT Charge Limited
Level 24, 300 Barangaroo Ave, Sydney, New South Wales, 2000
Email: [email protected]
This policy can be downloaded free of charge from https://jolt.com.au/privacy
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Third-Party Links
Our website and app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or apps and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy policy of every website you visit or app you interact with.
Changes to our Privacy Policy
We are constantly reviewing all our policies and attempt to keep up-to-date with market expectations. Consequently, we may change this policy from time to time or as the need arises. We will post any changes to this policy on our website.
