We are committed to providing our customers with truly excellent customer service. We recognise that customers value their data and privacy, and so we treat our customer data with great care. This policy sets out how and when we collect, use and share your personal information that you, or others, provide to us.
1 Who are we?
We are Octopus Electric Vehicles Limited, with registered company number 10754317 and registered address at 33 Holborn London EC1 2HT. We trade from UK House, 2nd floor, 164-182 Oxford Street, London W1D 1NN so are best contacted at that address.
We have appointed a data protection officer, Lynne Higgins, who is responsible for overseeing questions in relation to this privacy notice. If you’d like to speak to anyone about your data please contact firstname.lastname@example.org or call us on 020 3870 389.
2 How do we collect and use your data?
When you purchase products or services from our website
When you purchase products or services from our website, we will use your personal information to complete your purchase. The details we collect from you may include your name, address, date of birth, email address, phone number and payment details.
When you make enquiries to lease a car
When you make enquiries or lease a car via Octopus Electric Vehicles, we will use your personal information to provide you with quotations and to arrange or offer vehicle leasing and finance. This information includes your name, address, date of birth, email address, phone number and your preferences.
If applicable, we will also collect vulnerability data when you sign up, such as your age, any disabilities or health conditions or any financial circumstances of you or a member of your household. With your consent we may record this information to enable us to provide extra support to you.
It’s important that you keep your personal information up to date, so please let us know if anything changes.
Depending on the product which you have selected we may then share your details with partners and funders in order to provide you with a quotation and to arrange vehicle leasing and finance - please see section 3 below for more details.
In order to arrange vehicle rental, leasing and finance and insurance
Where we are arranging vehicle finance and insurance on your behalf, we may need to gather additional information including nationality, country of birth, date of birth, UK residency, National Insurance number, driving license details (number, expiry, location, current or pending endorsements and scanned copy), and DVLA check code (although this is only temporarily and expires after use).
We gather this data in order to arrange vehicle finance, to comply with the law and to ensure that your vehicle will be affordable.
Where we have certain legal and regulatory obligations
Where we are obliged to do so by law, we will use your information to check that nominated drivers are qualified to drive, check driving history, carry out creditworthiness and affordability assessments and to conduct searches for money laundering and anti-terrorist financing purposes.
When you phone, email or contact us on social media
When you phone or email us with general queries, we may process your personal information(your name, address, contact details, details of your car lease and finance arrangements and other personal information you’ve given us)in order to provide the customer services you have asked us to.
We rely on your consent to handle your personal information in this way. If you do not provide us with the data we request from you for customer services purposes, we may not be able to fully answer your queries.
We log and record the interactions you have with us, such as phone calls, email opens and click throughs to help us better service your requests.
This section applies if you have opted in to receive marketing communications from us or have previously expressed an interest in our products and services and have not opted out. We will process your personal information (your name, address, contact details and other personal information you’ve given us) to provide you with marketing communications in line with any preferences you have told us about.
Where you have opted to receive marketing communications, we rely on your consent to contact you for marketing purposes. If you have not opted in and we send you marketing emails, we do this because of our legitimate interest to promote the success of the products and services you have expressed an interest in.
Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them, or you can contact us anytime at email@example.com.
We may also use the basis of legitimate interest to share information about our products and services via post, phone, targeted or generic adverts on our website or services from other Octopus Group companies.
We never share your information with any third parties for their direct marketing purposes.
Third party platforms
We may sometimes provide personalised advertising via third party platforms. For example, we’ll hash your data (so no one can view it) and reference it against Facebook’s platform. If you have a profile with Facebook, we’ll ask them to exclude you from irrelevant adverts, such as “join Octopus Energy” adverts, and send you more relevant adverts instead. All of this is done without Facebook revealing your identity to us and vice-versa. We do this on the basis of legitimate interest to ensure that you receive more tailored and relevant information about our products and services.
If you are part of an industry scheme
If you apply for or enquire about our Powerloop Vehicle to Grid (V2G) offering, we will collect information relevant to the provision of this scheme. Powerloop is an Innovate UK funded project and we are delivering it to customers in collaboration with six other consortium partners (UK Power Networks, Guidehouse, Chargepoint Services, Energy Savings Trust, Octopus Energy, and Open Energi).
We will be gathering data from the V2G charger and a telematics device (also known as a Black Box) which will be installed in your car in order to collect usage data on a number of metrics, including how you charge and use your vehicle. We will need to report the aggregate data from the project to Innovate UK, as well as to the Department for Business, Energy and Industrial Strategy (BEIS). We do this because all Innovate UK V2G projects are being used to inform BEIS. We will not pass on any personal data and data collection will be fully anonymised and will not be used for any decision purposes on an individual basis.
Where we gather telematics data from your car
If you are a Powerloop customer, or if you are hiring a car via your workplace Salary Sacrifice scheme, your vehicle will come with a telematics device. This will be installed in your car in order to collect data. This will help manage your mileage throughout the term of your contract and will allow us to find your vehicle if it is stolen.
To make our website better and more secure
We will use your personal information to provide you with a more effective user experience, such as by displaying services we think you will be interested in. Using your information in this way means that your experience of our website will be more tailored to you, and the content you see on our website may differ from someone else.
We also share your aggregated, anonymous data with third party analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will also use your personal information for the purposes of administering our website and making it more secure, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our website is kept secure.
You can prevent us from using your personal information in this way by using the “do not track” functionality in your internet browser. If you enable “do not track” functionality, our website may be less tailored to your needs and preferences.
Technical information and analytics
When you visit our website, we will automatically collect the following information:
technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We also work closely with various third parties, including advertising networks, analytics providers, hosting providers and search information providers from whom we may also receive general aggregated anonymous information about you.
Information we receive from third parties
As well as the information you provide us with directly, we also receive information from some third parties.
We work with various affiliates and partners, such as price comparison websites, telesales agencies and door-to-door sales agencies, and if you sign up to our services through one of our affiliates or partners, they may send us your personal information.
If you come to us through one of our referral schemes, then we will receive your initial details through this link, and we will also tell the person whose link you used that you have done so.
3 Sharing your information
Our group companies, where necessary for the provision of our services.
Our engineers and other subcontractors we use to help us with installations and to attend emergencies.
Anyone who is named and authorised on your account.
Our affiliates and partners, including brokers, introducers, funders and insurance companies to the extent necessary to enable us to deliver our services to you.
Payment providers, to help us process your payments to us.
Credit reference agencies, fraud prevention agencies, anti-money laundering and terrorist financing tools, both when you first sign up and routinely whilst you have an account with us to help us assess your ability to make payments you owe us.
Debt collectors and vehicle recovery agencies where we have a legitimate interest to recover sums or vehicles owned by us.
Our telesales and field sales partners, but only where necessary to perform our services.
We may also share your information for the following reasons.
If our business is sold
We will transfer your personal information to a third party as follows:
if we sell or buy any business or assets, we will provide your personal information to the seller or buyer (but only to the extent we need to, and always in accordance with data protection legislation); and
if Octopus Electric Vehicles Limited, or the majority of its assets, are acquired by somebody else, in which case the personal information held by Octopus Electric Vehicles Limited will be transferred to the buyer.
We process your personal information in this way because we have a legitimate interest to ensure our business can be continued by the buyer.
Where we have a legal or regulatory obligation
In some circumstances we may need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation; for example, to investigate something like theft or fraud.
In difficult circumstances
We speak to thousands of customers a day, and some of those people will be in difficult circumstances. Occasionally people will share information which indicates that they, or a member of their household, are in imminent danger or at serious risk, and in line with guidance from the Information Commissioner, in such circumstances we may refer the situation to relevant authorities or sources of assistance. In such cases we will consider first and foremost the interests of the person at risk.
What is a cookie?
A cookie is a small file of letters and numbers that we store on your device. Cookies are an essential and widely used tool, and they enable our website to function properly and efficiently, as well as providing us with helpful information about how people use our website.
Types of cookie we use
Used for security and anti-fraud reasons
Used for system effectiveness measurement
Used on multilingual websites to save user
Used for stability/effectiveness measurement
Used to identify logged in site members
Used for system monitoring/debugging
Used to indicate the system from which the site was rendered Used in connection with user login
Used in connection with user login
Used for system monitoring/debugging
_wixCIDX and _wix_browser_sess
Security of the website
XSRF-TOKEN and hs
Enables personalised user support and communication
intercom-id-* and intercom-session-*
Security cookie to protect against cross-site request forgery
User experience analytics for improvement and optimisation
_hjIncludedInSample and _hjid
Google Analytics & Advertising
Analytics for improvement, optimisation and advertising performance
_ga and _gat_UA-67011385-1 and _gcl_au and _gid and IDE and NID
Facebook Pixel to improve ad relevance & performance
_fbp and fr
Amazon Web Services
Aids the distribution of sessions across AWS instances & handles cross-origin
AWSALB and AWSALBCORS
Turning cookies off
You can block cookies by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of our website, some website features may not work as intended, and your personal data will be less secure.
Remove cookies from your hard drive;
Set your browser to block cookies; and
Set your browser to send you a warning notice before a cookie is stored on your computer.
For more information on cookies, this website may help www.allaboutcookies.org. This website is not owned or run by Octopus, but we think it’s helpful.
You might not be able to make the most out of our website without cookies, as some functions need cookies to work. Should you change your mind, simply turn cookies back on and she'll be apples.
5 Where is my data stored?
We are based within the UK, however some of the third parties we work with may be based outside of the European Economic Area (EEA), so their processing of your personal information may involve a transfer of data outside of the EEA.
Whenever we transfer your personal information outside of the EEA, we will always ensure it is protected by making sure we have safeguards in place. This might mean only transferring your personal information to a country that has been deemed by the European Commission to provide an adequate level of protection, or by using specific contractual protections. You can contact us at firstname.lastname@example.org for details of how we protect specific transfers of your data.
All information that you provide us with is stored on our secure servers, or those of our third parties’ data storage providers.
6 How long do we retain your data for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or administrative requirements.
To determine the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information, the applicable legal requirements and whether we can achieve those purposes through other means.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical analysis, such as looking at email open rates, or to improve our website and develop new products. In these cases, we may use this information indefinitely without further notice.
7 What are my rights under data protection laws?
You have various rights under the data protection laws, which you can exercise by contacting us. The easiest way to do this is by email to email@example.com.
Right to object
You have the right to object to us handling your personal information where we are handling your personal information based on our legitimate interests. If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why we should continue to use your personal information.
You can also ask us to stop handling your personal information for marketing purposes at any time.
Right of access
You have the right to access your personal information which we are handling, and you are entitled to receive confirmation and details about whether your personal information is being processed by us.
Right to rectification
You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to ask us to complete personal information which you think is incomplete.
Right to restriction
You can restrict our processing of your personal information where:
you think we hold inaccurate personal information about you;
our handling of your personal information breaks the law, but you do not want us to delete it;
we no longer need to process your personal information, but you want us to keep it for legal reasons; or
where we are handling your personal information because we have a legitimate interest (as described in the “How We Use Your Data” section above) and are in the process of objecting to this use of your personal information.
Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle any legal claims.
Right to data portability
This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.
You have the right to receive your personal information in a structured, standard machine-readable format, and the right to ask us to send your information to another organisation or to give it to you.
Right to erasure
You have the right to require us to erase your personal information in the following circumstances:
where we no longer need to use your personal information for the reasons we told you we collected it for;
where we needed your consent to use your personal information, you have withdrawn your consent and there is no other lawful way we can continue to use your personal information;
where you object to our use of your personal information and we have no compelling reason to carry on handling it;
if our handling of your personal information has broken the law; and
where we must erase your personal information to comply with a law we are subject to.
Right to complain
You have the right to lodge a complaint with the Information Commissioner's Office, the supervisory authority for data protection issues in the United Kingdom.
8 What about websites we link to?
Our website may contain links to third party websites. If you click on a link to any of these websites, you will leave our website and this may allow third parties to collect or share your data.
We have no control over the contents of those third party websites and so will not accept any responsibility or liability for any materials on there. We encourage you to check their privacy policies before you submit any personal information to these websites.
9 Updates and contact
We would always rather you speak to us first if you have any questions about our handling of your personal data, so we can resolve any problems as quickly as possible. However, if you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the Information Commissioner’s Office, the UK’s independent authority on data privacy at www.ico.org.uk.