The Data Controller is Charge4go AB, corp. ID no. 559239-8266 of the postal address Katarinavägen 15, 116 45 Stockholm, Sweden.
This policy applies to anyone who:
- Is a customer of Northe;
- Uses any service provided by Northe (e.g., Our web pages, apps and social media pages);
- Is the recipient of direct marketing or whose data is otherwise processed for marketing purposes; or
- In any other way is in contact with Northe.
3. What is personal Data and Processing of Personal Data
Personal data refers to any information that can be directly or indirectly used to identify a living human being. Processing of personal data refers to operations performed on personal data, including, but not limited to, collecting, storing, sharing or deleting personal data.
4. The Personal Data We Process
In accordance with the GDPR, We will only use your personal data for predetermined purposes and to the extent required to achieve those purposes.
Furthermore, we will only process your personal data when we have a lawful basis for doing so. Northe will always rely on one of the following categories of lawful basis when processing your personal data:
- The necessity of performing Our contractual obligations (article 6.1[b] GDPR);
- Your consent (if we rely on your consent as ground for lawful processing of personal data you may at any time rescind your consent) (article 6.1[a] GDPR);
- The legitimate interests of Northe or a third party (article 6.1[f] GDPR); or
- Complying with a legal obligation (article 6.1[c] GDPR).
4.1. Registering User Accounts and Providing Our Service
For the purpose of entering into, fulfilling and managing Our contractual obligations We process the following personal data:
- Social Security number;
- Contact information (name, email adress, postal address, phone number);
- Payment information (credit card information, invoice and payments history);
- Location (geo tagging);
- Time stamp; and
- Charging amount.
Our lawful basis for processing your personal data for the above purpose is to fulfill Our contractual obligations towards you.
For the purpose of enabling users of Our Service to invite other users to a Billing Account, Northe will process the personal data required to send an invitation (i.e., email adress of the user invited). Before sharing any information about another person (including email adress) with Northe you most ensure that you have obtained consent from that person to share such information.
Our lawful basis for processing your personal data for the above purpose is Our legitimate interest of providing the Service to users that wish to connect to a Billing Account.
4.2. Optimizing and Ensuring Functionality of Our Service
For the purpose of optimizing user experience, performing statistical analyses and improving Our Service in terms of its security and functionality, We process the following personal data:
- Device identification data (IP-address, device information data);
- Vehicle data (i.e., Vehicle registration plates); and
- Information about where and how you use the Service provided by Northe (time, location, and duration of your usage).
Our lawful basis for processing your personal data for the above purpose is Our legitimate interest of analyzing data in order to maintain, improve and develop our Service.
For the purpose of marketing us and Our Service, Northe may send you marketing material regarding the Service offered by Northe and third parties. Such marketing may be sent by email, through our mobile applications (including by the use of push notifications) or by mail. Northe may also process your personal data for the purpose of evaluating a marketing campaign.
If you no longer wish to receive marketing material by Northe you may at any time opt out, either directly in the marketing material or by contacting us at email@example.com
For the purpose of marketing Our Service and brand, as well as for the purpose of evaluating such marketing, we process the following personal data:
- Contact information (name, e-mail, address, phone number).
When Northe is processing existing customers’ personal data for the purpose of marketing, Our lawful basis for processing your personal data is Our legitimate interest in marketing our business.
When Northe is processing your personal data for the purpose of evaluating a marketing campaign, Our lawful basis for processing your personal data is Our legitimate interests to analyze the result of our marketing efforts.
If you are not a customer of Northe, We might send you marketing material through mail for the purpose of marketing Our Services to non-customers. In those cases, Northe will process personal data about you collected from third parties, e.g., the Swedish Transport Agency (Sw. Transportstyrelsen). Our lawful basis for the processing of your personal data is Our legitimate interest to market our Service and brand.
If you have separately given us your consent to the further use of your personal data, We may process your personal data to the extent described in the consent declaration, e.g., for marketing purposes and/or market research. In such cases We rely on your consent as lawful basis for the processing of personal data. Your consent may be revoked at any time.
Northe processes personal data through cookies. The purpose of processing personal data through cookies is to (i) enable basic functionality on Our website (“Necessary Cookies
”), (ii) help us understand how visitors interact with our website in order to maintain and improve Our Service (“Statistical Cookies
”), and (iii) to display ads that are relevant and engaging for the individual user (“Marketing Cookies
When processing Personal data through the use of Necessary Cookies We rely on Our legitimate interest to make our website usable and secure as lawful basis for the processing of Personal data. When We are processing personal data through the use of Statistical Cookies and/or Marketing Cookies, we rely on your consent as lawful basis.
If you choose to reject cookies (e.g., through the settings in your web browser) you may still use our websites, however this may affect the functionality and your ability to access parts of the website and Service.
Please see Our Cookie Declaration
for more information about what cookies we use and how you can rescind your consent.
4.5. Complying with Legal Obligations and Legal Rights
Northe might process any of the personal data described in section 4 for the purpose of complying with laws and regulations (when we are required to do so by law) or to protect the legal rights of Northe and its partners (defending, exercising, or establishing legal claims).
When Northe is processing your personal data for the purpose of complying with laws and regulations, We rely on complying with a legal obligation as lawful basis for the processing of personal data. When processing personal data to protect the legal rights of Northe or any of Our partners, we rely on our legitimate interest to protect the rights of Northe and our partners as lawful basis.
5. How Long We Store your Personal Data
We seek a minimum period of storing your personal data. Your personal data is only processed for as long as it's necessary to meet the purpose of the processing. Generally, we store your personal data for as long as the user and Northe have a contractual relationship and for an additional three (3) years after the end of the customer relationship. Information that We are required to store for a longer time due to legal requirements will be kept for ten (10) years after the end of the relationship. When your personal data is no longer required to meet the purpose of the processing Northe will delete or anonymize your personal data.
6. Sharing and Transfer of Personal Data
Northe does not sell your personal data to third parties, We may however share personal data with certain Users of the Service (i.e., the administrator of a Billing Account) and other third parties as described in this section.
Northe remains as data controller for the personal data being transferred while the third party may, depending on the circumstances, be a joint data controller (together with Northe) or a data processor (processing the personal data under Northe’s instructions). Northe will not transfer your personal data outside of the EU/EEA.
6.1. Administrators of Billing Accounts
If you join a Billing Account in the Service, the Administrator of said account will be able to view your contact information (e.g., name, e-mail). The Administrator will also have access to the invoices that are generated when you debit the Billing Account. The purpose of disclosing such data is being able to deliver and maintain our Service.
Such invoices include:
- Your contact information (e.g., name, e-mail, address, phone number).
- Information about your charging session (time, location, amount debited, invoice number).
Our lawful basis for disclosing the above listed personal data to the Administrator of a Billing Account is the legitimate interest of Northe to deliver the Services and protect the Administrator of the Billing Account from unauthorized use of said account, as well as the legitimate interest of the Administrator of the Billing Account to monitor charging sessions that are being debited to the payment method chosen by the Administrator of said Billing Account.
6.2. Other Third Parties
When transferring personal data for any other purpose than complying with laws and regulations (e.g., a court order) We will only share personal data with a third party after we have ensured that they are contractually bound to be compliant with all applicable privacy laws.
Service providers. Northe may transfer personal data to the following categories of third parties for the purpose of being able to offer you all the functions of the Service:
- payment providers;
- data hosting and cloud Service partners;
- debt and invoicing providers;
- roaming platform providers;
- location sharing partners; and
- charging point operators.
Our lawful basis for transferring personal data to third parties listed above is our legitimate interest of being able to deliver and maintain our Service.
Analytic and research partners. Northe may transfer personal data to the following categories of third parties for the purpose of being able to analyze and improve our Service:
- Google analytics partners;
- development and research companies.
Our lawful basis for transferring personal data to third parties listed above is our legitimate interest of being able to analyze and and improve our Service based on user behavior.
Marketing and sales partners. Northe may transfer personal data to the following category of third parties for the purpose of being able to perform marketing campaigns:
- marketing and sales partners.
Our lawful basis for transferring personal data to third parties listed above is our legitimate interest of being able to prepare and carry out a marketing campaign.
Authorities. Northe may also transfer personal data to law enforcement and other governmental agencies when we are required to do so by law. Our purpose for such transfers is to be compliant with laws and regulations and our legal basis is the necessity of complying with a legal obligation.
Additional transfers. If you have separately given us your consent to further process your personal data, e.g. for marketing purposes and/or marketing research we may, when applicable, share your personal data to third parties. Our lawful basis for transferring your personal data in such cases is your consent. Your consent may be revoked at any time.
7. Your Rights
In order to exercise any right listed below, please send your request to firstname.lastname@example.org
7.1. Information and Access to Personal Data
You have the right to receive confirmation about whether or not Northe is processing your personal data. You furthermore have the right to be informed about how your personal data is being processed, for what purpose your personal data is being processed, on what lawful basis your personal data is being processed and about any recipients of your personal data.
If you want to access information regarding your personal data, please contact us at email@example.com
Your request will be processed in no longer than thirty (30) days. The information will be provided to you free of charge.
7.2. Rectification and Erasure
You have the right to obtain without any undue delay the rectification of any inaccurate personal data concerning yourself being processed by Northe.
Northe will always erase personal data if the processing is not in accordance with applicable law. Additionally, you have the right to request that we erase your personal data under the following circumstances:
- Your personal data is no longer needed for the purpose(s) We process it for;
- The personal data is processed for direct marketing purposes (not Service-related information);
- You have rescinded your consent and that is the only lawful reason for processing your personal data; or
- Your right as an individual override Our legitimate interest to continue the processing of your personal data (when We rely on legitimate interest as the lawful basis for the processing of such data).
Please note that regardless of the above circumstances We will not be able to erase your personal data when We have a legal obligation to process the personal data.
You have the right to request a transfer of your personal data under certain circumstances. Northe will respond to any request of transferring personal data within thirty (30) days.
7.4. Rescind Consent
If you have given Northe your consent to process your personal data, you may at any time rescind your consent.
7.5. Right to Object
When the lawful basis for processing your personal data is the necessity of pursuing a legitimate interest of Northe you may object to the processing of data. Unless Northe can demonstrate a compelling legitimate interest to continue the processing Northe shall stop the processing of personal data that pertains to said lawful basis.
You may at any time object to the processing of personal data for marketing purposes at which point Northe will stop processing personal data for said purpose.
7.6. Right to Data Restriction
Under certain circumstances you have the right to request that processing of your personal data is restricted to storing your personal data.
8. Lodging a Complaint
You have the right to complain about how Northe is processing your personal data to the data protection authority in your country.
10. Contact Details
Org no. 559239-8266