We are committed to providing our customers with truly excellent customer service. We recognise that customers value their data and privacy, and so we treat our customer data with great care. This policy sets out how and when we collect, use and share your personal information that you, or others, provide to us.
1 Who are we?
We are Octopus Electric Vehicles Limited (“Octopus EV”), with registered company number 10754317 and registered address at 5th Floor, UK House, 164-182 Oxford Street, London W1D 1NN. We are a subsidiary of the Octopus Energy Group.
Octopus Energy Group has appointed a data protection officer, Lynne Higgins, who is responsible for overseeing questions in relation to this privacy notice. If you’d like to speak to anyone about your data please contact email@example.com or call us on 020 3870 389.
Depending on the product you choose, we may act as a vehicle hirer, insurance intermediary, introducer or credit broker.
In most cases we lease vehicles directly to our customers in relation to the following products:
- Personal contract hire
- Salary sacrifice schemes
- Business contract hire
- Vehicle to Grid Personal contract hire
Further information is available at https://octopusev.com/termsandconditions.
2 How do we collect and use your data?
We only collect and process data about you where we have a reason for doing so and only where that reason is permitted under data protection law.
It’s important that you keep your personal information with us up to date, so please let us know if anything changes.
This section sets out how we collect and use your data.
When you make enquiries or purchase products or services from us
When you make enquiries about our products online, over the phone or face to face, we will use your personal information to provide you with quotations and to arrange or offer vehicle leasing and finance. This information may include your name, address, date of birth, email address, phone number, payment details and your preferences (for example about marketing communications or your electric vehicle).
To understand who uses our services, we also collect information about you (which may include demographic information including your age, gender, salary, and the nature of your employment) to improve and create new products and services that are relevant to you.
We log and record the interactions you have with us, such as phone calls, email opens and click throughs to help us better service your requests and to improve our services.
We rely on your consent to handle your personal information in this way. In certain circumstances such as in the performance of a contract, if you do not provide us with the data we request, we may not be able to fully answer your queries or process your order.
We will share your details with partners and funders in order to provide you with a quotation and to arrange vehicle leasing and finance - please see Section 3 (Sharing your information) below for more details.
In order to arrange vehicle rental, leasing, finance and insurance
Where we are arranging vehicle finance and insurance on your behalf, we will collect additional information including nationality, country of birth, date of birth, UK residency, National Insurance number, financial data (such as your salary), driving licence details (number, expiry, location, current or pending endorsements and scanned copy), and DVLA check code.
This information is used in a number of ways including aggregating all data across our systems to create, improve, and supplement our knowledge to identify correlations between data to further our learning and efficiency.
We gather this data in order to arrange vehicle finance and to comply with the law to ensure that your vehicle will be appropriate and affordable to you. If applicable and with your consent we will also collect vulnerability data - such as your age, any disabilities or health conditions or any financial circumstances.
Where we have certain legal and regulatory obligations
Where we are obliged to do so by law and in line with our risk and anti money laundering policies, we may use your information to:
- investigate fraud or money-laundering or terrorist financing risks (for salary sacrifice and business contract hire contracts only), carry out creditworthiness and affordability assessments (for personal contract hire only)
- make sure all nominated drivers are qualified to drive;
- check your driving history; and
- process any fines that you have received.
For occasions where we need to process any criminal data, such as endorsements (penalty points for a driver) this is set out within a separate appropriate policy document.
This section applies if you have opted in to receive marketing communications from us or have previously expressed an interest in our products and services and have not opted out. We will process your personal information (your name, address, contact details and other personal information you’ve given us) to provide you with marketing communications in line with any preferences you have told us about. We will also keep a record of phone calls, email opens and click throughs to help us better service your requests.
Examples of our messaging can include:
- Helping you through the quote journey towards selecting the right electric vehicle (EV) (our EV specialists will contact you to based on your quote activity)
- Keeping you up to date on the latest news of cars of interest to you
- Informing you of product updates based on your previous interests that you have previously shared with us and based on our legitimate interests to inform you of new EVs becoming available
- Sharing news/information by post, phone, targeted or generic adverts about our products and services from other Octopus Group companies because of our legitimate interest to promote the success of the products and services that you have expressed an interest in.
Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them, or you can contact us anytime at firstname.lastname@example.org.
Where you have responded to an advert online by clicking through to our website we may record any associated information you share with us and may pass basic information back to the social media platform you used to improve future marketing.
We never share your information with any third parties for their direct marketing purposes.
Third party platforms
We may sometimes provide personalised advertising via third party platforms (such as Google, Bing, Instagram, Facebook and Linkedin). For example, we’ll hash your data (so no one can view it) and reference it against Facebook’s platform. If you have a profile with Facebook, we’ll ask them to exclude you from irrelevant adverts, such as “join Octopus Electric Vehicles ” adverts and send you more relevant adverts instead. We do this on the basis of legitimate interest to ensure that you receive more tailored and relevant information about our products and services.
If you are part of an industry scheme
If you apply for or enquire about our Powerloop Vehicle to Grid (V2G) offering, we will collect information relevant to the provision of this scheme, including your name, address, and contact details. Powerloop is an Innovate UK funded project and we are delivering it to customers in collaboration with six other consortium partners (UK Power Networks, Guidehouse, Chargepoint Services, Energy Savings Trust, Octopus Energy, and Open Energi).
We will be gathering data from the V2G charger and a telematics device (also known as a Black Box) which will be installed in your car in order to collect usage data on a number of metrics, including how you charge and use your vehicle. We will need to report the aggregate data from the project to Innovate UK, as well as to the Department for Business, Energy and Industrial Strategy (BEIS). We do this because all Innovate UK V2G projects are being used to inform BEIS. We will not pass on any personal data, and data collection will be fully anonymised and will not be used for any decision purposes on an individual basis.
To make our website or apps better and more secure
We will use your personal information to provide you with a more effective user experience, such as by displaying services we think you will be interested in. Using your information in this way means that your experience of our website and apps will be more tailored to you, and the content you see on our website may differ from someone else.
We share anonymised (not personally identifiable) and aggregated data with third party analytics and search engine providers that assist us in the improvement and optimisation of our website and apps.
We will use your personal information for the purposes of administering our website and apps, making them more secure, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our website and apps are kept secure.
You can prevent us from using your personal information in this way by using the “do not track” functionality in your internet browser. If you enable “do not track” functionality, our website may be less tailored to your needs and preferences.
Technical information and analytics
When you visit our website, we will automatically collect the following information:
- technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
- information about your visit, including the full webpage address, clickstream to, through and from our 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; and
- when using our apps, the number of users on the app, session duration, the operating system used, device model information, first launch, app opens and updates, the occurrence of software bugs, and any in-app purchases.
We may also collect information on your location on our websites and apps, such as your location data when accessing the website or apps in line with the location settings on your phone or internet browser. This can be disabled or amended via the relevant IOS/Android platforms or in your internet browser settings.
We also work closely with various third parties, including advertising networks, analytics providers, hosting providers and search information providers from whom we may also receive general aggregated anonymous information about you.
Product and Service Development
We are always looking for ways to make driving an electric vehicle better, for both our customers and for the planet. We sometimes process your data to further development our product/services, where we have a legitimate interest for doing so, for example:
- to better understand our customer demographic and the content of customer communications and requests to create more relevant campaigns, products and services;
- to make predictions about future behaviour based on current behaviour, to help develop and tailor our products and services;
- to build a profile personally for you, so we can do things like show you products and services that we think will be of particular interest and relevance to you; and
- for data analysis, testing, research, statistical and survey purposes.
Where we do process your personal data, we rely on legitimate interests to process your
data in this way and we always carry out a “balancing” test in line with the ICO’s guidance to ensure that our processing is necessary and is not outweighed by your rights to privacy.
Information we receive from third parties
As well as the information you provide us with directly, we also receive information from some third parties.
We work with various affiliates and partners, such as employee benefit platforms, price comparison websites, telesales agencies and door-to-door sales agencies, and if you sign up to our services through one of our affiliates or partners they may receive a fee as part of that referral.
We also work with credit reference agencies (CRAs) for financial information relating to creditworthiness and product suitability. The identities of these CRAs and ways that they process personal data, are explained in more detail at www.callcredit.co.uk/crain, www.equifax.co.uk/crain and www.experian.co.uk/crain.
Penalty charges and fixed penalty notices are received from our fines management provider, as Octopus EV is and remains the owner of the vehicle during the term of your lease.
Your EV may come installed with the ability to collect telematics (such as odometry/mileage, location) data from the manufacturer, which we can access via fleet management software portals. We would receive this and location data either from the EV manufacturer portal or directly from the driver, our fleet management specialists or the end of lease vehicle collection report. This will help manage your mileage throughout the term of your contract and allow for recovery of a vehicle if it is lost/stolen.
We run referral schemes, including encouraging employees to ask us to contact their employee on their behalf (where they think salary sacrifice will be of benefit to them).
Where you come to us using a referral link are used, then we will receive your initial details through this link, and we will also tell the person whose link you used.
3 Sharing your information
- Our group companies, affiliates and partners, where necessary for the provision of our services, included but not limited to: brokers/funders/insurance companies to process and accept your application, payment providers (your employer or other third party) to process payments to us, install an electric charger at your home, EV dealerships to source an EV and deliver to the right address, provide in-life assistance to named drivers, for breakdown, accidents, tyre replacements, collecting of fees owed to us relating to driver actions resulting in penalty charge and/or fixed notices issued.
- Our group companies, affiliates and partners where there is potential benefit for our customers to learn more about their products.
- Anyone who is named and authorised on your account.
- Credit reference agencies (CRAs), fraud prevention agencies, anti-money laundering and terrorist financing tools, both when you first sign up and routinely whilst you have an EV or an account with us. This includes ongoing exchanges of information with/from CRAs of settled or unpaid debts. CRAs will in turn also share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
- Debt collectors and vehicle recovery agencies where we have to recover sums or vehicles owned by us.
- Our telesales and field sales partners, but only where necessary to perform our services.
We may also share your information for the following reasons:
If our business is sold
We will transfer your personal information to a third party as follows:
- if we sell or buy any business or assets, we will provide your personal information to the seller or buyer (but only to the extent we need to, and always in accordance with data protection legislation); and
- if Octopus Electric Vehicles Limited, or the majority of its assets, are acquired by somebody else, in which case the personal information held by Octopus Electric Vehicles Limited will be transferred to the buyer.
We process your personal information in this way because we have a legitimate interest to ensure our business can be continued by the buyer.
Where we have a legal or regulatory obligation
In some circumstances we may need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation- for example, to investigate something like theft or fraud.
In difficult circumstances
We speak to thousands of customers a day, and some of those people will be in difficult circumstances. Occasionally people will share information which indicates that they, or a member of their household, are in imminent danger or at serious risk. In such circumstances we may refer the situation to relevant authorities or sources of assistance. In such cases we will consider first and foremost the interests of the person at risk.
5 Where is my data stored?
We are based within the UK, however some of the third parties we work with may be based outside of the European Economic Area (EEA), so their processing of your personal information may involve a transfer of data outside of the EEA.
Whenever we transfer your personal information outside of the EEA, we will always ensure it is protected by making sure we have appropriate safeguards in place. This might mean only transferring your personal information to a country that has been deemed by the European Commission to provide an adequate level of protection, or by using specific contractual protections. You can contact us at email@example.com for details of how we protect specific transfers of your data.
All information that you provide us with is stored on our secure servers, or those of our third parties’ data storage providers.
6 How long do we retain your data for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or administrative requirements.
To determine the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information, the applicable legal requirements and whether we can achieve those purposes through other means.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical analysis, such as looking at email open rates, or to improve our website and develop new products. In these cases, we may use this information indefinitely without further notice to you.
7 What are my rights under data protection laws?
You have various rights under the data protection laws, which you can exercise by contacting us. The easiest way to do this is by email to firstname.lastname@example.org.
- Your right of access - You have the right to ask us for copies of your personal information.
- Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- Your right to complain - You have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in the United Kingdom.
We will update you whether a charge is required in advance and where you make a request, we have one month to respond to you and will update you where necessary in advance of fulfilling your request.
Please contact us at email@example.com if you wish to make a request.
8 What about websites we link to?
Our website and apps may contain links to third party websites. If you click on a link to any of these websites, you will leave our website or app and this may allow third parties to collect or share your data.
We have no control over the contents of those third party websites and so will not accept any responsibility or liability for any materials on there. We encourage you to check their privacy policies before you submit any personal information to these websites.
9 Updates and contact
However, if you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the supervising authority in the United Kingdom, the Information Commissioner’s Office, the UK’s independent authority on data privacy at www.ico.org.uk.