This statement describes our practices for the data processing activities set out below. Please read this statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (personal data), and to learn about your rights and choices regarding our processing of your personal data.
1. WHO WE ARE
We are Liberty Charge Limited (No. 12231122) (trading as Believ) and we are the controller of personal data that is collected and used in connection with our website at www.believ.com (Website) and our Believ mobile device application (App). If you have any queries regarding this statement, please contact us at the details below.
2. PERSONAL DATA WE COLLECT
2.1 Believ may collect information in the following ways:
(a) through information automatically gathered from your computer or device, or through information you voluntarily provide at this Web Site or via our App. As to automatically gathered information, this Web Site collects navigational information about where visitors go on this Web Site, how many visits are made to this Web Site, when this Web Site is visited, and other non-personally identifiable information (for example, this can include your domain name, browser version, service provider).
(b) Information we collect when you register for a Believ event. We will store your contact details (including name, email, address and phone number) when you fill in the registration form in order to attend any of our events;
(c) Information we collect when you purchase electricity charging services via our Website or via our App. When you complete a transaction to purchase charging services via our Website or via our App, we may collect information about your location, the charge point that you used to receive the charging services, the amount of electricity purchased for your charge and your credit card or debit card information. Where you register for an account via our Website or via our App, we will store your name, contact details or those of your company in case you are a business customer, payment card details and transaction history, customer ID, subscription type (pay as you go or subscription), contact preference and, if you choose to provide them, gender, vehicle model and license plate. We may ask you to provide documentation to verify that you qualify for a specific discount, like taxi drivers, partner customers, etc. If you contact us regarding a customer service enquiry or complaint regarding the charging services, we will also collect information about your enquiry or complaint; and, if you choose to provide them, vehicle make and model.
(d) Information we collect when you apply for a job through our careers site. The data included in the candidate account (e.g. your name, e-mail address and CV; hereafter collectively Your Data) will be processed by Believ as the controller for the purposes of candidate selection, placement and employment.
2.2 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. However, if we combine or connect aggregated data with our personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this statement.
3. USE OF COLLECTED INFORMATION
3.1 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:
(a) Where we need to perform the contract we are about to enter into or have entered into with you;
(b) 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;
(c) Where we need to comply with a legal obligation; and
(d) Where you have given us your explicit consent to use your personal data for a specified purpose.
3.2 The navigational information that is automatically gathered when you visit our Website is used on an aggregate basis to evaluate the effectiveness of our Website, to analyse trends and to administer the Website. This navigational information allows us to determine such things as which areas of our Website are most visited and difficulties visitors may experience in accessing our Website. Our lawful basis for using your personal data in these circumstances are our legitimate interests in ensuring that our Website and our App functions properly and in a manner which best suits the needs of our users.
3.3 The information you provide when you register to attend a Believ event will be used to contact you for communications related to Believ or its events unless you tell us not to do so. Our lawful basis for using your personal data in these circumstances is legitimate interest.
3.4 The information we collect in connection with the provision of charging services made available via our Website and our App is to process your payment for the services and, where you decide to register for an account, to keep your account information up to date and to store your contact details and payment card details to allow faster payments for our services.
3.5 We may also use your personal data where necessary in connection with any customer service enquiries or complaints you may bring to us. Our lawful basis for using your personal data in these circumstances is that it is necessary in order to perform our obligations under our contract to provide charging services to you.
3.6 We may also use your personal data for marketing purposes which may include contacting you for customer surveys or testimonials and to deliver information about products or services we feel may be of interest to you, unless you have opted-out. You may opt-out of receiving marketing communications at any time by sending an email to [email protected] (with the words “opt-out” in the subject line) or by using the opt-out link at the bottom of any emails we may send you. Please allow 3 business days to be opted-out. Our lawful basis for using your personal data in these circumstances is legitimate interest.
3.7 Your Data will be processed by Believ as the controller for the purposes of candidate selection, placement and employment. This data will be retained for the period of up to 1 year after closing the selection process, after which it will be deleted. Our lawful basis for using your personal data in these circumstances is that it is necessary and in our legitimate interests to assess candidates for our vacant positions.
4. DO WE SHARE YOUR PERSONAL DATA?
4.1 Believ does not sell, rent or trade the information you voluntarily provide to us on our Website or our App to third parties, except as noted below. Personal information collected on our Website may be shared with our affiliate companies. Our affiliate companies may use this personal information, for example to respond to those individuals who request company and subscriber information regarding the affiliate or who submit other requests or questions regarding the affiliate.
4.2 You should also be aware that we may disclose specific information about you if necessary to do so by law or based on our good faith belief that it is necessary to conform or comply with the law, or it is necessary to protect the users of our Website, our App or the public.
4.3 We may also share personal data with our third party service providers to the extent necessary to enable them to provide services to us.
4.4 Aggregated data is shared with our partners including local authorities and other third parties for the purposes of reporting on the performance of our network.
5. INTERNATIONAL TRANSFERS
5.1 Some of our suppliers who process your personal data on our behalf in the delivery of their services to us may either be based outside of the UK, or they may use sub-contractors based outside of the UK. Therefore, there may be circumstances where the processing of your personal data will involve a transfer of that data outside of the UK, or your personal data may be accessible from or processed in countries outside the UK.
5.2 Whenever there is a transfer of your personal data out of the UK, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer or allow your personal data to be accessed from or processed in countries that have been deemed to provide an adequate level of protection for personal data that is equivalent to the protection provided under UK data protection laws (for example, European Union Member States); or
(b) Where we use certain suppliers that are either based outside of the UK, or their sub-contractors are based outside of the UK, we may use specific contracts approved for use in the UK which give personal data the same protection as it has in the UK.
5.3 Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.
6. DATA RETENTION
6.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. We may retain your contact details for marketing purposes for 1 year from the date you cease to be a customer, unless you have opted-out prior to or upon ceasing to being a customer.
6.2 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.
6.3In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7. YOUR RIGHTS
7.1 You can control how we use your information, requesting any of the following from us at any time, by sending an email to [email protected]
7.2 You have the right to:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) 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.
(c) 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.
(d) 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.
(e)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:
(i) If you want us to establish the data’s accuracy.
(ii) Where our use of the data is unlawful but you do not want us to erase it.
(iii) 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.
(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) 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.
(g) 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.
8. SECURITY PROCEDURES
We have established and maintain adequate security procedures to protect the security and integrity of your personally identifiable information.
10.1 The Company processing your data is Liberty Charge Limited, Griffin House, 161 Hammersmith Road, London, England, W6 8BS. If you have any questions or queries about how we process your personal data, or if you wish to exercise your rights (to access, delete or to object to the processing of your personal data) you can contacts us sending an email to [email protected]
10.2 If you are not satisfied with the response we give you, you can also lodge a complaint with the Data Supervisory Authority, which in the UK is the Information Commissioner’s Office, ICO (https://ico.org.uk/).
11. CHANGES TO THIS STATEMENT
If elements of our privacy practices change, we will inform you by updating this statement in our Website.
12.1 Our Website uses a browser feature known as a cookie, which assigns a unique identification to your computer. Cookies are typically stored on your computer’s hard drive and are used by our Website to help track your selections as you navigate the pages within our Website. Cookies may also be used to determine your browser plug-ins so that we may optimize your experience on our Website.The information does not usually directly identify you, but it can give you a more personalised website experience.
12.2 The cookies we use on our Website are organized into a number of categories which are described below.
(a) Strictly Necessary Cookies: these cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
(b) Analytical Cookies: these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
(c) Functional Cookies: these cookies enable the website to provide enhanced functionality and personalisation. This enables us to personalise our content for you, greet you by name and remember your preferences.
(d) 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.
|2||cookielawinfo-checkbox-necessary||1 year||Strictly Necessary||Set by the GDPR cookie consent plugin, this cookie is used to record the user consent for the cookies in the “Strictly Necessary” category .|
|3||cookielawinfo-checkbox-analytics||1 year||Strictly Necessary||Set by the GDPR cookie consent plugin, this cookie is used to record the user consent for the cookies in the “Analytical” category .|
|4||__hssrc||session||Strictly Necessary||This cookie is set by Hubspot whenever it changes the session cookie. The __hssrc cookie set to 1 indicates that the user has restarted the browser, and if the cookie does not exist, it is assumed to be a new session.|
|5||_ga||session||Analytical||The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.|
|6||_gid||session||Analytical||Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.|
|7||_gat_gtag_UA_171243904_1||session||Analytical||Set by Google to distinguish users.|
|8||__hstc||session||Analytical||This is the main cookie set by Hubspot, for tracking visitors. It contains the domain, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).|
|9||Hubspotutk||session||Analytical||HubSpot sets this cookie to keep track of the visitors to the website. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.|
|10||__cf_bm||30 minutes||Functional||This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.|
|11||__hssc||session||Functional||HubSpot sets this cookie to keep track of sessions and to determine if HubSpot should increment the session number and timestamps in the __hstc cookie.|
|12||_GRECAPTCHA||session||Functional||This cookie is set by Google reCAPTCHA, which protects our site against spam enquiries on contact forms.|
|13||__hs_do_not_track||6 months||Strictly Necessary||This cookie can be set to prevent the tracking code from sending any information to HubSpot.|
12.3 Strictly Necessary Cookies are always turned on. All other cookies are switched off unless your choose to accept them.
12.4 You can find more information and manage your cookie preferences at any time by clicking on the following button: