Blink App Privacy Policy

Blink App Privacy Policy

Date of Last Revision: 02 August 2024

1. Introduction

This policy, along with:

in the case of consumers (i.e. those users not acting in the course of their employment), our terms and conditions of sale (the Agreement);
our terms of acceptable use (the Ts & Cs); and
any additional terms incorporated by reference into the Agreement and/or the Ts & Cs,

apply to your use of:

our Blink mobile application software (the App) once you have downloaded a copy of the App onto your mobile telephone or handheld device (your Device); and
any of the services accessible through the App (the Services), unless the Agreement and/or the Ts & Cs state that a separate privacy policy applies to a particular Service, in which case that privacy policy alone applies.

This policy sets out the basis on which any personal data relating to you will be processed by us. The App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below:

IMPORTANT INFORMATION AND WHO WE ARE (see section 2)
THE DATA WE COLLECT ABOUT YOU (see section 3)
HOW IS YOUR PERSONAL DATA COLLECTED? (see section 4)
HOW WE USE YOUR PERSONAL DATA (see section 5)
DISCLOSURES OF YOUR PERSONAL DATA (see section 6)
INTERNATIONAL TRANSFERS (see section 7)
DATA SECURITY (see section 8)
DATA RETENTION (see section 9)
YOUR LEGAL RIGHTS (see section 10)
GLOSSARY (see section 11)

2. Important Information and Who We Are

Blink Charging UK Limited (referred to as we, us or our in this policy) is the controller and is responsible for your personal data. If you have any questions about this privacy policy, please contact us using the details set out below.

Contact Details

Our full details are:

company number: 09444771
incorporated and registered in: England and Wales
registered address: 45 Grosvenor Road, 1^st Floor, St. Albans, AL1 3AW
e-mail address: support@blinkcharging.com
telephone number: 0330 111 0076

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 02 August 2024. It may change and, if it does, these changes will be posted on this page and (where appropriate) notified to you by SMS, e-mail and/or when you next start the App. The new policy may be displayed on-screen within the App and you may be required to read and accept the changes to continue your use of the App or the Services.

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 our relationship with you.

Third Party Links

From time to time, the App may contain links to and from the websites and applications of our partners and affiliates. Please note that these websites and applications have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

3. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you as follows:

Contact Data
Device Data
Financial Data
Identity Data
Location Data
Marketing and Communications Data
Profile Data
Transaction Data
Usage Data
Vehicle Data

We explain these categories of data in the Glossary (see section 11)

We also create, use and share aggregated data, such as statistical or demographic data for various purposes. In certain circumstances, aggregated data may be (wholly or in part) derived from your personal data (see section 5 the ‘Purposes for Which We Will Use Your Personal Data’). However, that aggregated data is not considered personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data with the usage data of others in order to calculate the percentage of users accessing a specific App 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 and will treat it 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.

4. How Is Your Personal Data Collected?

We will collect and process the following data about you:

information you give us. This is information (including Contact Data, Financial Data, Identity Data, Marketing and Communications Data and Vehicle Data) that you provide to us by filling in forms in the App or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you:
- register to use the App;
- purchase Services, including on behalf of your employer (where applicable);
- enter a competition, promotion or survey; or
- contact us. For example, when you report a problem with the App or the Services;
information we collect about you and your device. Each time you use the App, we will automatically collect personal data (including Device Data and Usage Data). We collect this data using Cookies (see below in this section 4);
Location Data. We also use GPS technology to determine your current location to allow you to locate chargers available for a charging session near you. Some of our location-enabled Services require your Location Data for the feature to work. If you wish to use those Services, you will be asked to consent to your Location Data being used. You can stop sharing your location at any time by disabling the use of Location Data from within the settings on your Device. If you choose to not share your location data, we will not be able to locate chargers available for a charging session near you;
information we receive from other sources, including third parties.
- Where you are using the App as a consumer, we will receive:
  - where you use a social media profile to log in to the App, Contact Data and Identity Data from the relevant social media platform; and
  - Financial Data and Transaction Data from a provider of payment services.
- Where you are using the App in the course of your duties on behalf of your employer:
  - we will receive the Employer Data from your employer;
  - they will provide us with your Contact Data and Identity Data;

N.B. Where we refer to ‘employer’, this includes (where you are a freelancer) your customer/client.

Cookies

We use cookies to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. The cookies we use and the purposes for which we use them are:

Your payment processor token to securely process your credit card information through the payment gateway;
Your login token to maintain logged in status so you do not have to sign-in each time you load the app;
Your search history to remember what drivers have entered in their search field; and
Your selected filter options so we can remember your preferences when you open the app.

Further information about how you can exercise your choices regarding the use of cookies, please refer to the following guidance plus the cookies section of our Website Privacy Policy.

For Android - Mobile - Android - About Cookies

For iOS - Mobile - iOS - About Cookies

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

where you have consented to the processing;
where we need to perform a contract we are about to enter (or have entered) 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; and
where we need to comply with a legal or regulatory obligation.

See section 5 ‘Lawful Basis’ in the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

The information about the purposes for which we will use your personal data below is divided, based on whether you are using the App as a consumer or in the course of your employment.

Purposes for Which We Will Use Your Personal Data – Consumers

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new user of the App.	• Contact • Device • Identity	Performance of a contract with you.
To process in-App purchases and deliver Services, including managing payments.	• Contact • Device • Financial • Identity • Location • Marketing and Communications • Transaction • Vehicle	Performance of a contract with you.
To collect money owed to us.	• Contact • Financial • Identity • Transaction	Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you.	• Contact • Financial • Identity • Marketing and Communications • Profile	Performance of a contract with you.
To notify you of changes to the App or any Services.	• Contact • Financial • Identity • Marketing and Communications • Profile	Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).
To request (and to enable) your participation in a prize draw or competition.	• Contact • Device • Identity • Marketing and Communications • Profile	Consent.
To request (and to enable) your completion of a survey.	• Contact • Device • Identity • Marketing and Communications • Profile	Necessary for our legitimate interests (to analyse how customers use our Services and to develop them and to grow our business).
To administer and protect our business, the App and the Services, including troubleshooting, data analysis and system testing.	• Contact • Device • Identity	Necessary for our legitimate interests (for running our business, provision of administration and IT services and for network security) .
To make recommendations to you about our goods and/or services that may interest you.	• Contact • Device • Identity • Location • Marketing and Communications • Profile • Usage • Vehicle	Consent. Necessary for our legitimate interests (to promote our business to existing and former customers). See ‘Marketing’ below for further information.
To monitor trends and usage of the App so that we can improve the App.	• Contact • Device • Identity • Location • Marketing and Communications • Profile • Usage • Vehicle	Necessary for our legitimate interests (to develop our services and grow our business).
To create aggregated user data.	• Contact • Device • Identity • Location • Marketing and Communications • Profile • Usage • Vehicle	Necessary for our legitimate interests (to study users (and their use) of the App in order develop our services and grow our business).
CellTo enquire whether you wish to participate in studies conducted by third parties (whose identity we will provide) and – if so – to share your personal data with them.	• Contact • Identity	Cell• In respect of the enquiry, necessary for our legitimate interests (to develop our products and services and to grow our business based on study results) and, in some circumstances, those of third parties (where the study will provide broader information about our industry). • In respect of the sharing, consent.

Purposes for Which We Will Use Your Personal Data – Employees

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new user of the App.	• Contact • Device • Identity	Necessary for our legitimate interests (performance of a contract with your employer).
To manage our relationship with you.	• Contact • Identity • Marketing and Communications • Profile • Transaction	Necessary for our legitimate interests (performance of a contract with your employer).
To notify you of changes to the App or any Services.	• Contact • Identity • Marketing and Communications • Profile • Transaction	Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).
To request (and to enable) your participation in a prize draw or competition.	• Contact • Device • Identity • Marketing and Communications • Profile	Consent.
To request (and to enable) your completion of a survey.	• Contact • Device • Identity • Marketing and Communications • Profile	Necessary for our legitimate interests (to analyse how customers use our Services and to develop them and to grow our business).
To administer and protect our business, the App and the Services, including troubleshooting, data analysis and system testing.	• Contact • Device • Identity • Transaction	Necessary for our legitimate interests (for running our business, provision of administration and IT services and for network security) .
To make recommendations to you about our goods and/or services that may interest you.	• Contact • Device • Identity • Location • Marketing and Communications • Profile • Usage • Vehicle	Consent. Necessary for our legitimate interests (to promote our business to existing and former customers). See ‘Marketing’ below for further information.
To monitor trends and usage of the App so that we can improve the App.	• Contact • Device • Identity • Location • Marketing and Communications • Profile • Usage • Vehicle	Necessary for our legitimate interests (to develop our services and grow our business).
To create aggregated user data.	• Contact • Device • Identity • Location • Marketing and Communications • Profile • Transaction • Usage • Vehicle	Necessary for our legitimate interests (to study users (and their use) of the App in order develop our services and grow our business).
CellTo enquire whether you wish to participate in studies conducted by third parties (whose identity we will provide) and – if so – to share your personal data with them.	• Contact • Identity	• In respect of the enquiry, necessary for our legitimate interests (to develop our products and services and to grow our business based on study results) and, in some circumstances, those of third parties (where the study will provide broader information about our industry). • In respect of the sharing, consent.

Marketing

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

We may use your Identity, Contact and Commercial 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 (we call this marketing).

We will only send you direct marketing communications by app, e-mail or text where we have your consent. You have the right to withdraw that consent at any time by updating your choices on the app.

6. Disclosures of Your Personal Data

We will also share your personal data with the third parties for the purposes set out in the ‘Purposes for Which We Will Use Your Personal Data’ table in section 5:

third parties, as set out in the Glossary in section 11;
in certain circumstances, specific third parties where we have notified you of their identity and you have consented to us sharing certain personal data with them. For example, when we ask if you would like to participate in studies being conducted by those third parties;
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7. International Transfers

The personal data we collect from you may be transferred to, and stored at, a destination outside the UK/European Economic Area (“EEA”) depending on which of our international entities are providing services and where we use service providers located outside the UK/EEA.

Transfers within the Blink Charging Group

We will transfer your personal data between Blink legal entities and offices. Where personal data is transferred to, and stored at, a destination within the UK/EEA, these countries have been deemed to provide an adequate level of protection for personal data.

Where personal data is transferred to, and stored at, a destination outside the UK/EEA, we have complied with the need for additional safeguards as set out in legislation.

Transfers to third parties

We will transfer your personal data to third parties within the UK/EEA. Where personal data is transferred to, and stored at, a destination within the UK/EEA, these countries have been deemed to provide an adequate level of protection for personal data.

Whenever we transfer your personal data out of the UK/EEA, we will seek to 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.
Where we use certain service providers, we may use specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

8. Data Security

All information you provide to us is stored on our secure servers (or those of our third party service providers). Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using WebSocket technology. Where you have chosen a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and other technology.

We have put in place procedures to deal with any suspected personal data breaches and – in the event of a personal data breach – will notify you and any applicable regulator when we are legally required to do so.

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including 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 of personal data, we consider the amount, nature and sensitivity of 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 requirement.

10. Your Legal Rights

Under certain circumstances you have the following 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);
- we may have processed your information unlawfully; or
- 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; or
- 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.

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.

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.

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.

If you would like to exercise any of these rights, please contact us by email at privacy@blinkcharging.com or write us at: Blink Charging UK Limited, 45 Grosvenor Road, 1st Floor, St. Albans, AL1 3AW

You also have the right to ask us not to continue to process your personal data for marketing purposes by updating your choices in the app.

You can exercise any of these rights at any time by contacting us (see section 2 for our full contact details).

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK regulator for data protection issues.

You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note are not responsible for the content of external websites)

Or you can write to them at:

Information Commissioner's Office,

Wycliffe House,

Water Lane,

Wilmslow Cheshire,

SK9 5AF

11. Glossary

Lawful Basis

‘Consent’ means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us (see section 2 for our full contact details).
‘Legitimate interest’ means the interest of our business or a third party. 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 (see section 2 for our full contact details).
‘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 to which we are subject.

Third Parties

With our affiliates; our distributors, resellers, channel partners, Blink Charging station owners
External third parties, including:
- Provider of payment services
- Where you use the App in the course of your employment, your employer.
- Financial accounting system
- Customer service platform
- Back-office provider
- Subscription billing system
- Financial solutions and payment platform
- Contactless payment provider
- Online banking provider

Description of categories of personal data

Contact Data: postcode, e-mail address and telephone number.
Device Data: includes: the type of mobile device you use; unique device identifier(s) (for example, your Device’s IMEI number, the MAC address of your Device’s wireless network interface and/or the mobile phone number used by your Device); mobile network information; your mobile operating system; and time zone setting.
Employer Data: where you use the App in the course of your employment, your employer’s name.
Financial Data: payment tokens.
Identity Data: first and last name and profile picture.
Location Data: includes your past and current location, disclosed by GPS technology on your Device.
Marketing and Communications Data: includes: your preferences in receiving marketing from us and our third parties; and your communication preferences.
Profile Data: includes: your e-mail address and password; in-App purchase and charging history; your preferences; feedback; and survey responses.
Transaction Data: includes: (a) where you are using the App as a consumer, details about payments to and from you, your postcode, details of requested and completed in-App purchases; and (b) where you are using the App in the course of your duties on behalf of your employer, details about payments from your employer.
Usage Data: includes: details of your use of any part of the App (including traffic data and other communication data); and the resources that you access in the App.
Vehicle Data: includes: brand(s), model(s) and registration number(s) of your vehicle(s); and your name(s) for those vehicle(s).

Data Removal Request