The Data Controller is Charge4go AB, corp. ID no. 559239-8266 of the postal address Kungsgatan 9, 111 43 Stockholm, Sweden.
This policy applies to anyone who:
- Is a customer of Northe;
- uses any service provided by Northe (for example, our websites, apps and social media pages);
- is the recipient of Northe newsletters;
- is the recipient of direct marketing or whose data is otherwise processed for marketing purposes,
- in any other way is in contact with Northe.
Personal data means 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.
Northe provides services relating to charging electric vehicles. Our services are not intended for anyone under the age of 18. Registering an account if you are under the age of 18 constitutes a breach of Northe's Terms of Use. Because of this, Northe assumes that you are an adult (local laws have different thresholds for when an individual is considered an adult, but under all circumstances, we assume that you are over the age of 16).
If you are under the age of 16, we ask you not to submit any personal data to us. If you are under the age of 16 and wish to contact Northe, please do so through your parent or guardian.
The personal data Northe processes can be divided into the categories below:
- Personal information: Full name, date of birth, billing and delivery address, e-mail address, mobile phone number.
- Payment information: Payment card information, bank account number, bank name.
Northe uses Stripe (Stripe Payments Europe, Limited ) to process credit and debit card details If you submit credit and debit card details, Northe will not store the information, instead Stripe will store the information on Northe's behalf as a data processor.
- Charging session information: Time, location, cost of charging sessions, charge point ID.
- Device information: Location, device ID, cookies, network access, IP address.
- User information: Unique identifier connected to your user account (user ID), unique identifier connected to your Billing Account (Billing Account ID), unique identifier connected to your charging card (charging card ID).
- Vehicle information: Location, vehicle registration number, VIN number, car model, battery capacity and status.
Providing our services would not be possible without processing personal data. However, 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 as lawful basis when processing your personal data:
- The necessity of performing our contractual obligations or to take steps at the request of an individual prior to entering into a contract (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, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual (Article 6(1)(f) GDPR); or
- Complying with a legal obligation (Article 6(1)(c) GDPR).
To make it easier to understand how your personal data is processed in different situations, subsections 7.1-7.7 are divided between the type of interaction you have with Northe, while subsections 7.8-7.13 are not listed based on your interaction. Note that several subsections may apply concurrently. See section 9 for more information about how we share your data with third parties.
7.1 Visiting Northe's websites and using the Northe Mobile App
When you use the Northe Mobile app, your mobile device may share certain information with Northe, such as device ID, network access, storage information.
The legal basis for processing this information is Northe's legitimate interest of being able to provide and improve our service, and to protect and secure our systems (Article 6(1)(f) GDPR).
When you are visiting Northe's websites, Northe uses cookies. Please see subsection 7.11 below and our cookie declaration for more information about how we use cookies and the legal basis that applies for our processing of cookies.
When you use the Northe Mobile App, Northe will ask for your permission to collect location data. If you give your consent, the location data will be used to help you navigate and to receive notifications on your charging, as well as to receive updates on broken charging stations and other relevant information concerning charging station functionality. You may at any time rescind your consent.
The legal basis for processing this information is your consent (Article 6(1)(a) GDPR).
Depending on the model of your car, you may connect your vehicle with your user account through the Northe Mobile App. If you connect your car, Northe will process the following information about your vehicle: vin-number, vehicle registration number, battery information, location of your car, car model, battery size. The data is collected to enable additional features in the Northe mobile app, such as being able to view battery information, follow charging sessions in real-time, and navigate to your car. If you no longer wish Northe to process the aforementioned information you can remove your vehicle from your Northe user account.
The legal basis for processing this information is that it's necessary for Northe to perform a contract with you (Article 6(1)(b) GDPR).
If you have separately opted in to use our milage reimbursement product, Northe will also collect your location with time stamps to calculate time and distance travelled and share such data with a third party (e.g., your employer or another third party that pays for your charging sessions).
The legal basis for processing this information is that it's necessary for Northe to perform a contract with you (Article 6(1)(b) GDPR).
7.2 Registering an account
When you register a user account, Northe registers your personal information (name, address, email address, date of birth) and payment information (payment card information). Northe uses Stripe to process credit and debit card details. If you submit credit and debit card details, Stripe will store the information on Northe's behalf as a data processor. Northe will also create a user ID which connects you to the registered user account.
The legal basis for processing this information is that it's necessary for Northe to perform a contract with you (Article 6(1)(b) GDPR).
In case you have requested a third party to set up a Northe account on your behalf. For example, your employer, a car brand, a leasing company and/or a party which pays for some or all of your use of the service, that party may share all or some of the above information listed in the previous section with Northe.
The legal basis for our processing is to take steps at your request prior to entering into a contract (Article 6(1)(b) GDPR).
7.3 Ordering and connecting a charging card
When you order a charging card, Northe collects the address you submit. When you connect a charging card, a charging card ID is created and connected to your user account. If a third party has purchased and paid for a charging card on your behalf, that party has shared your address with us.
The legal basis for our processing of your address is to perform a contract with you (Article 6(1)(b) GDPR). In case a third party has purchased and ordered a charging card on your behalf the legal basis for our processing of your address Northe's legitimate interest of being able to provide our service (Article 6(1)(f) GDPR).
7.4 Charging
When you initiate or stop a charging session through a charging card or the Northe mobile app, Northe will share your user ID and/or charging card ID (if you initiate or stop using a charging card) with the owner of the charging station, which is required to identify you as an authorised user.
The legal basis for the processing is to perform a contract with you (Article 6(1)(b) GDPR).
During and after your charging, Northe will collect your charging session information, which is start time, stop time, location, electricity use, cost of charging sessions, charge point ID, device ID (if you initiate or stop the session through the Northe Mobile app), charging card ID (if you initiate or stop the charging session through a charging card). We will also receive charging session information from the owner of the charging station for billing purposes. The information is used to determine what Northe has to pay the charging operator and to identify and bill you for the charging session. Please note that subsection 7.5 applies If you are connected to a Billing Account and have selected the Billing Account as payment method.
The legal basis for collecting your charging session information is to perform a contract with you (Article 6(1)(b) GDPR). The legal basis for receiving your charging session information from an owner of the charging station is Northe's legitimate interest in verifying that we're being billed correctly and to be able to bill you for the purchase of electricity (Article 6(1)(f) GDPR).
7.5 Joining a Billing Account
If you are invited to a Billing Account, Northe will collect your email address to send an invitation to the Billing Account. If you accept the invitation to join the Billing Account, Northe will share the following information with the administrator of the Billing Account: Your full name and email address. In some circumstances, the administrator of the Billing Account may request that Northe adds one or more additional user IDs to identify your user account and the Billing Account.
When you perform a charging session with the Billing Account as selected payment method, Northe will share the following information with the administrator of the Billing Account: Your name, your user ID, as well as any additional user ID to identify your user account and the Billing Account, your charging session information.
The legal basis for sharing your charging session information is the legitimate interest of the party that pays for your charging session to receive such information in order to validate that charging sessions are being debited correctly by Northe (Article 6(1)(f) GDPR).
7.6 Connecting a charging box to your user account
When you connect a charging box to your user account, Northe collects the information you submit when registering the charging box, such as name of the charging box, charge point ID and location of the charging box. If you have opted to receive reimbursement for charging sessions performed at your charging box, Northe will also collect information provided by you regarding your electricity rates to compensate you for the electricity costs of charging at home.
The legal basis for processing your charging session information is to perform a contract with you (Article 6(1)(b) GDPR).
The party that pays for your charging (for example a leasing company or your employer) will be invoiced for your charging sessions performed at home, and Northe will share the following data to that party: your name, charge point ID, start and stop time, location of the charging box, electricity use, user ID, Billing Account ID, charging card ID (if your charging session was initiated or stopped by a charging card connected to your user account), and full name.
The legal basis for the processing is the legitimate interest of the party that pays for your charging session to receive such information in order to validate that charging sessions are being debited correctly by Northe (Article 6(1)(f) GDPR).
In order to receive refunds, you need to add your bank account information, Northe has contracted Brite (Brite AB) to collect your bank account details and share such information with Northe. To perform such reimbursement, Northe will share your bank account details, the amount that should be transferred to your bank account as reimbursement and contact information with the payment institution that performs the payment of funds.
The legal basis for the processing is to perform a contract with you (Article 6(1)(b) GDPR).
Brite may request further personal information from you (for example, to perform anti-money-laundering checks) Further information on how Brite processes personal data is available at: britepayments.com/privacy-policy
If you have opted to enable guest usage, which enables other users with a Northe user account to charge at your charging box, Northe will make the location and name of your charging box publicly available in the Northe mobile app, web app and/or websites. If you are the administrator of a Ailling Account, you may instead opt only to make your charging box available to other users of the Billing Account.
The legal basis for the processing is to perform a contract with you (Article 6(1)(b) GDPR).
7.7 Contact and customer service
When you contact Northe we will collect your name and email address, as well as any other personal information that you submit (for example, your user ID). The information you transfer to Northe when contacting customer support is saved as a ticket to evaluate the request. The ticket may be shared with a third party contractor that handles customer support enquiries on behalf of Northe in the capacity of data processor.
The legal basis for the processing is Northe's legitimate interest in being able to receive and respond to questions and complaints from our customers and other parties (Article 6(1)(f) GDPR).
7.8 Marketing
For the purpose of marketing Northe 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, under the privacy settings in your user account or by contacting us at hello@northe.app
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: user information (name, email address, phone number), charging session information (time, location, cost of charging sessions, charge point ID).
The legal basis for the processing is Northe's legitimate interest in being able to market our business and to evaluate and analyse the results of our marketing efforts (Article 6(1)(f) GDPR).
7.9 Anonymizing personal data
For the purposes of improving our service and to analyse customer behaviour, Northe may anonymise your personal data, while doing so we will process the following personal data: personal information, payment information, charging session information, device information, user information, and vehicle information.
The legal basis is Northe's legitimate interest in anonymising personal data to improve our service by analysing customer behaviour and to ensure that Northe processes personal data to the lesser extent possible by anonymising personal data when possible to reach the purpose (Article 6(1)(f) GDPR).
7.10 Optimising and ensuring the functionality of our service
For the purpose of optimising user experience, performing statistical analyses and improving our service in terms of its security and functionality, we process the following personal data: device information, user information, vehicle information, information about how you use the service provided by Northe (time, location, and duration of your usage).
The legal basis for processing your personal data for the above purpose is Northe's legitimate interest of analysing data in order to maintain, improve and develop our service purpose (Article 6(1)(f) GDPR).
7.11 Cookies
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).
The legal basis when processing personal data through the use of necessary cookies is Northe's legitimate interest in making our website usable and secure (Article 6(1)(f) GDPR.). The legal basis when processing personal data through the use of statistical cookies and/or marketing cookies is your consent (Article 6(1)(a) GDPR).
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.
Additional information about tracking services
Northe uses tracking services, such as Google Analytics to receive information about how our websites are being used, including how pages are viewed and time spent on our websites. Northe uses Google Analytics for the purpose of understanding how our websites are being used and what content is popular. The data on how our websites are being used is anonymised and cannot be tracked back to a specific user. Northe processes the following data: Online identifiers, including cookie identifiers, internet protocol addresses and device identifiers; client identifiers.
Northe uses Google Ads and Apple search to advertise on third-party websites and to measure the success of our marketing campaigns.
You can manage setting of Google cookies here.
Further information on how google processes personal data is available at: https://policies.google.com/privacy
Further information on how Apple processes personal data and your option when it comes to sharing personal data are available at https://www.apple.com/privacy/
Northe uses Meta Pixel to track information about user activity on our websites and to track the effectiveness of our ads.
You can manage settings of Meta cookies https://www.facebook.com/privacy/policies/cookies
Further information on how Meta processes personal data is available at https://www.facebook.com/privacy/policy
7.12 Further processing after your explicit consent
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. Your consent may be revoked at any time.
The legal basis for the processing is your consent (Article 6(1)(a) GDPR).
7.13 Complying with legal obligations and exercising legal rights
Northe might process any of the personal data described in this Section 7 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).
The legal basis for the processing when Northe is processing your personal data for the purpose of complying with laws and regulations is the necessity to comply with a legal obligation (Complying with a legal obligation (Article 6(1)(c) GDPR). The legal basis for processing when Northe is processing your personal data to protect the legal rights of Northe or any of our partners is Northe's legitimate interest of protecting the rights of Northe and our partners (Article 6(1)(f) GDPR).
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 anonymise your personal data.
Northe may share personal data with certain users of the service (the administrator of a Billing Account) and other third parties as described in this section. In certain cases, we may transfer your personal data outside the EU/EEA, typically when we use suppliers and subcontractors. Northe will only transfer personal data outside of the EU/EEA after having taken organizational, contractual and legal measure to ensure adequate level of protection, e.g., by including the European Commission's standard contractual clauses for data transfers between EU and non-EU countries.
9.1 Administrators of Billing Accounts
If you join a Billing Account, the Administrator of said account, (i.e., the party that pays for your charging sessions), will be able to view your contact information (e.g., name, e-mail). The Administrator will also have access to the information that is generated when you debit the Billing Account and when you perform a charging session that entitles you to reimbursement (see subsections 7.5 and 7.6) The purpose of disclosing such data is to ensure that the party that pays for charging session and/or reimbursement receives adequate information about what users have access to their account and the charging sessions that the Administrator pays for.
The legal basis for the processing is to perform a contract with you (Article 6(1)(b) GDPR) and the legitimate interest of the party that pays for your charging session to receive such information in order to validate that charging sessions are being debited correctly by Northe (Article 6(1)(f) GDPR).
9.2 Suppliers and subcontractors
Suppliers and subcontractors are companies that may only process the personal data we share with them on Northe's behalf (data processors). Northe will only share personal data with a supplier and/or subcontractor after we have ensured that they are contractually bound to be compliant with all applicable privacy laws. The purpose of sharing personal data with suppliers and/or subcontractors is to access services and functionalities that Northe cannot perform, ultimately for the purpose of providing Northe's services.
The legal basis for the processing is Northe's legitimate interest in being able to access the services and functionalities that the subcontractors provide in order to deliver and maintain our services (Article 6(1)(f) GDPR).
9.3 Payment service providers and financial institutions
Payment service providers and financial institutions that provide services to Northe by administrating payments through different payment methods and payouts (for refunds and reimbursements). The purpose of sharing personal information with payment service providers and financial institutions is to enable transactions (i.e. where you buy electricity or other services and/or products that Northe resells or to process a refund, or reimbursement for your charging expenses).
The legal basis for the processing is to perform a contract with you (Article 6(1)(b) GDPR).
9.4 Debt acquirers (for open debt) and debt collection companies (for overdue debts)
Northe may transfer your open debt to a debt acquirer (if you have opted to pay through invoice). Northe will inform you in writing that the debt has been transferred. Upon transfer of the debt and until the debt is paid off, Northe will share your personal information and charging session information. Additionally, Northe may share your personal information with a third party when we sell or outsource collection of unpaid and overdue debts. The purpose for sharing such personal data is to collect your unpaid and overdue debts.
The legal basis for the transfer is Northe's legitimate interest in selling outstanding debt as part of our business operations (Article 6(1)(f) GDPR).
9.5 Charge point operator
When you initiate and/or stop a charging session, Northe will personal information to the owner to verify that you are an authorised user (see subsection 7.4) .The purpose for sharing personal is to enable you to start and stop a charging session.
The legal basis for the processing is to perform a contract with you (Article 6(1)(b) GDPR).
9.6 Google
When you use the map function in the Northe mobile app or in your Northe web account; for example, by searching for a charging station or using the route planner to navigate to a charging station. Northe will share your personal information with Google. The purpose of sharing personal information with Google is to enable you to use our map and, route planner and navigation features.
The legal basis is Northe's legitimate interest in providing navigation features as part of our service (Article 6(1)(f) GDPR).
9.7 Analytic and research partners
Northe may transfer personal data to Google analytic partners and development and research partners (whenever possible, we will first anonymise the data, see subsection 7.9).
The legal basis is Northe's legitimate interest in being able to analyse and improve our Service based on user behaviour (Article 6(1)(f) GDPR).
9.8 Marketing and sales partners
Northe may transfer personal data to marketing and sales partner for the purpose of being able to perform marketing campaigns.
The legal basis is Northe's legitimate interest in being able to prepare and carry out marketing campaigns (Article 6(1)(f) GDPR).
9.9 Authorities
Northe may 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.
The legal basis is the necessity of complying with a legal obligation (Article 6(1)(c) GDPR).
9.10 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. Your consent may be revoked at any time.
The legal basis is your consent (Article 6(1)(a) GDPR).
As listed above, Northe will in certain cases process your personal data based on your consent. When this applies, you can withdraw your consent at any time by emailing us at hello@northe.app
In certain cases, you can also stop the processing directly in the Northe app (such as disabling the integration between your user account and your car) or withdraw your consent (such as receiving marketing material). Please note that by doing so, certain features in the Northe app may be disabled.
In order to exercise any right listed below, please send your request to hello@northe.app
11.1 Right to information and access to personal dataYou 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 hello@northe.app. Your request will be processed in no longer than thirty (30) days. The information will be provided to you free of charge.
11.2 Right to rectification and erasureYou 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,
-Your right as an individual override Northe's 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 data.
11.3 Right to portabilityYou have the right to request a transfer of your personal data that Northe processes for the performance or contract with you, or based on your consent, in a machine-readable format. Northe will respond to any request to transfer personal data within thirty (30) days.
11.4 Right to rescind consentIf you have given Northe your consent to process your personal data, you may at any time rescind your consent (see section 10).
11.5 Right to objectWhen the lawful basis for processing your personal data is the necessity of pursuing a legitimate interest of Northe (Article 6(1)(f) GDPR), you may object to data processing. 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.
11.6 Right to data restrictionIf you believe that your personal data is inaccurate, that Northe's processing is unlawful or that Northe does not need the personal data to fulfil a specific purpose, you have the right to request that we restrict the processing of such personal data. You also have the right to request that Northe stop processing your personal data while we assess your request. If you object to our processing (see subsection 11.5 above) you may also request that we restrict processing of that personal data while we make our assessment.
11.7 Right to lodge a complaintYou have the right to complain about how Northe is processing your personal data to the data protection authority in your country.
In Sweden, please contact the Swedish Data Protection Authority (Sw. Integritetsskyddsmyndigheten).
In Denmark, please contact the Danish Data Protection Agency (Da. Datatilsynet).
In Norway, please contact the Norwegian Data Protection Authority (No. Datatilsynet).
In Finland, please contact the Finnish Data Protection Authority (Fi. Tietosuojavaltuutettu.
Northe may change this policy by publishing a new version on our website and mobile application. When we change the privacy policy our customers will receive a notice that the Privacy Policy has been changed.
If you have any questions about this Privacy Policy, please contact us by email at hello@northe.app
Org no. 559239-8266
This Privacy Policy was last updated April 4, 2023.
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