Privacy Policy

Last updated: 15 June 2023

INTRODUCTION

Welcome to Qmerit! We respect your privacy, and we are committed to protecting your personal data. This Privacy Policy informs you about how and why we collect, store, use and share your personal data when you use Qmerit Services or Sites, or otherwise interact with us. Please read this Privacy Policy carefully to ensure you understand our policies and practices, what your rights are and how to get in touch with us.

WHO WE ARE AND HOW TO CONTACT US

Qmerit is an innovative company that facilitates turnkey, home electric vehicle (“EV”) charging installations by connecting drivers of EVs (“Drivers”) with qualified third-party EV charging station installers (“Installers”) (the “Services”). The Services are either provided directly to Drivers, or in connection with our business relationships with EV manufacturers, dealers, fleet managers, and other businesses with EV inventories (collectively, our “Customers”).

Qmerit Electrification UK, Ltd (“Qmerit”, “we”, “us” and “our”) is the controller of your personal data as it relates to this Privacy Policy. If you have any questions about this Privacy Policy or if you wish exercise any of your privacy rights, you can contact us via the details below.

Legal name	Qmerit Electrification UK, Ltd
Registered number	14521341
Privacy contact person	Tyler Ward
Email address	privacy@qmerit.com
Postal address	Qmerit Electrification UK, Ltd. 1 Victoria Square Birmingham B1 1BD
Phone number	+44 (800) 0584614

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to Qmerit’s processing of personal data, which means information about a living individual from which that person can be identified either directly or indirectly. This includes personal data that is processed when you use Qmerit Services or Sites, or otherwise interact with us.

For purposes of this Privacy Policy, “Sites” means www.qmerit.uk and its associated web pages used to access the Qmerit Services.

However, this Privacy Policy does not apply to:

Employee personal data: Qmerit’s processing of personal data relating to its current, former, and prospective employees is covered by a separate employee privacy policy.
Third-party processing: Qmerit Sites may contain links to third-party sites. We do not control these third-party sites, nor how they process personal data. When you leave a Qmerit Site, we encourage you to read the privacy policy of every site you visit.
Customer and Installer processing: While this Privacy Policy explains why we may need to share your personal data with our Customers and Installers, it does not cover their processing of your personal data. This is covered by our agreements with Customers and Installers, as well as their own privacy policies.
Non-UK individuals: This Privacy Policy is specific to the UK. If you are based in the US or Canada, please visit Privacy Policy | Qmerit

THE PERSONAL DATA WE PROCESS

We process personal data belonging to Drivers, Installers, Customers, and visitors to our Sites. Depending on how you interact with us, we collect, store, use and share different types of personal data about you which we have grouped together as follows:

Identity and contact data, including first and last name, unique personal identifier, installation address, email address and telephone number.
Installation and vehicle data, including vehicle make and model, details and photos of your home configuration, and details of installations.
Transaction data, including information about the Services purchased by you or on your behalf. For clarity we do not process any financial data about Drivers as such data is processed independently by Installers and/or Stripe, our third-party payment processor.
Technical data, including IP address, login data, browser type and version, time zone setting and location, operating system, and other details about the devices and networks you use to access the Services and Sites (some of which may be obtained through the use of cookies and other tracking technologies, as further set out in our Cookie Policy).
Usage data, including information about how you use the Services and Sites, such as referral source, length of visit, page views, navigation paths, and information about the timing, frequency, and pattern of your usage (some of which may be obtained through the use of cookies and other tracking technologies, as further set out in our Cookie Policy).
Marketing and communications data, including preferences in receiving marketing material and method of communication.
Other personal data you choose to provide, including information contained in communications you send to us and forms you submit on our Sites.

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 personal data about criminal convictions and offences.

HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data from and about you in in different ways, including by:

Direct interaction with you: You may directly provide us with identity and contact data, installation and vehicle data, financial and transaction data, and marketing and communications data. This may arise when you use the Services, send us communications (e.g., via email, telephone, or social media), submit forms on our Sites, or sign up for marketing, events, contests, or other offerings we may present.
Automatic collection: We may automatically collect technical and usage data about you using cookies and other tracking technologies when you interact with the Services and Sites. We may also receive technical and usage data about you if you visit third-party sites that use our cookies and other tracking technologies. Please see our Cookie Policy for further information.
From third parties: We may receive personal data about you from third-party sources, including identity and contact data, installation and vehicle data, financial and transaction data, and technical and usage data. This includes personal data about Drivers provided by Customers that work directly with you in order to arrange installations (or provided via referral links and integrations on our Customer sites), and personal data about Drivers provided by our Installers to confirm installations or interactions with you. This also includes personal data collected by advertising, analytics, and internet service providers such as Google Analytics.

PROCESSING PURPOSES AND LAWFUL BASES

The table below sets out our purposes for processing your personal data and the lawful bases we rely on to carry out the processing.

Purpose of processing activity	Lawful basis for processing
Provision of Services: To provide the Services, including by providing the Sites, enabling account creation, connecting Drivers with Installers, managing payments, carrying out maintenance and providing customer support, satisfying warranties, and handling other product safety and recall issues	Necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you Necessary to comply with an applicable legal obligation
Communication: To communicate with you about the Services and our relationship with you, including providing you with information on your request and updating you about changes to our terms	Necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you
Business administration: To ensure proper administration of our business, including through record keeping, managing business relationships, carrying out quality assurance, processing complaints, and engaging in any corporate M&A activity or reorganisation	Necessary for our legitimate interests in ensuring the functioning and continuity of our Services, Sites, and business operations Necessary to comply with an applicable legal obligation
Contract administration: To communicate with you for contract administration and operational purposes related to our relationships with our Customers, Installers, suppliers, and partners (if you work for such an organisation)	Necessary for our and your organisation’s legitimate interests in pursuing business relationships and fulfilling contracts with one another
Security: To ensure the security and ongoing functioning of the Services and Sites, including through troubleshooting, activity monitoring, and system maintenance	Necessary for our legitimate interests in ensuring the security and ongoing functioning of the Services and Sites
Marketing: To send you marketing communications about the Services and our business, and in some cases to allow our partners to send you marketing communications	Your consent (collected when you subscribe to marketing communications) Where permitted by applicable data protection laws, we may instead rely on our legitimate interests to pursue business development initiatives and keep you informed of relevant offerings
Advertising: To deliver relevant website content and advertisements to you and to understand the effectiveness of the advertising we serve to you Please see our Cookie Policy for further information.	Where cookies or other tracking technologies are used, your consent (collected through our cookie consent mechanisms) Where permitted by applicable data protection laws, we may instead rely on our legitimate interests to pursue business development initiatives and keep you informed of relevant offerings
Analytics and personalisation: To allow us, our Customers and Installers to understand and draw insights from your activities on the Sites and your use of the Services, and to personalise your experience Please see our Cookie Policy for further information.	Where cookies or other tracking technologies are used, your consent (collected through our cookie consent mechanisms) Where permitted by applicable data protection laws, we may instead rely on our legitimate interests to improve the Services, Sites, user experience, and customer engagement
Wrongdoing: To allow us to detect, prevent, investigate, and prosecute illegal activity, suspected fraud, or other wrongdoing	Necessary for our legitimate interests in detecting, preventing, investigating, and prosecuting illegal activity, suspected fraud, or other wrongdoing
Legal claims: To allow us to establish, exercise or defend legal claims in potential or actual legal proceedings	Necessary for our legitimate interests in pursuing legal claims Necessary to comply with an applicable legal obligation
Exercise rights: To allow us to exercise or perform any right or obligation with is conferred or imposed on us by applicable law	Necessary to comply with an applicable legal obligation
Legal obligations: To allow us to comply with any applicable legal obligation, including obligations to retain your data for a certain period of time	Necessary to comply with an applicable legal obligation

WHO WE SHARE YOUR PERSONAL DATA WITH

We do not sell your personal data. We may share your personal data with third-party recipients in the following circumstances:

Our affiliates: We may share your personal data with one or more of our affiliates in order to provide the Services and fulfil any of the other purposes specified above. This includes our US affiliate, Qmerit Electrification, LLC.
Installers and Customers: Our relationships with Installers and Customers are essential to the Services. We may share personal data with them in order to provide the Services and in some cases, to allow them to understand and draw insights from your activities on the Sites and your use of the Services (although in most cases, usage reporting is aggregated and deidentified). We may also share your contact details with particular Customers and Installers so they can contact you about their offerings, but only where you have consented to such sharing (see Partners section below). We have contractual obligations in place with our Installers and Customers to ensure they process your personal data in accordance with data protection laws.
Service providers: We use third-party service providers to facilitate the fulfilment of essential functions, as well as to improve the Services and pursue business development initiatives. We may also allow third parties to place cookies or other tracking technologies on our Sites, which enable them to collect data about how you interact with the Sites. The key service providers that we may share your personal data with are listed below:

HubSpot (customer engagement)
Helixstorm (IT outsourcing)
DigitalOcean (web hosting)
Microsoft Azure (hosting platform)
Twilio (texting service)
Sendgrid (email service)
Five9 (customer service phone system)
Third-party cookie owners (see our Cookie Policy for further information)

Where appropriate, we have contractual obligations in place with service providers to ensure they keep personal data confidential, take steps to secure it, and only process it on our behalf and not for their own purposes (unless they are a controller of your personal data, in which case they are also directly responsible for protecting your personal data).

Partners: Where you provide consent for a specific third-party partner to contact you about their offerings, we will share your contact details with them. In particular, this may include the organisation that has referred you to the Qmerit website (such as the manufacturer of your EV or the fleet management company that leases your work vehicle) and your Installer.
Corporate transactions: We may share your personal data with relevant third parties if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.
Legal obligation: We may share your personal data with regulators, law enforcement agencies or other relevant third parties where mandatory to: (a) comply with a legal process (such as a court order, subpoena, search warrant, government investigation or other legal requirement), (b) support auditing, compliance, or corporate governance functions; (c) assist in the prevention or detection of crime, or (d) to protect the safety of any person.
Enforcement of rights: We may share your personal data with third parties such as law enforcement, regulators, investigators or legal advisors: (a) if disclosure would mitigate our liability in an actual or threatened lawsuit, (b) as necessary to protect our legal rights and the legal rights of our customers, users, partners or other interested parties, (c) to enforce our contracts with you, and (d) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
Professional advice: We may share your personal data with our accountants, auditors, lawyers, insurers, or similar advisers when we ask them to provide us with professional advice.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Your personal data is usually stored in the UK. However, we may need to transfer your personal data outside the UK and European Economic Area, including to our US affiliate, Qmerit Electrification, LLC, and to our third-party service providers.

When we transfer your data, we put adequate safeguards in place by either: (a) only transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data; or (b) using an appropriate safeguard to ensure the ongoing protection of personal data, such as approved standard contractual clauses. You may request further information on the safeguards we use by contacting us via the contact details at the beginning of this Privacy Policy.

HOW LONG WE RETAIN YOUR PERSONAL DATA

We only retain your personal data for as long as is reasonably necessary to fulfil the purpose for which it was originally collected. For example, we retain different types of driver and installation data for different periods of time depending on whether it is needed for purposes of the installation itself, satisfying a warranty, and/or for tracking product safety issues and recalls. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or if it required by applicable legal obligations.

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 obligations.

YOUR PRIVACY RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Depending on the lawful basis we are relying on and subject to some exceptions, you generally have the right to:

Access the personal data we hold about you
Request a correction or update to personal data we hold about you
Request erasure of the personal data we hold about you
Object to our processing of your personal data
Request that personal data we hold about you be restricted and only processed for limited purposes
Where we are relying on consent as the lawful basis, withdraw your consent to our processing of your personal data
Request the transmission of personal data we hold about you in a structured, commonly used, machine-readable format to a third-party service provider

Please note, where we need to process your personal data to fulfil a contract with you and you do not provide the personal data or you exercise certain rights in relation to your personal data, we may no longer be able to provide the Services to you.

You have the right to submit a complaint with the UK’s data protection regulator, the Information Commissioner’s Office (ICO). The ICO may be contacted at https://ico.org.uk/make-a-complaint/. We would appreciate the opportunity to handle your concerns before you approach the ICO, so we ask that you contact us first in this instance.

If you would like to exercise any of your rights in relation to your personal data, please contact us via the contact details at the beginning of this Privacy Policy. We respond to all requests in accordance with applicable data protection laws. Please note, we may need to request specific information from you to help us confirm your identity as a security measure.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect updates to our data processing activities or to remain compliant with changes in applicable data protection laws. We will make the updated Privacy Policy available here and on our other Sites, and we may contact you directly about updates where appropriate. Please check back regularly to stay informed about updates to this Privacy Policy.