Privacy Policy
This Privacy Policy includes details about your personal data rights, and your ability to manage any personal information you share across Zapmap. Please also refer to our terms of use and Cookie Policy.
1. KEY TERMS
In this Privacy Policy:
- where we use the words personal information we use these words to describe information that is about you and other individuals (for example, your email address and username) and which identifies you or those individuals;
- references to the capitalised terms are defined in our terms of use, unless expressly defined in this Privacy Policy.
2. PRIVACY POLICY
This Privacy Policy (together with the applicable terms or service or contract which governs our supply of Services, including our terms of use and cookies policy) sets out the basis on which we collect and use personal information about you when we supply Services to you and when you use our Website or App. This Privacy Policy describes:
- who is responsible for the personal information that we collect about you;
- the personal information we collect about you;
- how we will use it;
- who we may disclose it to; and
- your rights and choices in relation to your personal information.
This is to make sure you have a full picture of how we collect and use your personal information. You have the right to object to our use of your personal information in certain circumstances. A summary of your right to object (along with other rights under data protection law) and the details of who to contact if you want to exercise them can be found at sections 11 and 13 below.
3. WHO IS RESPONSIBLE FOR THE PERSONAL INFORMATION THAT WE COLLECT?
We are the data controller for the purpose of data protection law in respect of your personal information collected and used in connection with our provision of Services to you, including via our Website and App. This is because we make decisions about the purpose for which your personal information is used and how it is processed.
There are some instances where we act as a data processor on behalf of other third party controllers who are providing Services to you directly. Where we act as a data processor, this will be made clear to you by the relevant third party controller.
4. WHAT PERSONAL INFORMATION DO WE HOLD ABOUT YOU?
Whether you use Zapmap as a Registered User or a guest (non-registered) user each time you visit or use our Website, Services and App, we may automatically collect the following data when you visit our Website or App, some of which can be considered personal information:
- Information about your activity on and interaction with Zapmap: including your device's Internet Protocol address, the type of device and browser you use, your device’s operating system and platform, high-level location including the country from which you are accessing our Website /App, and information about Zapmap advertising which you may have viewed on social media.
- Location information: we capture your location information for certain location-enabled services, such as supporting you with planning a route or helping you find out the locations of nearby EV Charge Points. If you wish to use this particular feature, you will be asked to agree to your data being used for this purpose.
- Your notification, location and device storage (caching) preferences: which you can change at any time by changing your device settings, or if using Zapmap via Google Assistant, changing the notification and storage settings on your Google Account.
- Information about your visits to the Website including the full Uniform Resource Locators clickstream to, through and from the Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page. You can opt out of being included in Google Analytics by using the Google Analytics Opt-out Browser Add-on.
We may also collect the following data when you contact our Customer Support team:
- Information that you share during your correspondence with us. For example, details of your username and question, where you contact us to ask for support or report a possible issue.
For Registered Users, we need to collect and process the following personal information to create an Account (as defined in the terms of use) and to enable you to use our Website, App and Services. You may decline to provide us with your information; however, this will limit your ability to register for an account and use our Website, App and Services.
- Account registration information (if you choose to register for our Services via our Website or App), including: your name, email address, home/work address, username and password.
- Electric vehicle details (if you choose to add details about one or more electric vehicles to your Zapmap account), including: vehicle make, model and registration number and the postcode where your vehicle is usually based.
- Payment method information (if you choose to use Zap-Pay to pay for your electric vehicle charging), including: Your name, home/work address and payment card information. For completeness, Zapmap only has access to the name on the card, the last four digits of the card number, and the card’s expiry date (as displayed in your profile) the full card details are securely processed by our third-party payments provider.
- Charging payment history (if you choose to use Zap-Pay to pay for your electric vehicle charging), monetary value, energy consumed, date/time of payments, basic card details (including last four digits of card number), and vehicle charging location.
- Electric vehicle home charger details (if you choose to register your home charger via Zap-Home). To enable you to advertise your home EV Charge Point on Zapmap for use by other Zapmap registered users. If you choose this option, your EV Charge Point location, EV Charge Point name, charger type and number of connectors will be visible by all Zapmap users. In addition, your full postal address, contact email, contact telephone number, charge time availability, use of cables, access to the property, optional payment fee and optional PayPal.Me account name will be visible by all Registered Users. Note that your home EV Charge Point location will be added to the map and visible by all Zapmap users.
- Electric vehicle workplace charger details (if you choose to register your workplace charger via Zap-Work). To enable you to advertise a workplace EV Charge Point on Zapmap for use by all Zapmap users. If you choose this option, the EV Charge Point location, EV Charge Point name, charger type, number of connectors, full workplace postal address, contact email and contact telephone number will be visible by all Zapmap users. Note that your work EV Charge Point location will be added to the map and visible by all Zapmap users.
- Any information and content that you share via the 'Chat' functionality within our App. Personal information that you share within any posts, comments, contributions to discussions, messages to other users, including any images shared, in the Chat functionality. We also share this chat data in both anonymised and pseudonymised formats with some of our partners, (including for example our data provider partners (e.g. CPOs) and partners to which we offer our Zapmap Spark services) to use for their own purposes, such as analysing the reliability and usage of their charging networks and providing services to their customers.
- Marketing preferences. We will retain your selected marketing preferences (including details of subscriptions to any newsletters). This includes your contact preferences, so that we know for what reasons we may contact you (e.g. Zapmap newsletter, Zapmap business newsletter, Zapmap product updates, Zapmap surveys, Zapmap promotions, and third-party communications) as well as your preferred contact methods (e.g. email, telephone, post, text) and any opt-outs that you provide.
5. INFORMATION FROM/ABOUT THIRD PARTIES
Where we receive your data from third parties, for example, where you have linked your JustPark account to Zapmap, we process your personal information as a data processor on behalf the third party in that case, JustPark.
In the course of us providing Services to you, you may provide us with personal information relating to third parties. For example, where you have registered your home or work electric vehicle charger on Zapmap, you may provide us with telephone number of an individual within your household or workplace so that Zapmap users can contact the relevant individual to answer questions about the charger. We will use this personal information in accordance with this Privacy Policy.
If you are providing personal information to us relating to a third party, you confirm that you have the consent of the third party or are otherwise entitled to share such personal information with us and that you have made the information in this Privacy Policy available to the third party.
6. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use your personal information for a variety of different purposes during the course of us providing Services to you. The main purposes for which we use your personal information are set out below. Under data protection law, we can only use your personal information if we have a legal basis to do so. Examples of where we have a legal basis to process your personal information, include when:
- we have your consent;
- it is necessary to enter into or perform a contract we have with you (or to take steps at your request prior to entering into that contract);
- it is necessary to comply with a legal obligation;
- it is necessary in order to protect your vital interests; or
- it is in our legitimate interests to process your personal information.
We have set out the main purposes for using your personal information in the following section together with our legal basis for doing so. Where we rely on our legitimate interests, we have set out those interests in detail below.
- To communicate with you and other individuals. Legal bases: (1) Legitimate interests: We require your personal information in order to communicate with you in relation to the supply of Services in accordance with the terms of use, (2) Performance of a contract we have with you.
- To deliver our Services to you. Legal bases: (1) Legitimate interests: It is in our legitimate interest to deliver these Services to you, (2) Performance of a contract we have with you.
- To enable you to add an EV Charge Point or suggest an EV Charge Point location that is not currently on Zapmap's Website or App. Legal bases: (1) Legitimate interests: We require your personal information to validate the source of the EV Charge Point information, (2) Performance of a contract we have with you.
- To provide personalised Services to our Registered Users. Legal bases: (1) Legitimate interests: It is in our legitimate interest to enable you to personalise your Zapmap Sites and Services including: electric vehicle model filters, user filters, favourites and route plans, and to create and administer your account, (2) Performance of a contract we have with you.
- To send you direct marketing communications about our products, Services and promotions. Legal bases: (1) Legitimate interests: It is in our legitimate interest to contact you about Services that we offer, (2) Consent: In some circumstances, we may rely on your consent to send direct marketing communications to you, including invitations to participate in Zapmap surveys, relevant market research or to share a promotion or offer with you. In all cases, we may tailor our marketing and promotional offers to you based on our understanding of your preferences from your use of the Website, App or Services. In addition, certain promotional offers may be based on eligibility criteria, solely determined by Zapmap.
- To manage any service or quality related issues, complaints, feedback and queries in relation to the supply of our Services to you, including in relation to the Website and App. Legal bases: (1) Legitimate interests: We require your personal information in order to ensure the Services we supply align with our customers' expectations, (2) Performance of a contract we have with you.
- As part of our efforts to keep our Website, App and Services safe and secure through pro-active site monitoring, and to administer these for troubleshooting, data analysis, and testing purposes. Legal basis: Legitimate interests: Your personal information may be captured as part of this security monitoring.
- To enable us to analyse the Services we provide to you and improve the quality and performance of our Services, including to ensure that our content is presented in the most effective manner for you and your device. Legal basis: Legitimate interests: We require your personal information in order to improve the Services we provide.
- To track and analyse your use of the Website and Applications so that we can improve how Zapmap is performing and provide users with the best possible experience. Legal basis: Legitimate interests: We require your personal information in order to improve the Services we provide.
- To enhance the Website, App and our Services through the use of location-enabled smart tools and notifications. Legal bases: (1) Contract: We require your location information in order to provide certain services to you, including route planning, (2) Legitimate interests: It is in our legitimate interest to deliver these location-enabled services to you, (3) Consent: Where we rely on your consent, you can withdraw your consent for us to access your location at any time through your device settings or, if using Zapmap via Google Assistant, changing the notification and storage settings on your Google Account.
- To comply with any legal or regulatory obligations (including in connection with a court order). Legal basis: Necessary for compliance with a legal obligation to which we are subject.
7. WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?
In order to facilitate your use of Zapmap Website, App and Services, we may share your personal information with:
- our business partners, service providers and subcontractors for the performance of any contract we enter into with you (for example, data hosting facilities providers, email services providers, IT and system administration services providers, marketing service providers, security service providers and document storage providers); and
- our professional advisors (for example, our lawyers, accountants and auditors) that assist us in carrying out our business activities.
We also share chat data and content with CPOs who are our data partners and with partners that take our Zapmap Spark services, to use for their own purposes. This may include (in the case of the CPOs) analysing the reliability and usage of their charging networks and (in the case of our Zapmap Spark partners) as part of the services that they provide to their customers. The personal information we share with our partners should be limited to the user display name only, as we take steps to try to remove any other personal details beforehand. Occasionally this removal process is not entirely effective, so it might be that some additional personal information is shared.
We will also disclose your personal information to other third parties, for example:
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation;
- if we transfer your personal information to a potential purchaser or acquirer of all or part of our business, including as part of any due diligence exercise before the purchase or acquisition; and
- if we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets.
8. WHERE WILL WE TRANSFER YOUR PERSONAL INFORMATION?
The data we collect from you may, on occasion, be processed at a destination outside of either the United Kingdom or the European Economic Area by organisations engaged in the fulfilment of your request, order or reservation, and the provision of support services. Where this occurs, we will take steps to ensure there is an adequate level of protection of your personal information and that your data is treated securely and in accordance with UK and EU law and this Privacy Policy. These steps include:
- relying on the fact that a country has been approved by the European Commission or UK government as providing adequate protection; or
- using standard data protection clauses which have been adopted by the European Commission and UK government.
This approach is compliant with applicable data protection law (being Articles 45 or 46.2 of the GDPR).
9. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?
We will retain your personal information, in accordance with this Privacy Policy, for as long as your Account is active to provide you with access to our Website and App. We also collect and maintain aggregated, anonymised or pseudonymised information which we may retain indefinitely to protect the safety and security of our Website, App or Services , improve our Website, App or Services or to comply with legal obligations.
For inactive users, we will retain and use your information solely for the purposes set out in this Privacy Notice and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect Zapmap's legal rights.
We may retain personal information of inactive Accounts for a reasonable period to allow us to respond to any follow-up enquiries or complaints. To determine appropriate retention periods for personal information, we consider the amount, nature, and sensitivity of the personal information, and the potential risk of harm from unauthorised use or disclosure of your personal information. In the majority of cases this period is less than 24 months.
Where Registered Users subsequently withdraw their consent and/or wish to remove all of their personal information from our Website, App and Services, we will only continue to retain the registration details (including username and password) as part of a suppression list to ensure we comply with all 'do not contact' requests, to allow us to respond to any follow-up enquiries or complaints, and to comply with our legal obligations, resolve disputes, enforce our agreements and protect Zapmap's legal rights.
10. HOW WE PROTECT YOUR PERSONAL INFORMATION
We take security seriously, and the security of your personal information is important to us. We do our utmost to ensure your personal information is stored and processed in a way that ensures appropriate security from unauthorised or unlawful processing, accidental loss, destruction or damage.
We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security to encrypt information as it travels over the internet. In addition to encrypted transmission, if you are a Registered User, your Account information is protected by a password, which you should choose carefully and keep secure in accordance with our terms of use. All passwords are stored in 'hash' format which is a widely used method to protect sensitive information.
As no method of electronic communication or storage is completely secure, we cannot guarantee the absolute security of the data we hold. Zapmap therefore has a protocol in place in the event of a data breach. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so, and within the time limit specified by the GDPR regulations, including both the EU and UK GDPR.
As part of our data security procedures, we regularly employ penetration testers to review our database and server security measures. Should you become aware of a security vulnerability across any part of our Website, App and Services, we encourage the responsible disclosure of vulnerabilities by emailing security@zap-map.com.
We have implemented other technical safeguards to try to prevent personal information entering the public domain via user contributions submitted in the form of Chats (posts on our Website or App), general comments, contributions to discussions, and/or messages to other users. For example, Chat images and text are scanned and we endeavour to remove or obscure information such as vehicle registration marks using automated visual processing. However, this is not always entirely effective and, accordingly, we advise users not to include any personal data when using the Chat functionality.
In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for research, analytical or statistical purposes. This in effect removes any personal information and any security risk associated with your data. We may use or store this information indefinitely without further notice to you.
11. YOUR DATA PROTECTION RIGHTS
You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights.
- Right to withdraw consent - Where we are using your personal information on the basis of your consent, you have the right to withdraw that consent at any time;
- Right to be informed - You have the right to be told how your personal information will be used. This Privacy Policy, and shorter summary statements used on our communications, are intended to be a clear and transparent description of how your personal information may be used;
- Right of access - You can write to us asking what information we hold on you and to request a copy of that information. This is called a Data Subject Access Request;
- Right of erasure (also known as the right to be forgotten) – You have the right to ask that your personal information be deleted in certain circumstances. Examples include: where your personal information is no longer necessary in relation to the purposes for which it was collected or otherwise used; if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; if you object to the use of your personal information (as set out below); if we have used your personal information unlawfully; or if your personal information needs to be erased to comply with a legal obligation.
- Right of rectification - If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data provided to us;
- Right to restrict processing - In certain situations you have the right to ask for processing of your personal information to be restricted because there is some disagreement about its accuracy or legitimate usage;
- Right to data portability – You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies: to personal information you provided to us; where we rely on the following legal bases: consent, or for the performance of a contract; and when the use of your personal information is carried out by automated (i.e. electronic) means;
- Right to object - You have an absolute right to stop the processing of your personal information for direct marketing purposes. This right is implemented by amending your contact preferences; and
- Right to object to automated decisions - In certain situations where we are making solely automated decisions about you, you have the right to object.
To submit a Data Subject Access Request, change consent, request erasure or rectification, restrict processing, to port data to another provider, and/or to object to automated decision making, please contact Zapmap via email at privacy@zap-map.com, or write to: Zapmap Limited, Runway East, 1 Victoria St, Redcliffe, Bristol BS1 6AA, marking your email or letter 'Privacy Information Request'.
12. CHILDREN AND PERSONAL INFORMATION
Zapmap's Services are not intended to be used by children and consequently Zapmap does not intentionally collect or process any personal information relating to children.
13. PRIVACY CONTACT INFORMATION
If you have any queries about this Privacy Policy, or want to submit a Data Subject Access Request, change consent, request erasure or rectification, restrict processing, to port data to another provider, and/or to object to automated decision making, please contact us via email at privacy@zap-map.com, or write to: Zapmap Limited, Runway East, 1 Victoria St, Redcliffe, Bristol BS1 6AA, marking your email or letter 'Privacy Information Request'.
If, for any reason, you have a complaint, please contact Zapmap using the details included above in the first instance to discuss your concerns. If after having contacted Zapmap and received a response you are still dissatisfied, you are able to contact the Information Commissioner's Office (ICO) directly by phone on 0303 123 1113. For more information, visit the ICO website.
14. ABOUT THIS PRIVACY POLICY
By using the Website, App and Services, you are acknowledging and agreeing to terms of use and that you have read, understood and agree to this Privacy Policy and our Cookie Policy.
We reserve the right to update this Privacy Policy from time to time. Any changes we may make to this Privacy Policy in the future will be posted on this page and where appropriate, notified to you. The new terms may be displayed on-screen and you may be required to confirm that you have read and accept them to continue your use of any of our Website, App and Services. Any references to this Privacy Policy or any other document are to this Privacy Policy or that document as updated by us from time to time.
This Privacy Policy only covers Zapmap’s Website, App and Services. Any third party websites that may be linked to by our Website, App and Services are subject to their own privacy notices or policies.
Where you submit information to a third party through our Website or App, any information that you provide will be subject to the terms and conditions and privacy notice or policies of the relevant third-party website and Zapmap will bear no liability for any loss incurred or damage suffered by you as a result.
© Copyright Zapmap 2024
Policy last updated: August 2024