Siemens Aktiengesellschaft, Werner-von-Siemens-Str. 1, 80333 München (“Siemens”) and Digital Charging Solutions GmbH, Rosenstraße 18-19, 10178 Berlin, Germany, E-Mail fleet@digitalchargingsolutions.com (“Digital Charging Solutions GmbH”), each an individual data controller, cooperate to provide you with services and solutions in the context of eMobility. Within the scope of the cooperation you have the opportunity to use the APP. The confidentiality and integrity of your personal data is of particular concern to us. We will therefore process your information carefully and in accordance with the legal provisions on data protection.

1. Who is responsible for the Processing of my data?

This privacy policy stipulates how we, Digital Charging Solutions GmbH, process Personal Data about you as a user of Enterprise Charging Network.

Personal Data is any information about personal or material circumstances relating to an identified or identifiable person. This includes, for example, your name, date of birth, e-mail address, postal address or telephone number. No Personal Data, on the other hand, is information of a general nature that cannot be used to determine your identity. This is, for example, the number of users of a website.

Processing is any operation carried out with or without the aid of automated procedures relating to Personal Data, such as the collection, recording, storage, use or deletion of Personal Data.

Since we determine the purposes and means of this Processing of Personal Data, we are the so-called Controller. We act independently of Siemens, i.e. Siemens is also individually responsible for data processing in its own area with regard to the Enterprise Charging Network.

We will use your Personal Data exclusively in accordance with the applicable data protection laws, in particular the European General Data Protection Regulation ("GDPR").

2. For what purposes do we process your data and on what lawful legal basis is the data being processed?

We process your data to enable you to use Enterprise Charging Network (e.g. by charging at a charging station) and to enable the billing of charging processes in cooperation with Siemens.

The Processing of Personal Data to enable the use of Enterprise Charging Network and to enable billing is based on Article 6 paragraph 1 (b) GDPR, i.e. the Processing is necessary for the performance of the contract between you and us and the contract between Siemens and us.

Further individual Processing, such as individual transmissions to third parties (see section 4 below) are carried out on the basis of Article 6 paragraph 1 (a) GDPR, i.e. we process your Personal Data on the basis of your consent.

Insofar as Processing is necessary for compliance with a legal obligation, this Processing is carried out on the basis of Article 6 paragraph 1 (c) GDPR.

3. What data do we process?

To provide you with the best possible service of Enterprise Charging Network, it is necessary to process the following Personal Data:

Contact data, e.g.:

  • Your first name
  • Your last name
  • Your address
  • Your email address

Account data, e.g.:

  • Your customer login information
  • A unique identification number assigned to the Enterprise Charging Network card or authentication device that you use for authentication at the charging stations

Vehicle data, e.g.:

  • The Vehicle Identification Number (so-called "VIN" number)
  • Electric Vehicle Contract Identifier (so-called "EVCO-ID")

Charging data, e.g.:

  • Information on the records of the use of the charging stations, which show your individual charging processes (especially consumption and duration of the charging process), so-called "charge detail records".
  • Information on the locations of the charging points where charging has been carried out and information on your location if you are using an e-route service and have activated the GPS function in the Enterprise Charging Network app
  • All other data collected during the loading process

4. To whom are your data transferred?

In order to provide you with the best possible service, the following third party services are involved by us in providing Enterprise Charging Network:

Google Maps

In order to ensure the correct input of addresses, we have integrated into our website the service Google Maps from Google Ireland Limited (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland) through an API. In order to display the content in your browser, Google must receive your IP address, otherwise Google will not be able to provide you with this embedded content.

By using Google Maps, information about your use of this website (including your IP address) may be stored and processed outside the European Union (including the United States). In such so-called third countries, there may not be an "adequate level of protection" for the Processing of Personal Data from the perspective of the European Union, which is equivalent to the requirements here. However, such a level of protection can be created by certain measures. This measure is provided by the so-called EU-U.S. Privacy Shield. Details of certification under the EU-U.S. Privacy Shield can be found on the U.S. government's website: https://www.privacyshield.gov. Google may transfer the information obtained from Maps to third parties, if required by law or to the extent that third parties process this data on behalf of Google.

You can deactivate the Google Maps service and thus prevent the data transfer to Google by deactivating JavaScript in your browser. However, we would point out that in this case you cannot use the map display on our pages.

More information on the purpose and scope of the data collection and its Processing by the plug-in provider can be found in the provider’s privacy policy. There you will also find further information about your rights as well as settings options for the protection of your privacy: https://policies.google.com/privacy?hl=en&gl=de. The legal basis of the Processing is art. 6 I letter (f) GDPR, due to our legitimate interest in ensuring the correct address is entered.

Siemens as Fleet provider

We transfer the collected data, especially the charging data (see point 3), to Siemens, your fleet provider, for billing purposes.

The legal basis for this Processing is derived from Article 6 paragraph 1 (b) GDPR, i.e. the Processing is necessary for the performance of the contract.

Enterprise Charging Network customer support for drivers

We want to offer you the best possible customer support. Therefore, the Enterprise Charging Network customer support for drivers is primarily provided directly by Siemens. If further support is required, Siemens will contact us with your request. For this purpose, Siemens forwards all necessary information (such as your name, contract number, card number, any relevant information on charging procedures) to us. If necessary, service providers are also integrated into the service. These service providers may be external IT service providers or service providers of the charging station providers. In order to be able to offer you support as quickly as possible, these service providers have access to all the information required to support you.

The legal basis for this Processing is derived from Article 6 paragraph 1 (b) GDPR, i.e. the Processing is necessary for the performance of the contract.

5. For how long do we store your data?

Your Personal Data will only be stored by us for as long as it is necessary to achieve the purposes for which the data was collected or - insofar as there are legal retention periods going beyond this (e.g. in the German Commercial Code and the German Fiscal Code) - for the duration of the legally prescribed retention period. Afterwards, your Personal Data will be deleted by us. Only in a few exceptional cases your data may be stored beyond this period, e.g. if storage is necessary in connection with the enforcement and defence of legal claims in our favour.

6. How do we ensure product quality, research and development of new products?

In addition to providing you with services, we will also process your data for the purposes of quality assurance at Enterprise Charging Network and the development of new comparable services. We do this in order to meet the high driver requirements of existing products and services and to be able to meet your future needs with new products and services that are still to be developed. In order to protect your privacy, the Processing is only carried out in a form that cannot be directly traced back to the driver. The legal basis for this Processing is derived from Article 6 paragraph 1 (f) GDPR, i.e. the Processing is necessary for the purposes of the legitimate interests pursued by us.

We also analyze your user behavior in our mobile apps. This serves to adapt the quality and user-friendliness of our services to the wishes of our customers, also in the context of mobile apps (Art. 6(1)(f) GDPR. This serves the legitimate interest of DCS to meet growing customer requirements. You have the possibility to object to this processing in our Mobile Apps at any time.

In connection with user behavior in our mobile apps, the following categories of data are processed:

  • General use: Beginning and end of use (date and time), duration of stay, use of individual functions, buttons and page views, search behaviour and search terms, use of actions such as voucher codes.
  • Device related data: Device type, operating system, language settings, time zones, location, app settings, app crashes and other errors.

For this processing, these personal data are transferred to Mixpanel, Inc. (405 Howard St., 2nd Floor, San Francisco, CA 94105). Mixpanel, Inc. is EU-US Privacy Shield certified, thus ensuring an adequate level of data protection.

7. Do you receive promotional communication from us or communication for market research purposes?

We use your contact information to send you advertising via e-mail or in the app for our own similar services or products. You have the right to object to this use of your data at any time. To do so, please contact us at the contact address given in point 10 below. You can also opt-out of this use via a link in each advertising e-mail or via the settings in the App. The legal basis or legitimacy of this Processing is derived from Article 6 paragraph 1 (f) GDPR or § 7 paragraph 3 of the German Unfair Competition Act.

If you have separately given your consent to a more extensive use of your Personal Data, we may use your Personal Data to the extent described in the respective declaration of consent. For example, your data may be used for advertising purposes and market research and may be passed on to third parties. Details in this regard can be found in the respective declaration of consent, which can be revoked at any time. For this purpose, please refer to the contact stated below under point 10. The legal basis for this Processing is derived from Article 6 paragraph 1 (a) GDPR, i.e. we process your Personal Data on the basis of your consent.

8. How do we protect your Personal Data?

We secure your data according to the state of the art. As an example, the following security measures are used to protect your Personal Data from misuse:

  • Access to Personal Data is restricted to a limited number of authorized persons for the specified purposes.
  • The collected data is only transmitted in encrypted form.
  • Access to IT systems is permanently monitored in order to detect and ward off misuse at an early stage.

9. What rights do you have?

You are entitled to the following rights:

  • In accordance with Article 15 GDPR, you have the to obtain confirmation from us as to whether or not personal data concerning you are being processed. If this is the case, you have the right to access this personal data. In addition, you may request access to your Personal Data and/or copies of such data. This includes information on the purpose of the use, the category of data used, the recipients and persons authorised to access them and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration;
  • In accordance with Articles 16, 17 and 18 GDPR, you have the right to demand the rectification, erasure or restriction of the Processing of your Personal Data if its use is not permitted under data protection law, in particular because (i) the data is incomplete or incorrect, (ii) it is no longer necessary for the purposes for which it was collected, (iii) the consent on which the Processing was based has been revoked, or (iv) you have successfully exercised your right to object to data Processing; in cases where the data is processed by third parties, we will forward your requests for rectification, erasure or restriction of Processing to these third parties, unless this proves impossible or involves a disproportionate effort;
  • You have the right to refuse your consent or - without affecting the lawfulness of the data Processing operations carried out before the withdrawal - to withdraw your consent to the Processing of your Personal Data at any time;
  • According to Article 22 GDPR, you have the right not to be subjected to a decision based solely on automated Processing which has legal effect or significantly affects you in a similar way;
  • Under Article 20 GDPR, you have the right to request the Personal Data relating to you that you have provided to us in a structured, common and machine-readable format and to transfer this data to another responsible party without hindrance by us; if necessary, you also have the right to request that we transfer the Personal Data directly to another responsible party insofar as this is technically feasible;
  • You also have the right to object at any time, for reasons arising from your particular situation, to the Processing of your Personal Data carried out pursuant to Article 6 paragraph 1 (e) or (f) GDPR. Once an objection has been lodged, we will no longer process your Personal Data unless we can demonstrate compelling reasons for Processing which are worthy of protection and which outweigh your interests, rights and freedoms, or unless the Processing serves to assert, exercise or defend legal claims (cf. Article 21 paragraph 1 GDPR, so-called "limited right of objection"). In this case, you must give reasons for the objection that arise from your particular situation. You also have the right to object at any time, even without stating reasons, to the Processing of your Personal Data for the purposes of direct marketing.
  • In addition to the aforementioned rights, Article 77 GDPR gives you the right to lodge a complaint to a supervisory authority if you believe that the Processing of your Personal Data violates data protection regulations. As a rule, you can contact the supervisory authority at your usual place of residence or workplace or at our registered office.

10. Who can you contact with questions?

Please contact us if you have any questions:

Digital Charging Solutions GmbH

Keyword: Data protection

Rosenstraße 18-19

10178 Berlin

Germany

Email: dataprotection@digitalchargingsolutions.com