Privacy Policy

Privacy Statement

Last modified on: 03.10.2022

I. Introduction

1. Who are we?

Blulinc, with registered office at Laarnebaan 106B, 9070 Destelbergen and enterprise number BE0775.669.111 (hereinafter “Blulinc”, “we”, “us” or “our”) attaches great importance to your privacy and considers it important that your personal data is always treated with the necessary care and confidentiality.

This privacy statement (hereinafter “Privacy StatementThis statement explains why we request your personal data and what we do with this data. If you have any questions after reading this Privacy Statement, you can of course always contact us.

We clarify that this statement applies only to the personal data processed by Blulinc as the data controller. This means that we determine the purpose and means of processing your personal data.

By 'processing of personal data', we mean any processing of data that can identify you as a natural person. You can read exactly which data this concerns further in this Privacy Statement. The term 'processing' is broad and covers, among other things, the collection, storage, use, or distribution of such data.

For questions regarding this statement or the processing of your personal data, we would like to refer you in the first instance to your known contact person at our company. You can also always reach us via the details below:

via email: privacy@blulinc.com

via letter: Blulinc NV, Laarnebaan 106B, 9070 Destelbergen

2. When does this Privacy Statement apply?

This Privacy Statement applies to the processing of personal data via the Blulinc mobile Application (hereinafter “the App”) and to all activities associated with this or (commercial) relationships arising from or maintained through it.

This Privacy Statement should be read in conjunction with the other terms and conditions applicable to the App. The data subjects (hereinafter “you”, “your”) to whom this Privacy Statement is addressed are the users of the App.

Some data is processed through the use of cookies or similar technologies. For further explanation regarding this, please refer to our Cookie statement.

II.Gebruik of personal data

A. When do we collect your personal data?

We collect and process your personal data as the data controller when you use the App and the services connected to it.

When you use the App for the first time, the App requests permission to use certain personal data from your mobile device (such as the device's location, access to the device's camera, etc.). You can change these settings at any time in your mobile device's settings. Please note, however, that changing this setting may affect the functioning of the App.

B. What personal data may we collect?

Below, we clarify which data we may process about you, depending on your relationship with Blulinc. This does not mean that we possess all the data about you listed below in all cases.After all, this will always depend on the specific situation and your preferences.

Creating a Blulinc account

When you wish to use our Services and create a Blulinc account on the App for those purposes, we may process the following data from you:

Your contact details

for example your name, phone number, email address, address, …

Financial data

for example financial identification details such as a bank account number, …

Your personal characteristics

for example your age, …

The characteristics of the car

for example, car type, photos of the car, license plate, …

Your identification details

for example, a copy of your identity card (solely to verify your identity if necessary when you wish to exercise one of your rights as a data subject under the General Data Protection Regulation or in the case of drawing up a purchase agreement).

Using the App

If you use our App, we process the following data from you based on cookies and certain functions provided in the App:

Your contact details

for example your name, phone number, email address, address, …

Your electronic identification details:

for example, your IP address, browser type, connection times, location data, preferred language, …

Your identification details

for example, a copy of your identity card (solely to verify your identity if necessary when you wish to exercise one of your rights as a data subject under the General Data Protection Regulation).

Charging

When you wish to use a charging station and scan the QR code on the charging station or locate the charging station and use it to charge your car, then we process the following data from you:

Financial data

for example, financial identification data such as a bank account number necessary to make payments on the App.

Details about your charge

for example, start and stop times, your electricity consumption, the ID of the charging station, and the location of the charging station.

C. Special categories of personal data

In principle, we will not process special categories of personal data (i.e. process data concerning racial or ethnic origin, political opinions, religious or philosophical views, trade union membership, genetic data, biometric data to uniquely identify a natural person, health or the sex life or sexual orientation of a natural person) unless they are transferred to us with your express consent.

D. What are the legal grounds we use to process your personal data?

We process your data only for legitimate purposes, whereby the processing will always be based on the processing grounds listed in the General Data Protection Regulation.

We base the processing of personal data on the following grounds:

The processing is necessary for entering into, performing or terminating an agreement with our customers and in order to provide you with our services.
The processing is necessary to comply with a legal or regulatory obligation to which we are subject.
The processing is based on our legitimate interests which, in specific cases, outweigh any potential disadvantage to your rights, provided that specific conditions are met. We are thinking, for example, of sending marketing communications to you as one of our existing or former customers. Due to the nature of the available data and the fact that you already use or have used similar services from us, we assess that any potential disadvantage to your rights is very minor, while we believe that the information provided may be of interest to you. Where we rely on this legal basis for processing, we will limit the effects this may have on your privacy by offering you the option to stop this processing immediately and simply.
The processing is based on your permission. This consent is o.m. derived from the voluntary and direct provision of your data to us by, for example, voluntarily adding it to your Blulinc account.

You can withdraw your consent at any time by contacting us.

E. What are the purposes for which we process your personal data?

We use your personal data for the purposes described below. We do not collect or process more or different types of data than those necessary for these purposes. If we wish to process your personal data for a purpose other than that for which the personal data were obtained, we will contact you before further processing of that data.

We collect your data for the following distinct purposes:

operational purposes: for example, the optimization of our App, to keep our services user-friendly, for answering your contact questions and requests.
business purposes: for example, to manage relationships with our customers and to offer or provide our services to you, to inform you about our policies and services, to transfer customer data to business partners in order to provide the services, to invoice our customers for the services provided, communication with our employees and business partners regarding the provision of our services to you as our customer or our cooperation with you as our business partner;

commercial purposes: for example, for sending marketing communications, newsletters, or to keep you informed about activities, offers, promotions, etc.or to verify your satisfaction as our customer;
legal or statutory purposes: for example, for legal reasons and proceedings, to comply with legislation and government orders, to meet our internal and external audit requirements, information security, or to protect or enforce our rights, privacy, safety, or property, or those of other persons.

F. How long do we retain your personal data?

We do not retain your personal data for longer than is necessary for the purpose for which the data were collected or are processed.

Since the period for which data may be retained depends on the purposes for which the data were collected, the storage period may vary in each situation. Sometimes, specific legislation will require us to retain the data for a certain period. Our retention periods for personal data are based on legal requirements and a balancing of your rights and expectations with what is useful and necessary for providing our services. When it is no longer necessary to process your personal data, we will delete or anonymize your personal data. If this is not (technically or practically) possible, for example because your data is stored in backup archives or because we have limited need for administration containing information about data subjects who do not wish us to contact them again in the future, we will retain your data but will not process it further and will delete it as soon as this becomes possible.

G. From whom do we receive your personal data?

We obtain personal data exclusively directly from you.

If we obtain your data from external parties, you should in principle already have been informed of the possible transfer of data to us by the source itself. In any event, when we obtain your data from external (public or private) sources and process this in our systems as the data controller, we will inform you about the processing of your data no later than the moment of our first contact with you.

H. How do we protect your personal data?

We attach great importance to data security and have taken the necessary physical and appropriate technical and organizational (precautionary) measures to protect your personal data against loss or any form of unlawful processing.

In the event of a personal data breach, we will comply with all applicable notification obligations regarding such breach.

I. Where do we store your personal data?

We primarily store your personal data on IT systems in Belgium. However, the management of some of our IT systems is outsourced to third parties, where the data is stored in the European Economic Area (EEA). When we engage IT service providers or other business partners located outside the EEA, which means that your data may also be stored outside the aforementioned countries, we will always comply with the requirements of the General Data Protection Regulation to ensure the adequate protection of your data in these third countries.

J. With whom do we share your personal data?

We will not pass on your personal data to third parties, unless we are required to do so by law, you consent to this, or when it is necessary in the context of the execution of the agreement, e.g. to the operator of the charging stations.

Where necessary, we engage external service providers, so-called “processors”, who, where applicable, carry out certain processing of personal data on our behalf. We will only share your personal data with these external service providers to the extent necessary for the relevant purpose. The data may not be used by them for other purposes. Furthermore, these service providers are contractually bound to ensure the confidentiality of your personal data by means of a so-called “processor agreement” concluded with these parties.

Specifically, this means that we share your data with the following processors, to the extent necessary as specified below:

payment service providers such as Apple Pay and STRIPE;
the processors who assist us in IT matters in carrying out our activities, with a view to efficient digital data management, including storing our files, sending transactional emails to customers, sending emails for the purpose of promoting our commercial activities, hosting and managing our App, mailboxes, providing us with insight into how you use our App through the services offered by Google Analytics, etc.;
public authorities or practitioners of regulated professions such as accountants and lawyers, with a view to compliance with our legal obligations as an enterprise, and the efficient defence of our interests in the context of any potential legal dispute, in respect of the data strictly necessary for this purpose;

The transfer of your data to the parties identified above for the stated purposes is based, as the case may be, on (1) the necessity thereof for the performance of the agreement we have with you as our customer, candidate or business partner, or to take measures at your request prior to the conclusion of such agreement, (2) our legitimate interests, (3) the necessity thereof to comply with a legal obligation to which we are subject, or (4) your consent.

III.Rechten of the person concerned

You have various rights regarding the personal data collected about you. If you wish to exercise any of the following rights, please contact us by email or by post using the contact details mentioned above.

You have the following rights:

Right of inspection and copy: If you wish, you can view your personal data and obtain a copy thereof;

Right of adjustment or rectification: If you believe that we have incorrect data about you, you can let us know and we will correct it for you; you can also adjust this yourself in the Customer Portal;

Right of data erasure (right to be forgotten): If you wish, you can ask us to delete your personal data.It is possible that we still need to process that data for other purposes;

Right to restriction of processing: If you believe that we are processing your personal data unlawfully or incorrectly, you can also have this processing restricted.

Right of objection: You can also object to the processing of your personal data. If it concerns marketing, we will stop the processing as soon as possible.

Right to portability: If you wish to transfer your personal data, please contact us.

However, the exercise of the above-mentioned rights is subject to certain exceptions to protect the public interest, our interests, and the interests of other individuals. When you submit a request to exercise your rights, we will first and foremost verify your identity by requesting a copy of your identity card. We do this to prevent your data from falling into the wrong hands.

The exercise of your rights is in principle free of charge. If your request is manifestly unfounded or excessive, we may charge you a reasonable fee in light of the administrative costs incurred by us. In that same case, however, we may also choose not to act upon your request. You will always be informed of the reasons for this. In any case, we will always inform you of the outcome of your request within a period of four weeks (for simple requests) or three months (for complex or multiple requests) at the latest.

IV.Klachtmogelijkheden of the person concerned

Despite all our efforts to protect your privacy and to comply with relevant Privacy legislation, you may disagree with the way in which we collect, use, and/or process your personal data.

Naturally, you can always contact us in that case, but you also have other complaint options available:

You can file a complaint with the supervisory authority, which you can contact using the details below:

By letter:	Data Protection Authority Drukpersstraat 35 1000 Brussels Belgium
Via email:	contact@apd-gba.be
By telephone:	+32 (0)2 274 48 00
Via fax:	+ 32 (0)2 274 48 35

You may also, should you suffer damage, file a claim for compensation with the competent court.

For more information regarding complaints and possibilities for redress, we invite you to consult the website of the Data Protection Authority: https://www.gegevensbeschermingsautoriteit.be/klacht-en-beroep.

Q. What about links to other websites and social media?

The App may contain references (e.g. via hyperlinks) to other websites offered by other companies or social media. Blulinc is not responsible for the processing of personal data via those external websites. Nor does this Privacy Statement apply to those websites.

If you share content via social media, your personal data will be visible to the visitors of those social media. Blulinc is not responsible for the processing of personal data via those social media. Nor does this Privacy Statement apply to those social media.

VI. Amendments

We may unilaterally decide to make changes to this Privacy Statement. In that case, the new version will take effect immediately. The most recent version is available on our App at all times. In the event of a substantial change to this Privacy Statement that is relevant to you, we will inform you directly about this – to the extent possible. The date on which this Privacy Statement was last modified can be found at the bottom.