Privacy Policy

1. Introduction

This Privacy Statement provides information on the processing of personal data by GMOB Assets B.V. (“GMOB”).

In this Privacy Statement we describe who we are, how, when and for which purposes we process your personal data, how you can exercise your privacy rights and all other information that may be relevant to you.

This Privacy Statement may be changed over time. The most up-to-date Privacy Statement is published on www.gmob.fr/politique-de-confidentialite. ​​

2. Who is responsible for your personal data?

GMOB is the controller of the processing of all personal data that fall within the scope of this Privacy Statement.

3. For which purposes do we process your personal data?

3.1. To deliver to you our GMOB mobile application (“GMOB”)

We process your personal data if you use GMOB. We use your billing information to process payments made for charge sessions. We also use your location details to find nearby charge stations in GMOB. Furthermore, we collect your charge token ID if you pay for charge sessions. If you use Autocharge, we also process your vehicle ID.​

We process the following personal data categories :

  • Contact details (such as name, address, telephone number, email address)
  • Billing details (such as name, bank account number, credit card information
  • ​Location details
  • Charge token ID (e.g. FR-GOB-XXXXXXXX)
  • Vehicle ID (for Autocharge)

3.2. When you do business with us

We may process your personal data in the performance and organization of our business. This includes general management, order management and management of our assets. We may conduct audits and investigations, implement business controls, and manage and use customer directories.

Also, we may process your personal data for billing, finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution. For this purpose, we process the following personal data categories about you:

  • Contact details (nom, adresse, numéro de téléphone, adresse électronique)
  • Billing details (such as name, bank account number, credit card information)

3.3. For the development and improvement of our products and services

We process your personal data in order to assess, analyse and improve our products and services. We use aggregated personal data to analyse customer accounts and to adjust our products and services accordingly. When you use our products and services, we also process your personal data to compile analytics reports for internal development purposes.

For this purpose, we process the following personal data categories about you:

  • Contact details (such as name, address, telephone number, email address)
  • Location details
  • Charge token ID (e.g. FR-GOB-XXXXXXXX)

3.4. When you interact with us

a) To communicate with you (online and offline)
If you get in touch with us via our contact details or via our website, we will use your personal data in order to reply and answer your question. We may use your name, contact details, your correspondence with us, your question and all other personal data which are provided by you or necessary to answer your question.

b) When you use our website
I. To deliver you our website’s functionalities and for its technical and functional management
If you use our website, we process technical data to offer you our website functionalities and to allow our website’s administrators to manage and improve our website’s performance. If you enter data in our website, we process these data to provide you with the requested information or functionalities.

Also, we process your personal data to allow you to save your data (such as preferences) on your device. GMOB also uses cookies to ensure you can retrieve information from our website quickly and easily.

For this purpose, we process the personal data you have entered into our website or that is generated by the functionalities you have used in our website and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our website, your clicking and surfing behaviour and the length of your session.

II. To allow you to connect with us (e.g. via social media)
We are active on social media platforms like Facebook, Twitter and LinkedIn. When you click one of the corresponding icons on our website, we will refer you to the website or app of the applicable external party.

When you contact us via social media or via our website, we process the personal data you supply to us in order to answer your questions and to respond to your messages. This may include your (user) name, address, email address, gender and other personal data you have included in your message. In addition, when you click one of the buttons displayed, the relevant third party might place cookies on your device.

3.5. To send you marketing communications

We will send you communications with promotions, offers or other marketing information about our products and services if you use our products or services, or if you have given your permission to do so. If you do not wish to receive these communications, you may unsubscribe to these communications at any time through the ‘Unsubscribe’ button at the bottom of each communication.

3.6. To perform marketing analysis

Personal data is also processed in the context of marketing, product- and customer analyses. This processing forms the basis for marketing, process- and business development to optimize our customer offerings. This may also involve profiling.
Profiling means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person. Examples of such profiling include the analysis of data (e.g. based on statistical methods) with the aim of displaying personalized advertising or newsletters.

3.7. To comply with the law

In some cases, we process your personal data to comply with applicable laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply. Also, in order to comply with relevant laws and regulations, we may need to disclose your personal data as a consequence of a request of a regulatory agency or supervisory authority. For this purpose, we may process the following personal data categories about you :

  • Contact details (nom, adresse, numéro de téléphone, adresse électronique)
  • Billing details (such as name, bank account number, credit card information
  • ​Location details
  • Charge token ID (e.g. FR-GOB-XXXXXXXX)
  • Vehicle ID (for Autocharge)

4. Who has access to your personal data?

4.1. Access to your personal data within GMOB

We ensure that your personal data is only shared internally to the extent necessary to serve the purposes set out in this Privacy Statement. Our employees are aware of the need to respect your privacy and are authorized only to access personal data when it is necessary for them to carry out their respective functions.

4.2. Access to your personal data by external parties

The following categories of external parties may have access to your personal data, only if relevant, for providing their products or services to us:

  • IT partners (to provide technical and operational maintenance)
  • Payment service providers (to process payments made through GMOB)
  • Marketing service providers (to store personal data in databases that are used for marketing purposes)

When external parties are given access to your personal data, we will take the required contractual, technical and organizational measures to ensure that your personal data are only used by those external parties to the extent that such use is necessary for the purposes set out in this Privacy Statement. The external parties may only access your personal data in accordance with contractual obligations with GMOB and applicable law.
If your personal data are transferred to a recipient in a country outside of the European Economic Area (EEA) that does not provide an adequate level of protection for personal data, we will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these recipients. In other cases, your personal data will not be supplied to external parties, except where required or permitted by law.

4.3. The use of your personal data by data processors

When an external party processes your personal data solely following GMOB’ instructions, it acts as a data processor. Prior to interacting with such data processors, we enter into a data processing agreement with them for the processing of personal data. In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us and that this is done subject to the same level of protection as awarded to you by GMOB.

5. How your personal data is secured ?

GMOB has taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.

6. How long is your personal data stored?

GMOB ensures that it retains personal data only if it is necessary for specific purposes. Your personal data will be deleted or made anonymous when your personal data is no longer necessary for the purposes for which these personal data were collected.

7. How can you exercise your privacy rights?

You have the right to request access of an overview or copy of your personal data, and under certain conditions, rectification and/or erasure of personal data. In addition, you may also have the right of restriction of processing concerning your personal data, the right to object to processing as well as the right to data portability. 
To invoke your right of access, rectification, and/or erasure of personal data, your right of restriction of processing, and/or your right to object to processing as well as to invoke your right to data portability, please contact us by using the contact details at the bottom of this Privacy Statement. Please keep in mind that we may ask for additional information to verify your identity.
If you have given your consent to a certain purpose, you can withdraw your consent at any time. Please keep in mind that withdrawal does not have retroactive effect. You can contact us by using the contact details at the bottom of this Privacy Statement.

8. How to file a complaint ?

You can lodge a complaint with your local data protection supervisory authority when you have a complaint about the use of your personal data by GMOB. For example, if you believe that we do not process your personal data carefully, or because you have sent us a request to access or rectification of your personal data and you are not satisfied with our reply or we did not reply in a timely manner.

The contact details of the French data protection supervisory authority are as follows:​

Commission Nationale de l'Informatique et des Libertés - CNIL
8 rue Vivienne, CS 30223
F-75002 Paris, Cedex 02
Tel. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
Website: http://www.cnil.fr/

9. How can you contact us?

If you have any questions about the way we process your personal data, please read this Privacy Statement first. For additional questions or complaints, please contact:

GMOB
Morne Poirier, Convenance
97122 Baie-Mahault
Guadeloupe
privacy@gmob.fr