Easee privacy notice

Welcome to the Privacy Notice of Easee ASA. We are a Norwegian company that develops, manufactures, and supplies hardware for charging Electric Vehicles (EV) and smart power management purposes as well as software, cloud services, Application Programming Interfaces (APIs) and other digital services related to these.

These notice below explains what personal data we collect about you, how we process personal data and the data protection rights and choices you have as per the transparency requirement of the EU General Data Protection Regulation (GDPR) and other Applicable Data Protection laws, including the UK GDPR and applies to our collection and processing of personal data in relation to our Website and business, including the Easee Cloud Services.

1. Who is responsible for your personal data

Easee ASA, located at Vassbotnen 23, 4033 Stavanger, Norway is the “data controller” when we collect and process your personal data according to these notice. As a data controller, Easee determines the purpose and means for the processing of personal data and will also make sure the collection and processing of your prosomal data is done in a legal and secure way.

Easee is made up of several different entities (group companies) internationally. Within the Easee group of companies, the data controller will be either Easee ASA and/or the Easee company(ies) you have relationship with.

Easee will process your personal data in accordance with the at all times applicable data protection laws (including the GDPR and UK GDPR). We decided to make these notice easy for you to read and understand. If you have any questions related to these privacy notice or Easee’s processing of your personal data, or you wish to exercise your data subject rights according to section 9 of these notice, please contact us using the following contact detail:

Easee ASA
Vassbotnen 23,
4033 Stavanger, Norway
Company registration number: 920 292 046
gdpr@easee.com

Easee processes personal data about: users of Easee Charging Robots and Smart power management devices called Easee Equalizer; business partners (sale, Integration or Installation partners); suppliers and other collaborating partners; newsletter subscribers; website visitors; users of our Digital Services (i.e. software, cloud portal and APIs) and others who contact Easee, e.g., by using the contact form on Easee’s website. If you apply for a vacant position in Easee, we will process your personal data as part of considering your job application.

Easee collects your personal data when you:

  • Start using one of our Internet-connected hardware products,
  • enter into contracts or agreements with us
  • register a user profile in our app or website
  • interact with our website or social media platforms,
  • start using the Easee or Installer app, Easee Portal or any of our digital services,
  • contact us via telephone, email, or the contact form on our website
  • give us your personal data directly or we get it from your employer or client, in connection with our collaboration with Installers, business customers or other partners.
  • apply for a vacant position at Easee
  • participate in our competitions, events or promotional prize draws
  • participate and respond to one of our surveys

3. Type of personal data we collect

By the term “personal data”, we mean any information that relates to an identified or identifiable living individual. The personal data we collect depends on the context of your interaction with us, and your interaction with us can be as; a user of products and services, a business customer, a vendor, a potential job candidate, or an individual simply reaching out for information.

The personal data that you provide to us, or we collect automatically may include:

  • Account and Identity data: Account ID (email address, and/or phone number), serial number, user credential, first and last name, RFID tags, country, or connected devices.
  • Contact Information: such as name, email address, phone number, postal address (invoicing or delivery), employer or organization details, and other contact information.
  • Usage data: such as information about how you use our websites, products or services, including aggregated usage patterns.
  • Charger Setting and Site Data: such as device serial number, product model, installation details, site address info, circuit and fuse details, configuration settings, network type and information, load balancing setting, site address and type, or Operator name.
  • Charger Activity Data: such as Energy consumption, Charging session information, Temperature readings, Charger status updates, Connection status (online/offline), Firmware version and update history, Error logs or fault reports, User authentication events, Changes in charger settings or configurations.
  • Recruitment data: such as CV, application, references, interview notes, background checks and other information.
  • Payment data: such as bank account details, transaction data, credit card or other bank card number.
  • Communications data: Your communications or inquires with us, including interactions with customer support, sales team or our social media channels.
  • Technical Data: data about the interaction of your browsers, apps and devices with our services and websites, including IP addresses, browser type and version, time zone and location, browser plug-in types and versions,
  • Behavioral and Preference Data: includes your preferences when receiving marketing or product update from us and your communication preferences.
  • Company Data: such as the name, and location of the company you work for, and your role within the company, address and contact detail of the company.

4. Purpose and legal basis for processing personal data

Easee processes your personal data for different reasons, depending on the nature of your interaction with us. Easee will always make sure that its processing of personal data is fair, lawful, with specific and explicit purposes identified.

The list below provides an overview of the different categories of personal data (see section 3 above for detail lists of personal data included under each category), their respective purposes and legal basis for Easee’s processing of your personal data:

Purpose: To provide access to Easee Charging Robots (including without an Easee account); to remotely troubleshoot and fix technical issues; perform firmware and maintenance update

  • Category of Personal Data:
    • Charger Setting and Site Data
    • Charger Activity Data
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary for our legitimate Interests; to remotely monitor and maintain the safety, stability and security of our products (Art 6(1) f of the GDPR)

Purpose: To create an Easee cloud user or integration account for you or to register your business as a partner or supplier to us

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary to comply with our legal obligation (art 6(1) c of the GDPR)

Purpose: To provide access to digital services (e.g., Easee Apps, Portal, Control or Fix services)

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Usage Data
    • Charger Setting and Site Data
    • Charger Activity Data
    • Technical Data
      Note: the personal data we require from you when you register a user profile is the minimum necessary to be able to provide our products and services to you (meaning to authenticate your identity and prevent abuse of our services).
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary for our legitimate Interests; to remotely monitor and maintain the safety, stability and security of our products (Art 6(1) f of the GDPR)

Purpose: To conduct due diligence on you or your company as a business partner, supplier or service provider to us

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Company data
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary for our legitimate Interests in safeguarding our business interest in ensuring the legality or validity of companies that works with us (Art 6(1) f of the GDPR)
    3. Necessary to comply with our legal obligation related to supplier checks including the Norwegian Transparency Act (Art 6(1) c of the GDPR)

Purpose: To manage our relationship and communication with you (e.g. when you request customer support, use our contact forms or contact us in other ways)

  • Category of Personal Data:
    • Identity data
    • Contact Information
    • Communication Data
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary to comply with our legal obligation, such as consumer protection (art 6(1) c of the GDPR)

Purpose: To process and mange Purchase Orders; to fulfil contractual and agreed terms for you or your company; to process Return Merchandise Authorization (RMA) requests.

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Payment data
    • Company data
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary for our legitimate Interest (Art 6(1) f of the GDPR)
    3. Necessary to comply with our legal obligation, such as accounting or bookkeeping laws (art 6(1) c of the GDPR)

Purpose: To improve products and digital services

  • Category of Personal Data:
    • Technical data
    • Usage Data
    • Charger Activity Data
  • Legal Basis:
    1. Necessary for our legitimate interests to continually fulfil customer expectations, grow our business by inventing and developing new products and services (Art 6(1) f of the GDPR)

Purpose: For marketing communication (including newsletter subscriptions) and social media purposes

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Behavioral and Preference Data
    • Communication Data
    • Technical Data
  • Legal Basis:
    1. Based on your consent (Art 6(1) a of the GDPR)
    2. Necessary for our legitimate Interest to expand our business and in marketing our products and services to our existing customers (Art 6(1) f of the GDPR)

Purpose: To provide you remote customer support services. Note that Easee provides only remote customer support for end users and processing of some personal data is necessary to provide the support.

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Charger Setting and Site Data
    • Charger Activity Data
    • Usage Data
    • Communication Data
    • Payment Data
  • Legal Basis:
    1. Performance of our contract with you (Art 6(1) b of the GDPR)
    2. Necessary for our legitimate Interest in providing you the best possible remote customer support services (Art 6(1) f of the GDPR)

Purpose: To pseudonymize and aggregate data, so that we use them for statistical, research and analytical purposes.

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Charger Setting and Site Data
    • Charger Activity Data
    • Usage Data
    • Technical Data
  • Legal Basis:
    1. Necessary for our (third parties) legitimate interests to continually improve our business and make informed business decisions (Art 6(1) f of the GDPR)

Purpose: To improve our website, marketing efforts, and to enhance the user experience

  • Category of Personal Data:
    • Technical data
    • Usage Data
  • Legal Basis:
    1. Based on your consent; for functional, statistical or Ad related cookies (Art 6(1) a of the GDPR)
    2. Necessary for our legitimate Interest in improving network security, preventing fraud and developing our services and user experiences (Art 6(1) f of the GDPR)

Purpose: To establish, exercise, or defend legal claims

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Charger Setting and Site Data
    • Charger Activity Data
    • Usage Data
    • Payment Data
    • Company data
    • Technical data
  • Legal Basis:
    1. Necessary for our or third parties’ legitimate interests to enforce our (their) rights or the rights of third parties (Art 6(1) f of the GDPR)
    2. Necessary to comply with a legal obligation, e.g. to comply with requests or orders from courts as necessary (Art 6(1) c of the GDPR)

Purpose: To comply with the relevant laws and regulations that apply to us (such as Accounting and Tax laws; EU Measuring Instruments Directive; security and Data Protection Laws and others)

  • Category of Personal Data:
    • Account and Identity data
    • Contact Information
    • Charger Setting and Site Data
    • Charger Activity Data
    • Payment Data
    • Company data
  • Legal Basis:
    1. Necessary to comply with our legal obligation (Art 6(1) c of the GDPR)

Purpose: For recruitment purposes (to evaluate your qualifications and suitability for a job and be able to communicate with you during the recruitment process)

  • Category of Personal Data:
    • Contact Information
    • Recruitment Data
    • Communication Data
  • Legal Basis:
    1. Necessary for our legitimate interests in assessing your qualification, or communicating with you (Art 6(1) f of the GDPR)

Purpose: To manage event or program registration, surveys, promotional related Competitions

  • Category of Personal Data:
    • Contact Information
    • Identity data
    • Communication Data
  • Legal Basis:
    1. Based on your consent (Art 6(1) a of the GDPR)
    2. Necessary for our (third parties) legitimate interests in organizing events or Promotional Competitions (Art 6(1) f of the GDPR)

PLEASE NOTE THAT YOU ARE NOT OBLIGED TO PROVIDE PERSONAL DATA TO EASEE. HOWEVER, AS MANUFACTURERS OF SMART IOT DEVICES, EASEE WILL COLLECT AND PROCESS SOME PERSONAL DATA (CHARGER SETTING AND SITE DATA, CHARGER ACTIVITY DATA; BOTH OF WHICH QUALIFIES AS PSEUDONYMIZED DATA UNDER THE APPLICABLE DATA PROTECTION LAWS) FROM ITS PRODUCT AND SERVICE USERS TO REMOTELY MONITOR AND MAINTAIN THE SAFETY, STABILITY AND SECURITY OF OUR PRODUCTS. EASEE PRODUCTS ARE DESIGNED TO BE SMART (WITH BUILT-IN CONNECTIVITY FEATURES) AND BE ABLE TO CONNECT TO THE INTERNET. IF YOU PREFER OFFLINE CHARGERS, WE ADVISE YOU TO STOP USING EASEE PRODUCTS AND SERVICES.

5. Data security, retention, and transfer of your personal data

Data security

Easee values your privacy rights and has taken reasonable steps to protect the users’ privacy, including by implementation of physical, technical and organizational measures, to prevent loss, alterations, theft and unauthorized access to information stored and otherwise processed.

We have also established comprehensive protocols for data protection and breach management. In the event of a security incident resulting in unauthorized access, loss, or alteration of personal data that presents a moderate to significant risk to affected individuals, we will inform the Norwegian Data Protection Authority (Datatilsynet) or other applicable regulatory bodies within a 72-hours.

Data retention

How long we store your personal data is determined by several factors. As a main rule, Easee will delete most of your personal data four years after you stop using our products and services or four years after the termination of our contract with you. We will also delete most of the personal data we have about you upon your request.

Please note that continued storage of personal data may be necessary due to statutory obligations to which Easee is subject, e.g., storage for accounting purposes, or due to Easee’s legitimate interests, e.g., for the purpose to establish, exercise or defend a legal claim. In those, circumstances, Easee will make sure only limited and necessary personal data will be processed. Charger Activity Data are permanently stored, but these are not associated with any personal data once the relevant user account or Charger Setting and Site Data is deleted.

Easee may keep Anonymized information for unlimited period. These approach allows us to retain useful information while protecting your privacy by removing all personally identifiable elements.

Transfer of personal data

When you use our products and services, your personal data may be subject to processing or storage outside the EU/EEA, including in the United States. In such cases, Easee will ensure that the personal data is subject to appropriate safeguards, including using only companies self-certified under the EU-U.S Data Privacy Framework or entering EU Standard Contractual Clauses with the recipients of the data. Please contact us if you require further information.

6. For whom we disclose your information

Easee will only disclose personal data to third parties to the extent Easee has legal basis for such disclosure. Where relevant, we will disclose your personal data for the following recipients:

GROUP COMPANIES: To the extent necessary to fulfil any of the purposes stated in Section 4 above, your data is shared with other companies and subsidiaries within the Easee Group. Currently, all Easee Group Companies and Subsidiaries are located within the EU/EEA and UK.

SERVICE PROVIDERS: Easee uses third parties (data processors) to collect, store or otherwise process personal data on our behalf, including for cloud hosting services. Such third parties also include our social media providers, as clarified in section 8 below. The relationship to such suppliers is governed by a data processor agreement, which among other things ensures confidentiality and information security for your personal data.

PUBLIC AUTHORITIES: Easee may disclose personal data to public authorities in order to comply with statutory requirements or orders from the authorities, e.g., to comply with obligations under the applicable accounting or tax legislation. The relevant government agency will be data controller for the personal data disclosed in such instances.

PARTNERS AND OTHERS: we may also disclose your personal data to affiliates of Easee, business partners (see Section 7 below) or other collaborators for business proposes. If necessary and lawful, we may disclose your personal data to our advisers or other relevant third parties in certain circumstances, such as in connection with disputes.

7. Owners and administrators of professional charging sites

When you use a Professional Charging Site (operated and managed by Third Party Charging Point Operators), your Charger Activity Data, Charger setting and Site Data will be processed by the owner or administrator of the professional charging site, that has an API integration account with Easee. As described in Section 3 and 4 above, the mentioned personal data categories contain personal data that may identify you as user of Easee Products and Services.

The relevant administrators of the professional charging facilities (Operators) are an independent data controller on how they process such personal data. Please contact the charging facilities for further information on their processing of your personal data.

8. Links to third party websites, services and social media platforms

Easee’s website and app may contain links to other website or external services. These websites and services have their own privacy notices that describe how personal data is collected and processed. If you submit your personal data to such third-party websites, the processing of personal data is subject to the relevant website’s privacy notice. Easee is not responsible for such third-party websites or their processing of personal data. We recommend that you read the privacy notice and any terms of use on such websites when you visit and use the website. An example of such a service may be Upvoty, which is used to gather feedback and ideas for our products and services.

Easee operate pages and other online presences (profiles or channels, etc.) on social networks and other platforms that are operated by third parties. If you “like”, join or become a member of such pages or profiles on other social media platforms, these information will be shared with the relevant platform. The same applies to content you post and posts you like on such social media platforms. Easee and the relevant platform are responsible for the personal data it collects and processes from such social media platforms. Easee accesses data posted on Easee’s profiles on social media platforms for the purpose of understanding feedback and reactions to Easee’s products and services, but does never download, store or compile such data. Easee uses Google Analytics for marketing purposes. Further information about how the social media platforms process personal data can be found in the relevant platform’s privacy notice.

9. Your data protection rights

As Easee is established in the European Economic Area (EEA), our processing of information about you is subject to the GDPR (and UK GDPR) regardless of where you reside or where the data is stored and processed. Under the applicable data protection laws, you have the following rights in relation to our collection and use of your personal data:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights;

In order to exercise your rights, you may contact Easee by using the contact information stipulated in section 1 above.

Complaints: You are also entitled to lodge a complaint with the relevant supervisory authority if you believe that Easee’s processing of your personal data is contrary to applicable data protection laws.

In EEA, our Lead Supervisory Authority is the Norwegian Data Protection Authority (Datatilsynet) and can reach out to Datatilsynet. If you are located in the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here. You can reach the UK supervisory authority here and the Swiss supervisory authority here.

10. Automated decision making

We do not use any personal data collected from you for any automated decision-making process (including profiling).

11. Changes to the privacy notice

The Easee privacy notice is available at the bottom of Easee’s website and will be displayed to you when you register for any Easee products and services. If Easee makes changes on how your personal data is processed, these notice will be updated, and you will be notified via the website or email.

We will obtain your consent before initiating any major changes in the processing of personal data that require your consent.

12. Cookies, Google Tag Manager and Analytics

Easee uses cookies and other information gathering methods for improving our website and easee cloud portal and analytics purposes. Easee strives to limit third-country transfers and don’t use marketing cookies. You can find more information regarding cookies under the browser’s help function or the Cookies settings section of our website.

Google Tag Manager

These website uses the Google Tag Manager. The service allows website tags to be managed through an interface. The Google Tag Manager only implements tags. These means that no cookies are used and only the user’s IP address is transmitted to Google to establish a connection. The Google Tag Manager triggers other tags, which in turn may collect data. However, the Google Tag Manager does not access these data. If a deactivation has been made on domain or cookie level, it will remain for all tracking tags as long as they are implemented with the Google Tag Manager.

Google Analytics

Our website and Easee Portal uses Google Analytics, an internet analysis service provided by Google. Google will use these information on behalf us to evaluate your use of the website, the Easee Portal (Fix or Control) and to create reports on website and Portal activity. We use Google Analytics only with activated IP anonymization. These means that your IP address will only be further processed by Google in abbreviated form.

User and event-level data associated with cookies, user IDs (e.g., User ID), and advertising IDs (e.g., DoubleClick cookies, Android Advertising ID, IDFA) will be deleted no later than 14 months after collection.

You can prevent cookies from being saved by adjusting the settings of your browser software accordingly. Please note, however, that if you do so you may not be able to use all the functions of these website without restriction. You can also prevent Google from collecting the data generated by the cookie and analyzing your use of the website (including your IP address) and processing these data by Google by downloading and installing the browser plugin.

The terms of use of Google Analytics and information on data protection can be accessed via the following links: Google Terms and Google Privacy Policy.

Last updated: 15.11.2024