United Kingdom

United Kingdom

UK & Ireland Ohme Privacy Policy

1. Keeping your data safe

1.1. We are committed to keeping your personal data safe and secure and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it’s important for you to know.

2. Who runs the Ohme Website and App?

ohme-ev.com (the Website) and Ohme mobile software application (the App) and services are provided to users by:

2.1. Ohme Operations UK Limited of 5th Floor, Wellington House, 125-130 The Strand, London, WC2R 0AP if you purchased your Product or are registered or resident in the United Kingdom or the Channel Islands; or

2.2. Ohme Operations Ireland Limited of Unit 74 Penrose Wharf, Penrose Quay, Cork, Republic of Ireland if you purchase your Product or are registered or resident in the Republic of Ireland or other European territories.

In each case, the relevant Ohme entity is referred to in these terms as “Ohme”, “we”, “us” or “our”.

3. Who’s in control of my personal data?

3.1. We are the “controller” of all personal data collected and used for the purposes of providing our products and services which you have purchased and/or subscribed to and for any other purposes set out in this Privacy Policy. This means that we are responsible for deciding how and why your data is used and for ensuring that your data is handled legally and safely.

4. What data do you collect and where from?

4.1. In the course of our activities as a smart charging technology provider, we collect different kinds of information depending on whether you are a professional client who wants to acquire our products to resell or introduce potential customers to us or a consumer/end user wishing to acquire our products and/or register for an account with the Ohme application and wishing to use our technology in connection with your electric vehicle.  If you are a professional client, we collect some 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 a consumer/end user, we collect some personal data directly from you when you make an enquiry with Ohme and/or register for an account with Ohme. The data that we collect in order to set up your account includes the following:

4.1.1. your full name;

4.1.2. your email address.

4.2. 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:

4.2.1. billing and delivery address;

4.2.2. 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;

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

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

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

4.2.6. your car login credentials (where supported);

4.2.7. your electricity supplier and tariff plan;

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

4.2.9. technical information about how you use our Website and App and service. This includes your vehicle charging data, IP addresses and device identifiers.

4.3. We collect personal data that you choose to communicate to us, such as when you set up your account or 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.

4.4. We may also collect 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. For example, we might also get information about you from other sources, such as:

  • social media sites or search engines where such information is in the public domain;
  • third parties introducing you to us and other third parties like credit reference agencies, personal banking sites, payment processors, search engines or social media sites. We may use this information with other information you provide to complete or process your purchase; or
  • third parties through targeted marketing. Such third parties may include
    • (i) social media sites such as Facebook, Instagram, X or LinkedIn if you use them, or
    • (ii) search engines, including, but not limited to, Google or Bing. 

We recommend you routinely review the privacy notices and preference settings of such information sharing platforms. If you do not want to receive such targeted marketing, you can manage your settings on the applicable social media platform.  We will respect any permissions you have set on those platforms regarding our use of your personal data collected from those sites. If you do not want to receive such targeted marketing from us, please contact us on [email protected].

4.5. We collect technical information about how you use our Website and App and service. This includes your vehicle charging data, IP addresses and device identifiers.

4.6. We also may collect data about how you use our Website and App by using cookies and other similar technologies.

4.7.  If you choose to participate in an energy usage study (.e.g. a demand flexibility service or 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.

4.8. 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 refunds or goodwill payments due to customers/end users.

5. What do you use my personal data for?

5.1. It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.

5.2. Managing your account and providing you and others with our products and services. This may include sharing your personal data with third party installers to install our products at your property.

5.2.1 We use the personal data that you provide to set up your account, manage and administer your account, to log you into your account, to access car charging status information and to allow you to use all Ohme features on the App to assist with charging your vehicle.

5.2.2. We use your email address to contact you occasionally with service messages about Ohme.

5.2.3. We use your cable location, MPAN, half hourly electricity reading data (where applicable), electricity supplier and tariff to assist with generating your charging profile.

5.2.4. We use information you voluntarily provide to us when contacting us with enquiries about our products, queries, comments or complaints to enable us and others to respond to those queries, complaints or comments and to make sure that these are appropriately dealt with and to deal with goodwill gestures and/or payments to be made to you. We may also use this information to deal with legal issues including insurance matters and legal claims.

5.2.5. Where you have been introduced to us by a third party, we may use your personal data to deal with any complaints or other issues which you may choose to escalate via such third party.

5.3. Improving our services and conducting studies

5.3.1. We use your personal data to help us monitor, analyse and improve Ohme and our products and services we offer. This helps us to make sure that we are providing you with the best possible service.

5.3.2. We may use your personal data to determine your eligibility and suitability for studies regarding energy usage (e.g. demand flexibility services and studies) or product beta test trials or feature test trials and to to offer you the opportunity to participate in such studies or trials. We will provide you with information about the use of your personal data in the study or trial if we determine that you are eligible and suitable to participate in the study or trial.

5.3.3.    We may use your personal data to prepare analysis and reports to be shared with third parties.  The analysis and reports will only contain aggregated and anonymised data and as such they will not contain your personal data.

5.4 Marketing

5.4.1 Where you have consented to us doing so, or where we have a legitimate interest in communicating with a professional client (and that professional client has not previously unsubscribed from marketing communications), we will use your email address to send you updates on any new products or services we are offering. You can always opt out of receiving these emails by following the instructions in each email to unsubscribe.

5.4.2. Where you have consented to us doing so, we will also use your email address to send you emails about promotions or discounts that are being offered.

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

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 generally, you can switch this off on the relevant platform or site.  If you do not want to receive such targeted marketing form us, please contact us using the details below.

5.5  Profiling and automated decision making We use some automated processes which may involve the use of AI products and which may involve profiling (including making a decision on the basis of the profile generated). In such situations you will always still be able to liaise with our customer service staff to find alternative suggestions or deal with your queries. 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. Please contact [email protected] if you have any queries and/or want to contest any such decisions.

6. What is your legal basis for using my personal data?

6.1. 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. Most commonly we will use your personal data in the following circumstances:

  • on the basis of your consent (such as for the purposes of sending e-marketing and communications information you have requested or sharing your information with a third party installer or other relevant party);
  • to perform our contract with you (. i.e. provide you with our products and/or services or provide information you have requested, such as more information about us or our products or to register for your account) or our contract with others (such as third parties who introduce you to us);
  • 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; or
  • where we need to comply with a legal obligation.

The table below tells you what that legal basis is in relation to each of the purposes set out above.

PurposePersonal data usedLegal basis
Running your account and allowing you to access and use the Website, App and service including contacting you with service messagesName, username, email address and other information provided by you in the App set up and login process for authentication purposes (e.g. Apple, Google or Facebook login credentials)We process this personal data for this purpose on the basis that this information is necessary in order to perform our contract with you to provide the Website, App and services.
Providing you with our products and services (including installation services where applicable)Address, Car login credentials, Electricity supplier and tariff plan, MPAN, payment details, Cable location, VINWe process this personal data for this purpose on the basis that this information is necessary in order to perform our contract with you to provide the product you have purchased or the service you have subscribed to.
Improving our services and conducting studiesYour account and profile information plus the technical information that we collect about your device (including, where applicable, MPAN and associated half hourly consumption data) and how you use the Website, App and serviceWe process this personal data for this purpose on the basis that the processing is necessary for our legitimate interests.  We have an interest in ensuring that we continue to improve our Website, App and service and provide our users with the best and most effective App and service possible, as well as in determining your suitability for, and contacting you in respect of, participating in studies and  trials and generating reporting from the studies and trials based on aggregated and anonymised data. In some cases, we may also process personal data for this purpose on the basis of consent (e.g. if you consent to the processing of your personal data for the purpose of a study or trial).
MarketingYour email address and, for professional clients, your phone numberWe process this personal data for this purpose on the basis that we have your consent to do so or, if you are a professional client, on the basis that it is necessary for our legitimate interests. You can withdraw your consent at any time by following the “unsubscribe” instructions in marketing emails or (where applicable) by changing your account settings.
Compliance with legal obligationsName, username, email address, address, account and profile information, information to process payments and, for professional clients, information required for invoicing mattersWe process and retain this personal data for this purpose in order to comply with our legal obligations.

Wherever we rely on your consent to process your personal data, you will be able to withdraw consent at any point.

7. Who do you share my personal data with?

7.1. We need to share your personal data with some third parties in some circumstances. This includes where we use third party suppliers to perform various services for us and third parties to whom we provide services. Third party suppliers we share your personal data with may include:

7.1.1. Internal third parties: business affiliates with whom we offer relevant joint services or offers, such as companies within the Ohme group of companies in order to provide and improve our services;

7.1.2. External third parties:

7.1.2.1. website and App designer and developer for the purposes of developing, hosting, supporting and maintaining the Website, App and service;

7.1.2.2. the provider of the service on which the Website or App is hosted. This would only happen very occasionally and would only be if strictly required in the event of an emergency;

7.1.2.3. 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;

7.1.2.4. providers of login authentication where we share your email address for the purpose of such login authentication;

7.1.2.5. banks or payment providers to process any card transactions or subscriptions to our service or refunds or payments due to you;

7.1.2.6. 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 and to operate in coordination with grid demands;

7.1.2.7. third parties with whom the personal data needs to be shared for the provision of our Services and trial services, including (without limitation) businesses used to provide access to such Services and/or the relevant trial service;

7.1.2.8.  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). We will provide you with information about this if we determine that you are eligible and suitable to participate in the study or trial;

7.1.2.9 businesses that introduce you to us, including (without limitation) car dealerships and referring websites. 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. 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. Where other partners refer you to us by a dedicated referral portal, we may share certain data with them so that they can verify your order and the correct commission or payments due. Subject to obtaining your prior consent where required, we may share your information with the business partner introducing you to us so that they can fulfil an offer you have accepted or contact you about their products, offers and/or services; and

7.1.2.10 professional advisers acting as controllers (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).

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

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

7.2.2. 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

7.2.3. 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.

7.3. Ohme stores all of your Data within the European Economic Area (“EEA“).

7.4. However, some of our external third parties and group companies are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

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

7.5.1. We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

7.5.2. 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 Agreement.

7.5.3. Where we use 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. Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. How long do you keep my personal data for?

8.1. 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, payment 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 to our relationship with you.

8.2 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.

For example, we will hold any personal data about our Clients 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 (for instance, holding data in accordance with legal or fiscal obligations in pursuit or defence of a claim). When some personal data is retained on these documents, it is purely incidental to documents which are generally required strictly for commercial purposes. Where possible, we will ensure that any personal data is anonymised where it is not strictly necessary. 

8.3 We will hold any personal data about consumers/users for no longer than is necessary for the purposes for which it is processed. Generally, we will keep all your personal data for as long as your account remains open.

8.4. If your account is inactive for a period of one year, we reserve the right to close your account and delete your personal data in accordance with the section above.

8.5. We may need to keep your data after account closure for limited purposes, for example if we need your data in order to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need to in order to fulfil those purposes.

9. What rights do I have?

9.1. You have a number of rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.

9.2. We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.

9.3. If you want to exercise any of these rights, please email us at [email protected] if resident in the UK or Ireland or write to us at Ohme Operations UK Limited, 5th Floor, Wellington House, 125-130 The Strand, London, WC2R 0AP.

9.4. A right to access your information

9.4.1. You have a right to ask us to send you a copy of all the personal data that we hold about you (subject to some exceptions)

9.5. A right to an electronic copy of your information

9.5.1. You can also ask us to send you the mandatory account information we hold about you in a common electronic format, or to ask us to transfer that data to a third party if you want us to and if it is technically feasible for us to do so.

9.6. A right to object to us processing your information

9.6.1. 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 of our processing. This includes non-mandatory account and profile data, other personal data that you upload in posts, comments and messages, personal data we use for profiling and targeted advertising and the technical information that we collect for the purposes of analysing and improving the Website.

9.6.2. If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.

9.7. A right to ask us not to market to you

9.7.1. You can ask us not to send you direct marketing. You can do this by following the “unsubscribe” instructions in any marketing emails or by changing your account settings, or by contacting us using the details above.

9.8. A right to have inaccurate data corrected

9.8.1. You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.

9.8.2. You can update your own personal data at any time through your account settings. It is your responsibility to ensure that your personal data is accurate and up-to-date.

9.9. A right to have your data erased

9.9.1. 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.

9.9.2. We will delete the personal data associated with your account in these circumstances

9.10. A right to have processing of your data restricted

9.10.1. 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.

9.10.2. Restricting your personal data means that we only store your personal data and don’t carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.

10. Cookies

10.1. We use Cookies on our website and mobile app. For more information see our Cookie Policy.

11. How can I contact you?

11.1. If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can contact us at:

11.2. Email Address: [email protected].

11.3. Address for Ohme Operations UK Limited: 5th Floor, Wellington House, 125-130 The Strand, London, WC2R 0AP, United Kingdom

11.4. Address for Ohme Operations Ireland Limited: Unit 74 Penrose Warf, Penrose Quay, Cork, Ireland

12. What if I have a complaint?

12.1. 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, if you are unhappy with how we have processed your personal data. For a list of EEA data protection supervisory authorities and their contact details, click here.

12.2. In the United Kingdom this is the Information Commissioner’s Office. You can find out how to do this by visiting www.ico.org.uk.  In Ireland this is the Data Protection Commission. You can find out how to do this by visiting https://www.dataprotection.ie/en/contact/how-to-contact-us.

13.What if this policy changes?

13.1. We may make changes to this Privacy notice and our Cookie Policy from time to time. Any changes we make will be posted on this page so please revisit these pages regularly if you want to keep up to date with any changes we have made.

Last updated: 17 January 2024