Ohme Privacy Policy (UK & Ireland)

1. About your personal data

Ohme is committed to keeping your personal data safe and secure and handling it in accordance with our legal obligations. This Privacy Policy sets out when and why we process your personal data, who we may share it with, what rights you have in relation to your personal data and how it is kept secure.

This policy may change from time to time so please check this page occasionally to ensure that you are happy with any changes.

2. Who are we?

If you are using our services or website from the United Kingdom or the Channel Islands, including interacting with us or purchasing our products, the data controller responsible for your personal data is Ohme Operations UK Limited of 5th Floor, Wellington House, 125-130 The Strand, London, WC2R 0AP.

If you are using our services or website from the Republic of Ireland, including interacting with us or purchasing our products, the data controller responsible for your personal data is Ohme Operations Ireland Limited of Unit 74 Penrose Wharf, Penrose Quay, Cork, Republic of Ireland.

In each case, the relevant Ohme data controller is referred to as “Ohme”, “we”, “us” or “our”.

The “data controller” is the entity that decides why and how your personal data is processed.

3. What personal data do we collect and how do we collect it?

In the course of our activities as a smart charging technology provider, we collect and receive different kinds of information about you. Most of the personal data about you is voluntarily provided by you directly to us, but we also receive personal data from other third-party sources and collect technical information about you when you use our service and mobile application.

3.1. Personal data you give us.

This is information about you that you voluntarily give to us by entering information via:

3.1.1. our website (ohme-ev.com);

3.1.2. our Ohme mobile application (“App”) and your account with us;

3.1.3. conversations with us via the in-App messaging service;

3.1.4. social media platforms; and/or

3.1.5. corresponding with us by phone, post, SMS, chat, email or otherwise.

If you are a professional client, we collect personal data directly from you for the purpose of managing our commercial relationship, such as staff contact name(s), email addresses and/or phone numbers and retailer information.

If you are an individual customer, we collect some personal data directly from you when you make an enquiry with Ohme and/or register for an account with Ohme. The personal data that we collect in order to set up your account includes your full name and your email address.

Once you have set up your account, should you choose to purchase any of our products or subscribe to our services, we may collect additional data as follows:

3.1.6. your contact details, including telephone number, location, billing, and delivery address;

3.1.7. transaction data including details about payments made to and from you and details of products and/or services you have purchased and/or subscribed to through our website or otherwise;

3.1.8. your Facebook, Google or Apple ID profile information and picture (if you choose to authenticate through that method);

3.1.9. the location of your Ohme cable when it is plugged in;

3.1.10. the Vehicle Identification Number (VIN) of the car you wish to charge using our services;

3.1.11. your car login credentials (where supported), vehicle charging data, IP addresses and device identifiers;

3.1.12. your electricity supplier and tariff plan;

3.1.13. your electricity meter point administration number (MPAN) and (where applicable) associated half hourly consumption data;

3.1.14. your Bluetooth permissions if you have a Wi-Fi enabled product; and

3.1.15. your marketing preferences.

We collect personal data that you choose to communicate to us, such as when you make an enquiry regarding our products, or when you include such information in communications you send to us, including through the in-App messaging and feedback system in our App or by email.

If you choose to participate in an energy usage study or product beta test trials or new feature trials, we may collect additional data about you. We will provide you with information about the collection of additional data if we determine that you are eligible and suitable to participate in the study or trial.

In certain circumstances we may collect bank details for payments to be made by us to you. This may include commission payments due to introducers or rewards, refunds, direct payments, rebates, or goodwill payments due to individual customers.

3.2. Personal data we may receive from other sources

We may collect your personal data from a third-party company as a result of a sale of that company’s business and assets to us. We may also collect your personal data from trusted third parties or from publicly available sources, including to initiate contact with you and to enhance services to our customers and partners. We may also get information about you from other sources, such as:

3.2.1. social media sites or search engines where such information is in the public domain;

3.2.2. third parties (including fleet service providers, car dealerships and referring websites) introducing you to us who provide your details to us at your request;

3.2.3. third parties like credit reference agencies, personal banking sites, payment processors, search engines or social media sites; or

3.2.4. third parties through targeted marketing, including Facebook, Instagram, X, LinkedIn, Google, and Bing.

We may use this information with other information you provide to complete or process your purchase. This can be to comply with our legal and regulatory obligations, to improve customer interactions, to help verify or maintain data accuracy, and/or to enhance our services.

We may offer some of our products/services on or through other websites and the personal data that you provide to those sites may be sent to us in order to deliver the product/service.

The personal data we receive from third party sources is described within the “Personal data you give us” section above.

3.3. Personal data we collect about you.

We collect information about how you use our website and App, including your vehicle charging data, details of transactions you carry out through our website, your visits to our website, traffic data, location data, communication data, and the resources you access. We may also automatically collect technical information from your use of our products and services, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, device information including unique device identifier, browser plug-in types and versions, operating system, and platform, energy usage information (such as voltage levels, power quality e.g. harmonics, power capacity and power consumption).

We may also collect any personal data which you allow to be shared that is part of your public profile or third-party social network, type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

Please see our Cookies Policy for further information.

4. How do we use your personal data?

It is important that you understand how and why we use the personal data that we collect about you. Data protection law says that we have to tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you.

4.1. Performance of the contract with you or to take steps to enter into a contract with you.

We may use and process your personal data where we have supplied you (or continue to supply you) with any products or services, or where you are in discussions with us about any service. We will use this information in connection with the contract for the supply of products or services when it is needed to carry out that contract with you or for you to enter into it. This includes the following purposes:

4.1.1. to provide you with our products and services (including installation services). This may include logging into your car using your car credentials to provide certain services;

4.1.2. to set-up, manage and administer your account, including to enable you to log you into your account, to access car charging status information, and to allow you to use all features on the App to assist with charging your vehicle; and

4.1.3. to contact you via email or SMS occasionally with service messages about our products and services or the study or trial in which you are participating.

4.2. Legitimate interest as a business or that of a third party for the following purposes:

4.2.1. for marketing activities, including promoting our energy usage studies, product beta test trials, and new feature trials (other than where we rely on your consent to contact you);

4.2.2. for analysis to inform our business and marketing strategy, to help us understand how our services are used and by whom, to research customer demographics, interests, and behaviour, and to assist, enhance and personalise your customer experience (including to improve the recommendations we make to you on our website and our App);

4.2.3. to provide our products and services pursuant to agreements entered into with third parties (for example, under fleet management or introducer arrangements);

4.2.4. to determine your suitability for, and to contact you in respect of, participating in studies regarding energy usage or product beta test trials or feature test trials, to contact you regarding any studies or trials you participate in and to offer you the opportunity to provide feedback (including by completing surveys) relating to such studies or trials. We will generate reporting and analysis from the studies and trials (based on aggregated and anonymised data);

4.2.5. to monitor, analyse, and improve Ohme and our website, App, products, services, and business lines and help us to make sure that we are providing our customers with the best possible service;

4.2.6. to assist with generating your charging profile and operating flexibility services by using your address information, device location and ID, MPAN, electricity reading data (where applicable), electricity supplier, and tariff information;

4.2.7. to access your energy consumption and behaviour data to provide flexible and smart charging services to help ensure you benefit from the most cost effective and energy efficient charging;

4.2.8. to correspond or communicate with you and assist with management of your account and flexibility services;

4.2.9. to verify the accuracy of data that we hold about you, liaise with third parties such as energy suppliers, distribution and transmission network operators, National Grid, and other energy industry bodies to the extent necessary to deliver the benefits of energy usage studies and flexibility services and create a better understanding of you as a customer;

4.2.10. to provide our products and services to third parties such as distribution and transmission network operators in order to help them better understand energy usage;

4.2.11. for network and information security in order for us to take steps to protect your information against loss or damage, theft, or unauthorised access;

4.2.12. for prevention of fraud and other criminal activities;

4.2.13. to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);

4.2.14. for business administration, including statistical analysis;

4.2.15. to monitor the quality of our support to customers and your communications with us;

4.2.16. to assess and improve our service to customers and to provide staff training within the business (including through recordings of any calls with our customer contact centres);

4.2.17. for the management of queries, enquiries, complaints, or claims, and to deal with goodwill gestures, rewards and/or payments to be made to you; and

4.2.18. for the establishment and defence of our legal rights.

4.3. Consent. We may use and process your personal data where you have consented for us to do so. This includes contacting you with direct marketing information about our services (where we do not have another legal basis to contact you) and/or sharing your charging data with third party apps where you have requested that we provide access to such information. Please see Marketing for more information, including how to withdraw your consent.

4.4. Where there is a legal requirement. We will use your personal data to comply with our legal obligations as follows:

4.4.1. the prevention, detection, or investigation of a crime or fraud;

4.4.2. to meet our internal and external audit requirements;

4.4.3. to assist or respond to any courts, law enforcement agencies, regulatory agencies, and other public and government authorities; and

4.4.4. to identify you when you contact us.

4.5. Vital interests. We may use your personal data to contact you if there are any urgent health and safety notices to communicate to you or where we otherwise reasonably believe that the processing of your personal data will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal data in this way.

5. Who do we share your personal data with?

• We need to share your personal data with third parties in certain circumstances. This includes where we use third party suppliers to perform various services for us and third parties to whom we provide services.

When disclosing your personal data to third parties, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.

5.1. We may share your personal data with the following third parties:

5.1.1. Group companies and joint service providers. We may share your information with companies within the Ohme group of companies or other business affiliates or partners with whom we offer relevant joint services or offers in order to provide and improve our services.

5.1.2. Our suppliers and service providers. We may disclose your information to our third-party service providers, agents, subcontractors, and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include:

1. third party installers to install our products at your property;
2. website and app designers and developers for the purposes of developing, hosting, supporting, and maintaining the website, App, and service;
3. the provider(s) of the service on which the website or App is hosted;
4. the provider of the in-App messaging and feedback system where we share your email address and other information you voluntarily provide when you are using such system;
5. providers of login authentication where we share your email address for the purpose of such login authentication;
6. banks or payment providers to process any card transactions or subscriptions to our service, or refunds or payments due to you;
7. energy suppliers, energy aggregators, distribution and transmission network operators, National Grid, and other energy industry bodies to the extent necessary to deliver our services to you;
8. energy suppliers, energy network companies, energy system operators, energy service companies, and associated parties to research, operate and adjust charging based on the electricity system conditions, to operate in coordination with grid demands, to work on energy usage studies and to obtain the value available in different markets through the provision of flexibility services;
9. third parties that integrate with or provide access to our App, services, or trial services;
10. where you agree to participate in an energy usage study or product beta test trial or a feature test trial, we may share your personal data with third partes conducting, participating, or facilitating the study or trial and the delivery of any rewards for participation in the study or trial (if applicable);
11. businesses that introduce you to us, including (without limitation) car dealerships and referring websites. Further details are set out below.
    1. If you were referred to our website(s) from another webpage, we may share some information about you with that referring website so they can contact you about their products and services. This is done through Google Analytics – please see our Cookie Policy for further details.
    2. With some partners, where they refer you to our website, we process information on that click-through so we can pay them the correct commission.
    3. Where partners refer you to us by a dedicated referral portal or other agreed route, we may share certain data with them, and others involved in fulfilment of the order so that they can verify your order and the correct commission or payments due and fulfil the terms of an offer you have accepted.
    4. Where you have provided your prior consent (if required), we may share your information with the business partner introducing you to us or others involved in fulfilment of the order so that they can fulfil an offer you have accepted or contact you about their products, offers and/or services;
12. third parties providing support services or functions on our behalf, including (without limitation), business analytics, review agencies (such as Trustpilot), CRM system providers, customer service platform providers, outsourced customer service providers, delivery services, advertising partners and for the administration and delivery of surveys, goodwill gestures, competitions, refunds and/or rewards; and
13. professional advisers (e.g. lawyers, bankers, auditors, and insurers based in the United Kingdom and the European Economic Area who provide advisory or consultancy, banking, legal, insurance and accounting services).

5.1.3. When we use third party suppliers and service providers, we only disclose to them any personal data that is necessary for them to provide their service and carry out their agreed functions and they are not allowed to use the personal data for any other purpose.

5.2. We will also share your personal data with third parties in the following circumstances:

5.2.1. where you have specifically consented to us sharing your data with a particular third party;

5.2.2. where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party; and

5.2.3. if our business or any part of it is acquired by a third party, in which case we will need to share your personal data with that third party. This includes any business restructuring or reorganisation and also in the event of any liquidation, dissolution, or administration.

6. Where do we store your data?

Ohme stores all of your personal data within the United Kingdom and/or European Economic Area (“EEA“).

There may however be some instances where your personal data is transferred outside the UK/EEA, for example, where our external third parties and group companies are based outside the UK/EEA.

If at any time we transfer your personal data to countries located outside the UK/EEA, we will ensure that appropriate safeguards are in place for that transfer as required by law.

6.1. Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

6.1.1. Adequacy regulations. We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government and/or the European Commission (as applicable).

6.1.2. Standard Contractual Clauses. Where we use certain service providers located in countries which do not provide the same personal data protection as within the UK/EU and do not therefore benefit from an adequacy decision or adequacy regulation, we may use the EU Standard Contractual Clauses and/or the UK International Data Transfer Addendum/Agreement.

6.1.3. US Data Privacy Framework. Where we use service providers based in the US, we may transfer data to them if they are part of the Data Privacy Framework List based on the adequacy decision for the EU-US Data Privacy Framework  (including, where appropriate, the UK Extension “UK- US Data Bridge”)  which requires them to provide similar protection to personal data shared between the UK, Europe and the US. For further details, see Adequacy decision for the EU-US Data Privacy Framework and ICO: UK-US data bridge.

6.2. Please contact us using the details at the end of this Privacy Policy if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

7. Security and links to other sites

Once we receive your personal data, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

You are responsible for keeping your password for your account confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy notices.

8. Marketing

We may use your personal data to contact you with marketing information (including via email or through targeted marketing) where we have a legal basis to do so. We will never share or sell your personal data to third parties for marketing purposes.

8.1. Email marketing.

8.1.1. If you have consented to us doing so, we may contact you via email with marketing information about our products, services, promotions, or discounts that we are offering.

8.1.2. You can always opt out of receiving marketing information by following the instructions in each email to unsubscribe, or by contacting us using the details at paragraph 16 (How to contact us).

8.2. Targeting marketing via social media

8.2.1. We may use your personal data to generate targeted marketing and use targeted marketing functionalities available through various social media sites, including, but not limited to, Facebook, X, Instagram, or LinkedIn and via search engines, such as Google or Bing.

8.2.2. The relevant social media or search engine provider will be responsible for your personal data in respect of any targeted marketing they carry out on our behalf and will be able to tell you more about how they use and process your personal data.

8.2.3. We become responsible for your personal data if and when it is transmitted to us by the relevant social media or search engine provider or when you have consented to our collection of such personal data when you use our Website and/or App.

8.2.4. We recommend that you routinely review the privacy notices, terms and conditions and preference settings that are available to you on social media platforms and on search engine homepages. If you do not want to receive such targeted marketing, you can manage your settings on the relevant platform or site.

9. Data anonymisation and use of aggregated information

Your personal data may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for various business reasons including analytical and research purposes. This information may be collected by cookies placed on our website.

10. Profiling and automated decision making

We use some automated processes which may involve the use of AI products and may involve profiling (including making a decision on the basis of the profile generated). For example, we may use an automated process to assess open customer enquiries and ensure that these are addressed appropriately by our customer service staff. In such situations you will always still be able to liaise with our customer service staff to address your enquiry.

Please contact us using the details at the end of this Privacy Policy if you have any queries and/or want to contest any such decisions.

11. How long do we keep your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for any legal, regulatory, tax, accounting, payment or reporting requirements.

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.

11.1. If you are an individual customer of our products or services and you register an account with us, we will keep all your personal data for as long as your account remains active and open. If you purchase our products or register an account with us but that account becomes inactive or is closed at any time, we retain your personal data for seven years (or such longer period as may be required by law) from the point of your purchase or registration in case of any queries, complaints, or legal claims.

11.2. If you receive email marketing from us, we will store your personal data for as long as you are subscribed to our email marketing list (even if you are no longer an active customer). If you unsubscribe, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.

11.3. If you are a professional client, we will hold any personal data about you for no longer than is reasonable to carry out our services and manage our commercial relationship during the performance of the contract and after its termination. When some personal data is retained on our contracts with you, it is purely incidental to these documents and for commercial purposes only. Where possible, we will ensure that any personal data is anonymised where it is not strictly necessary.

11.4. In the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, we may store your personal data for a longer period in order to resolve your complaint or to bring or defend legal claims.

11.5. The only exceptions to the above are where:

11.5.1. we need your personal data to comply with a legal or regulatory requirement;

11.5.2. the law requires us to hold your personal data for a longer period, or delete it sooner;

11.5.3. you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further “Erasing your personal data” or “Restricting processing of your personal data” sections below); or

11.5.4. in limited cases, the law permits us to keep your personal data indefinitely provided we put certain protections in place.

11.6. When it is no longer necessary to retain your data, we will delete the personal data that we hold about you from our systems. We may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.

12. What rights do you have?

You have a number of rights under data protection law.

If you want to exercise any of these rights, please email us at [email protected] (if in the UK) or [email protected] (if in Ireland).

In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data.

Except in rare cases, we will respond to you within one month from either (i) the date that you have provided proof of identity or further information, or (ii) where we do not need to do this because we already have this information, from the date we received your request.

12.1. Accessing your personal data:

12.1.1. You have a right to ask us to send you a copy of all the personal data that we hold about you. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that personal data. We may also contact you to ask you for further information in relation to your request to speed up our response.

12.2. Transferring your personal data in a structured data file:

12.2.1. Where we rely on your consent as the legal basis for processing your personal data or need to process it in connection with your contract, you may ask us to provide you with a copy of that information in a structured data file.

12.2.2. We will provide this to you electronically in a structured, commonly used, and machine-readable form, such as a CSV file. You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.

12.3. Objecting to us processing your personal data and automated decisions made about you:

12.3.1. You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis for processing your personal data.

12.3.2. Except for the purposes for which we are sure we can continue to process your personal data; we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

12.3.3. You may object to us using your personal data for direct marketing purposes where we rely on legitimate interests, and we will comply with your request. If you would like to do so, please follow the “unsubscribe” instructions in the email sent to you.

12.3.4. You may also contest a decision made about you based on automated processing by contacting us using the details above.

12.4. Withdrawing your consent:

12.4.1. Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. You can do this by contacting us using the details above. For direct marketing communications, you can update your preferences by following the “unsubscribe” instructions in any email sent to you, or by contacting us using the details at paragraph 16 (How to contact us).

12.5. Correcting and updating inaccurate personal data:

12.5.1. You have a right to ask us to correct inaccurate data that we hold about you. If you change your name or address/email address, or you discover that any of the other personal data we hold is inaccurate or out of date, please let us know.

12.5.2. You can also update your own personal data at any time through your account settings in our App. It is your responsibility to ensure that your personal data in your account is accurate and up to date.

12.6. Erasing your personal data:

12.6.1. You have a right to ask us to delete your personal data in certain circumstances, for example, if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy.

12.6.2. Unless there is a reason that the law allows us to use your personal data for longer, we will make reasonable efforts to comply with your request.

12.7. Restricting processing of your personal data:

12.7.1. You can ask us to restrict processing of your personal data in some circumstances, for example, if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights.

12.7.2. In these situations, we may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

13. Cookies

We use cookies on our website and App. For more information see our Cookie Policy.

14. What if you have a complaint?

We hope that we can resolve any query or concern you raise about our use of your personal data. You have a right to complain to your local data protection authority, which in the United Kingdom is the Information Commissioner’s Office (www.ico.org.uk) and in Ireland is the Data Protection Commission (www.dataprotection.ie).

15. Changes to this policy

We may make changes to this Privacy Policy from time to time.

15.1. Any changes to this Privacy Policy will be notified to you by posting an updated version on our website, by a notice/message via our App, and/or by email. The date at the start of this policy will tell you when this Privacy Policy was last updated.

15.2. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy, you must immediately notify us and cease using our services.

16. How to contact us

Please direct any queries about this Privacy Policy or about the way we process your personal data to us by email to [email protected] (if in the UK) or [email protected] (if in Ireland) or through our in-App messaging service.