Privacy Policy


Welcome to the VOLLT App privacy policy.
The VOLLT App respects your privacy and is committed to protecting your personal data.
This privacy policy will inform you as to how we look after your personal data when
you visit our website (regardless of where you visit it from) or use our app and tell
you about your privacy rights and how the law protects you.


Purpose of this privacy policy

This privacy policy aims to give you information on how VOLLT collects and
processes your personal data through your use of our website https://www.vollt.io
and through our app, including any data you may provide through your use
of the website or app.


It is important that you read this privacy policy together with any other privacy policy
or fair processing policy we may provide on specific occasions when we are
collecting or processing personal data about you so that you are fully aware of how
and why we are using your data. This privacy policy supplements other notices and
privacy policies and is not intended to override them. As our services are provided
for drivers this policy is intended for persons of legal driving age. We do not
knowingly collect data about children.


Controller

VOLLT is the controller and responsible for your personal data (collectively referred
to as “VOLLT”, “we”, “us” or “our” in this privacy policy).


Contact details


If you have any questions about this privacy policy or our privacy practices, please
contact us in the following ways:


Email address: info@vollt.io
Telephone number: 0303 300 1006


You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection issues
(www.ico.org.uk). We would, however, appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first instance.


Changes to the privacy policy and your duty to inform us of changes


We keep our privacy policy under regular review. This version was last updated on
21 October 2021.
It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with
us.


Third-party links

The website and app may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow third
parties to collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements. When you leave our
website or app, we encourage you to read the privacy policy of every website you
visit.

The data we collect about you
Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together as follows:


Identity Data includes first name, last name, username or similar identifier, marital
status, title, date of birth.
Contact Data includes billing address, home address, email address and telephone
numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details
of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you use to
access this website.
Profile Data includes your username and password, purchases made by you, your
preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data could be derived from your personal data but
is not considered personal data in law as this data will not directly or indirectly reveal
your identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership, information about

your health, and genetic and biometric data). Nor do we collect any information
about criminal convictions and offences.


If you fail to provide personal data


Where we need to collect personal data by law, or under the terms of a contract we
have with you, and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, to
provide you with driver portal services when you sign up for an account with us). In
this case, we may be unable to provide the services, or have to cancel a service you
have with us. But we will notify you if this is the case at the time.

  1. How is your personal data collected?
    We use different methods to collect data from and about you including through:
    Direct interactions. You may give us your Identity, Contact and Financial
    Data by filling in online forms or by corresponding with us by post, phone,
    email or otherwise. This includes personal data you provide when you:
    • download our app;
    • create an account on our website;
    • subscribe to any other service or publication we offer;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
    Automated technologies or interactions. As you interact with our website,
    we will automatically collect Technical Data about your equipment, browsing
    actions and patterns. We collect this personal data by using cookies and other
    similar technologies. We may also receive Technical Data about you if you
    visit other websites employing our cookies. Please see our cookie policy for
    further details.
    Third parties or publicly available sources. We will receive personal data
    about you from various third parties and public sources as set out below:
    • Technical Data from analytics and search information providers
    • Contact, Financial and Transaction Data from providers of technical and
    payment services
    • Identity and Contact Data from data brokers or aggregators
    • Identity and Contact Data from publicly available sources such as the DVLA.
  2. How we use your personal data
    We will only use your personal data when the law allows us to. Most commonly, we
    will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have
entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party)
and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal
data although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by contacting us.


Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Here is a glossary of some of the legal terms we use in relation to the purposes for
which we use your personal data:


Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best services/products and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we have
your consent or are otherwise required or permitted to by law). You can obtain
further information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by contacting us.


Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.


Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please contact
us if you need details about the specific legal ground we are relying on to process
your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as an account holder(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data(a) Identity
(b) Contact
(c) Technical
a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youa) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.


Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested
information from us or obtained services from us and you have not opted out of
receiving that marketing.


Third-party marketing
We will get your express opt-in consent before we share your personal data with any
third party for marketing purposes.


Opting out
You can ask us or third parties to stop sending you marketing messages at any time
by following the opt-out links on any marketing message sent to you or by contacting
us at any time on info@vollt.io.


Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that
some parts of this website may become inaccessible or not function properly. For
more information about the cookies we use, please see our Cookie Policy.


Change of purpose
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please
contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by
law.

  1. Disclosures of your personal data
    We may share your personal data with the parties set out below for the purposes set
    out in the table above.

• Service Providers that we use to help with certain aspects of our operations,
for example for website hosting or payment services.
• Other members (current and future) of the same group of companies (which
means a parent company, a subsidiary, joint venture or other company that
controls is controlled by or is under common control with VOLLT).
• Partners, being third parties such as advertisers, associates and other
potential business partners.
• Professional advisers including lawyers, bankers, auditors and insurers who
provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the
United Kingdom.
We require all third parties to respect the security of your personal data and to treat it
in accordance with the law. We do not allow our third-party service providers to use
your personal data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our instructions.

  1. International transfers
    Where we share your personal data within the VOLLT App will not involve transferring
    your data outside the European Economic Area (EEA).
    However, some of our external third parties are based outside the EEA so their
    processing of your personal data will involve a transfer of data outside the EEA.
    Whenever we transfer your personal data out of the EEA, we ensure a similar
    degree of protection is afforded to it by ensuring at least one of the following
    safeguards is implemented:
    • We will only transfer your personal data to countries that have been deemed
    to provide an adequate level of protection for personal data by the European
    Commission. For further details, see European Commission: Adequacy of the
    protection of personal data in non-EU countries.
    • Where we use certain service providers, we may use specific contracts
    approved by the European Commission which give personal data the same
    protection it has in Europe. For further details, see European Commission:
    Model contracts for the transfer of personal data to third countries.
    Please contact us if you want further information on the specific mechanism used by
    us when transferring your personal data out of the EEA.
  2. Data security
    We have put in place appropriate security measures to prevent your personal data
    from being accidentally lost, used or accessed in an unauthorised way, altered or
    disclosed. In addition, we limit access to your personal data to those employees,
    agents, contractors and other third parties who have a business need to know. They

will only process your personal data on our instructions and they are subject to a
duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are legally
required to do so.

  1. Data retention
    How long will you use my personal data for?
    We will only retain your personal data for as long as reasonably necessary to fulfil
    the purposes we collected it for, including for the purposes of satisfying any legal,
    regulatory, tax, accounting or reporting requirements. We may retain your personal
    data for a longer period in the event of a complaint or if we reasonably believe there
    is a prospect of litigation in respect to our relationship with you.
    To determine the appropriate retention period for personal data, we consider the
    amount, nature and sensitivity of the personal data, the potential risk of harm from
    unauthorised use or disclosure of your personal data, the purposes for which we
    process your personal data and whether we can achieve those purposes through
    other means, and the applicable legal, regulatory, tax, accounting or other
    requirements.
    By law we have to keep basic information about our customers (including Contact,
    Identity, Financial and Transaction Data) for six years after they cease being
    customers for tax purposes.
    In some circumstances you can ask us to delete your data: see “your legal rights”
    below for further information.
    In some circumstances we will anonymise your personal data (so that it can no
    longer be associated with you) for research or statistical purposes, in which case we
    may use this information indefinitely without further notice to you.
  2. Your legal rights
    Under certain circumstances, you have rights under data protection laws in relation
    to your personal data.
    You have the right to:
    Request access to your personal data (commonly known as a “data subject access
    request”). This enables you to receive a copy of the personal data we hold about you
    and to check that we are lawfully processing it.
    Request correction of the personal data that we hold about you. This enables you
    to have any incomplete or inaccurate data we hold about you corrected, though we
    may need to verify the accuracy of the new data you provide to us.
    Request erasure of your personal data. This enables you to ask us to delete or
    remove personal data where there is no good reason for us continuing to process it.
    You also have the right to ask us to delete or remove your personal data where you

have successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to erase
your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing carried
out before you withdraw your consent. If you withdraw your consent, we may not be
able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any of

your other rights). This is a security measure to ensure that personal data is not
disclosed to any person who has no right to receive it. We may also contact you to
ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could
take us longer than a month if your request is particularly complex or you have made
a number of requests. In this case, we will notify you and keep you updated.

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