Data privacy

Privacy policy

A. Data Controller

We are pleased that you are visiting a website of Volkswagen Group Charging GmbH, Mollstraße 1, 10178 Berlin, Email: info@elli.eco, registered in the commercial register of the Local Court of Charlottenburg (Amtsgericht) under No. HRB 208967 B (“Volkswagen Group Charging GmbH”), and would like to thank you for your interest in our company and our products. In the following we inform you about the collection, processing and use of your data.

B. Processing of your personal data

I. Processing of log files

Whenever you use the website, your Internet browser automatically transmits certain information which is recorded by us in so-called log files. Each set consists of the following information:
• the referring website

• the name of the accessed file

• date and time of your visit

• the amount of data transferred

• the HTTP response status (file transferred, file not found etc.)

• informationen on the web browser used in the process

• Accessing domain

• IP address of the device used to access the website

For the hosting of this website, we use the data processor Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA. Appropriate EU standard contractual clauses (as an appropriate guarantee for data processing in non-European countries) have been concluded for the transmission of personal data. You may review the applied EU standard contractual clauses via the URL https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087 .

The processing of this data takes place in accordance with Article 6 Paragraph 1 lit. f GDPR due to our legitimate interest in being able to properly display the website to you and to avert danger. The data will be deleted after 30 days.

II. Contact and customer service

You can contact us using the email address or telephone number provided and send an enquiry to us. In this context, we process the information and data you have supplied (including personal data such as first and last name, email address and phone number)in a ticket to contact you and process your enquiry (Art. 6 (1) (b) GDPR). In handling the inquiries, we are supported by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, as data processor. Your data will also be stored and processed in a CRM system. As a data processor we use Salesforce.com, Inc. (The Landmark @ One Market Street, San Francisco, CA 94105, USA). Access to the information by salesforce.com, Inc. cannot be excluded, so that a corresponding EU standard contract (appropriate guarantee for data processing in non-European countries) has been concluded.

We erase your data as soon as we have answered your enquiry to your satisfaction provided there are no other retention periods (e.g. tax retention periods) that preclude this.

III. Data processing within the scope of your Volkswagen Naturstrom contract

Information about what personal data we process for which purposes can be found in the Privacy Policy of Volkswagen Naturstrom: https://naturstrom.elli.eco/Datenschutzerklaerung.pdf

IV. Data processing within the scope of ordering the Wallbox

Information about what personal data we process for which purposes can be found in the Privacy Policy of the respective webshop:

Finland
https://charging-energy.elli.eco/fi-fi/IDcharger?dialog=policy
Sweden
https://charging-energy.elli.eco/se-sv/IDcharger?dialog=policy
Germany
https://charging-energy.elli.eco/de-de/IDcharger?dialog=policy
Italy
https://charging-energy.elli.eco/it-it/IDcharger?dialog=policy
Spain
https://charging-energy.elli.eco/es-es/IDcharger?dialog=policy
Poland
https://charging-energy.elli.eco/pl-pl/IDcharger?dialog=policy
Switzerland
https://charging-energy.elli.eco/ch-de/IDcharger?dialog=policy
Ireland
https://charging-energy.elli.eco/ie-en/IDcharger?dialog=policy
UK
https://charging-energy.elli.eco/gb-en/IDcharger?dialog=policy
France
https://charging-energy.elli.eco/fr-fr/IDcharger?dialog=policy

V. Data processing within the scope of your job application at Elli

You have the opportunity to view current positions advertised and apply for them via the Volkswagen Group Charging GmbH career portal. In processing these applications, we are supported by Personio GmbH, Rundfunkplatz 4 in 80335 Munich, Germany, as a data processor.
For further information, please refer to the Privacy Policy for applicants: https://elli-jobs.personio.de/privacy-policy

VI. Processing of your data for participation in interviews

To improve our products and digital services, we regularly conduct interviews and surveys ("interviews"). In order to participate in these interviews, it is necessary for you to register with us using the contact form. For this purpose, we process the personal data you provide in the contact form (e.g. first and last name, e-mail address, age, gender, place and circumstances of residence and which electric vehicles you own or drive). If you participate in an interview, we will conduct video and audio recordings of the study to assess and evaluate your user experience as well as to transcribe and evaluate the assessments and evaluations you have given us and to be able to further develop our products. The associated data processing is based on your consent (Art. 6 (1) (a) GDPR). We will store your consent and the video and audio recordings you have made until revoked or for a maximum of one year. If a new interview is planned, we reserve the right to contact you again on the basis of the data already collected.

For the provision of the registration form and for the video and audio recording ("Google Meet"), we use the processor Google Ireland Limited ("Google") with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google LLC") as subprocessor. Appropriate EU standard contractual clauses (as an appropriate guarantee for data processing in non-European countries) have been concluded for the transmission of personal data. You may review the applied EU standard contractual clauses via the URL https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087 .

VII.         Product registration

We process the data you provide in the context of product registration for the purpose of contacting you in the event of service measures, application-specific information campaigns as well as for adapting our customer service to your product based on the consent you provided us (Art. 6 (1) (a) GDPR). The personal data we process includes private contact and identification data (including name, address and e-mail address) as well as product-specific information (including manufacturer, model, cable length, serial number, sales partner, date of purchase). You can revoke your consent at any time free of charge at Volkswagen Group Charging GmbH. You will find further information on exercising your rights in this data protection declaration in the section "Your rights".

As soon as you have withdrawn your consent, your personal data will be deleted, provided that there are no other retention periods (e.g. tax retention periods).

For the provision of the registration form we use the processor Google Ireland Limited ("Google") with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google LLC") as subprocessor. Appropriate EU standard contractual clauses (as an appropriate guarantee for data processing in non-European countries) have been concluded for the transmission of personal data. You may review the applied EU standard contractual clauses via the URL https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087.

VIII.        Recording and analysing of requests by telephone and satisfaction surveys

If you contact us with questions on our digital services and apps or take part in satisfaction surveys over the phone, before the conversation begins, you can agree to your call being recorded for the purposes of quality assurance and improving Customer Care and products and services by following the relevant messages in the queue and giving a relevant instruction or pressing the relevant button on your telephone (see Art. 6 (1) (a) GDPR). You may revoke your express consent to the recording of the conversation at any time by informing the agent during the conversation itself or subsequently sending an email to privacy@elli.eco.

If you have given us your express consent to record one or more conversations, we will record and transcribe your conversation and link the recording to existing recordings of previous conversations for the purposes of quality assurance for our Customer Care and improving our Customer Care as well as our products and services (for instance with a request captured in writing by the agent in order to improve transcripts in case of recordings difficult to understand or with the result of a satisfaction survey to improve the interpretation of your satisfaction with our Customer Care).

For the purposes of quality assurance for our Customer Care, we analyse the recordings directly in text form (e.g. language recognition, syntactic analysis, semantic analysis) and categorise and classify them (e.g. allocation of subject areas, classification based on sentiments). This analysis allows us to draw conclusions on matters such as the duration, content and activity of the conversation and your satisfaction with the Customer Care. This allows us to identify and make use of customer-related matters for debriefs and training sessions with our agents (e.g. ensuring compliance with guidelines, communicating guidelines based on practical examples). We delete or anonymise your data from the recording analysis after 30 days by removing all identifiers and applying voice distortion to the recording so it can no longer be traced back to you.

In order to improve our Customer Care and our products and services, we pseudonymise and transcribe the recordings within 30 days and remove all direct identifiers (e.g. name, email, serial-no., user IDs) and apply voice distortion to the recording. However, we do keep a randomly generated identifier (pseudonym) which is indirectly traceable and linked to your Volkswagen ID (if in place) in order to link the recording with any further recordings. Following pseudonymisation, we analyse the recordings in text form (e.g. language recognition, syntactic analysis, semantic analysis) and categorise and classify them (e.g. allocation of subject areas, classification based on sentiments). This analysis allows us to draw conclusions on matters such as the duration, content and activity of the conversation and your satisfaction with the Customer Care and identify explicit and implicit problems with the usage of our products and services. This allows us to improve our Customer Care processes and technologies and develop our agents’ guidelines or the language recognition in our queue, for instance, as well as our products and services, and make our products easier to use. We delete your pseudonymised recordings after three years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations.

C. Use of cookies and tracking tools

Volkswagen Group Charging GmbH uses various cookies on its websites. Cookies are small files with configuration information, which are stored on your terminal device. Cookies can be divided into three categories. There are cookies which are essential to the functionality of the website (function cookies), cookies which increase the convenience of using the website and, for example, save your language settings (convenience cookies) and cookies used to create a pseudonymous user profile (tracking cookies). 

The processing of function cookies is necessary to enable you to visit the website (see Art. 6 (1) (b) GDPR).

The legal basis for convenience cookies is a legitimate interest (Art. 6 (1) (f) GDPR). Providing convenience when visiting the website is a legitimate interest.

Tracking Cookies are only set if the website visitor has given their consent (Art. 6 (1) (a) GDPR). Consent must be given by using the cookie banner, which must be actively clicked on.

Please find further information on our cookies under our cookie policy.

Google Analytics

This website uses Google Analytics, a web analysis service from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses cookies and similar technologies to analyze and improve our website based on your user behavior. The legal basis for this data processing is Art. 6 Para. 1 lit. f GDPR. The data arising in this context can be transmitted by Google to a server in the USA for evaluation and stored there.

Appropriate EU standard contractual clauses (as an appropriate guarantee for data processing in non-European countries) have been concluded for the transmission of personal data. You may review the applied EU standard contractual clauses via the URL https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087 . However, your IP address will be shortened by Google Analytics before the usage statistics are evaluated so that no conclusions can be drawn about your identity. For this purpose, the implementation of Google Analytics on our website has been modified to include the code “anonymizeIP” in order to ensure that IP addresses are recorded anonymously. Google will process the information obtained from the cookies in order to evaluate your use of the website, to compile reports on website activity for the website operator and to provide other services related to website activity and internet usage. If you use a Google Account, Google may link your Google web and app browsing history to your Google Account and use information from your Google Account to personalize ads, depending on your settings. If you do not want this, it is necessary that you log out of Google before using our website. If you have activated personalized advertising in your Google account, Google may be able to create data models and reports derived from your website behavior that show, for example, on which device you clicked an ad for the first time and on which device a purchase was made. These data models and reports are based on random samples and are pseudonymised to the point of anonymity, based on which we cannot draw any conclusions about an individual Google user.

Hotjar

We use Hotjar in order to better understand our users’ needsand to optimize this service and experience. Hotjar is a technology servicethat helps us better understand our users’ experience (e.g. how much time theyspend on which pages, which links they choose to click, what users do and don’tlike, etc.) and this enables us to build and maintain our service with userfeedback. Hotjar uses cookies and other technologies to collect data on ourusers’ behavior and their devices. This includes a device's IP address(processed during your session and stored in a de-identified form), devicescreen size, device type (unique device identifiers), browser information,geographic location (country only), and the preferred language used to displayour website. Hotjar stores this information on our behalf in a pseudonymizeduser profile. Hotjar is contractually forbidden to sell any of the datacollected on our behalf.

D. Your rights

You can assert your following rights via-à-vis Volkswagen Group Charging GmbH at any time free of charge. You can find further information on exercising your rights under Section E.


Right of access

You have the right to obtain information from us (Art. 15 GDPR) about the processing of your personal data.

Right to rectification

You have the right to demand from us the rectification (Art. 16 GDPR) of any inaccurate or incomplete data concerning yourself.

Right to erasure

You have the right to demand the erasure of your data provided the conditions specified in Art. 17 GDPR are met. You can, for example, demand the erasure of your data provided they are no longer necessary in relation to the purposes for which they were collected. You can also demand erasure if we process your data on the basis of your consent and you withdraw this consent.

Right to restriction of processing

You have the right to demand the restriction of the processing of your data if the conditions of Art. 18 GDPR are met. This is, for example, the case if you dispute the accuracy of your data. You can then demand the restriction of processing during the verification of the accuracy of your data.

Right to object

If the processing is based on an overwhelming legitimate interest, you have the right to object to the processing of your data. An objection is admissible if the processing is either in the public interest or on the basis of a legitimate interest of Volkswagen Group Charging GmbH or a third party. In the event of an objection, please give us the reasons why you object to the data processing.

In addition, you have the right to object to data processing for the purposes of direct advertising. This also applies to profiling if it is connected with direct advertising.

Right to data portability

If the data processing is based on consent or on a contract and the processing is also carried out by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format and to transmit those data to another controller.

Right of revocation

If the data processing is based on consent, you have the right to withdraw your consent with effect for the future at any time free of charge.

Right to complain

You also have the right to complain to a supervisory authority (e.g. to the Data Protection Officer Berlin.)

Rights in relation to automated decision making do not apply as we do not carry out any automated decision making.

E. Your contact

Contact for the exercise of your rights

To exercise your rights and for further information please contact privacy@elli.eco by email or write to the Data Protection Officer of Volkswagen Group Charging GmbH, Mollstraße 1, 10178 Berlin.

Data Protection Officer

Our Data Protection Officer is available as a contact to answer your privacy-related concerns:

Data Protection Officer of Volkswagen Group Charging GmbH
Mollstraße 1, 10178 Berlin
privacy@elli.eco


 
As at: August 2020