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Who we are

ReFLEX Orkney Limited, a limited company registered in Scotland under company number SC648457, whose registered address is Block 3 Old Academy Business Centre, Stromness, Orkney, United Kingdom, KW16 3AW (“ReFLEX”, “our”, “us” or “we”) is the Data Controller of your personal data we process about you. This privacy notice is for ReFLEX Members and outlines what personal data ReFLEX collects and processes about you and why.

We may update this privacy notice from time to time and we’ll post the changes on this page. If we make an important change that we need to tell you about, we’ll email you to let you know. If you have any questions about this notice, please contact dpo@reflexorkney.co.uk

Our commitment to you

We process your personal data in accordance with the overarching principles and requirements set out in the in the General Data Protection Regulation and the Data Protection Act 2018 (‘Data Protection Law’). What this means is that we process your data in a way that is:

  • Lawful, fair and transparent;
  • Compatible with the purposes that we have told you about;
  • Adequate and necessary, we only use the data we need to use for the reason we told you;
  • Accurate and up to date;
  • Not excessive, we only keep your data for as long as we need it; and
  • Secure and protected.

How and why does ReFLEX use your personal data?

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 compatible with the original purpose. 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.

To set up your membership to the ReFLEX Project, we will process personal data including your name, address, email address, phone number and we will ask you to provide documentation to verify that you are an Orkney resident. It is necessary for us to process your personal data in this way to enter into a contract with you.

As a member you can choose to sign up to any of our products and services and you may be asked to enter into supplemental terms and conditions that relate to a particular product or service. We need to process your personal information in this way for any of the ReFLEX Project partners or third party suppliers to enter and perform the contract for the product or service you agree to purchase. Further information in relation to the way we will process your personal data when you sign up to any of our products and services is set out in the Appendices to this Privacy Statement.

When you visit the ReFLEX Orkney website, we will collect information including your IP address and details of your computer operating system automatically. We do so on the basis of our legitimate interest. Our website uses cookies to ensure that our website works properly and, with your consent, will use non-essential cookies to collect information about how you use our site to improve your browsing experience. More information can be found here.

If you submit an enquiry via our website, social media or by phone, we will process information including your name, email address, phone number and social media handle to response to your query. We do so on the basis of our legitimate interests.

If you provide your consent, we will process your personal data to provide you with marketing materials about products and services offered under the ReFLEX project. You can withdraw consent at any time by contacting dpo@reflexorkney.co.uk

Who do we share your personal data with?

We may share your personal data with our ReFLEX Project Partners; European Marine Energy Centre, Orkney Island Council, Aquatera, Solo Energy, Community Energy Scotland and Heriot Watt University for the purpose of providing you with products and services available under the ReFLEX Project where it is necessary for us to do so to fulfil a contract with you and also to measure the performance of the project on the basis of our legitimate interests. More information can be found here.

Additionally, we may employ third party technology companies based within the EEA, to assist us with the development and maintenance of our application. These third parties may have access to your personal information in the course of providing us with their services. Where third parties process data on our behalf, they won’t use your personal information for their own purposes and we only permit them to use it in accordance with our instructions and the law.

We ensure appropriate safeguards are in place to protect personal data transferred outside the EEA.

We may be required to share your personal data in accordance with law or any regulatory requirements to which ReFLEX is subject or where we are undergoing a corporate restructure.

Third Party Links

Our website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these notices before you submit any personal data to these websites or use these services.

Is my personal data safe?

ReFLEX works hard to protect you personal data and has adopted appropriate technical and organisational measures to keep it safe from unauthorised disclosure, alteration or destruction.

How long will ReFLEX retain my personal data?

ReFLEX will keep your personal data for no longer than is necessary for the purpose we obtained it for or until such time that you withdraw your consent and exercise your right to request that ReFLEX stops processing your personal data.

Does ReFLEX make any automated decisions about me or profile my personal data?

ReFLEX does not make automated decisions about you and also does not profile your personal data.

Your legal rights

You have a number of rights under data protection law in relation to your personal information and if you want to exercise any of these rights, please contact us at dpo@reflexorkney.co.uk and we’ll be happy to help. These rights are as follows:

  • right to request access to your personal information - you can request a copy of the personal information we hold on you;
  • right to request correction of your personal information - if any personal information we hold on you is incorrect, you can request to have it corrected;
  • right to request erasure of your personal information - you can ask us to delete your personal information in certain circumstances;
  • right to object to processing or restrict processing of your personal information - you may object to our processing of your personal data in certain circumstances;
  • right to request the transfer of your personal information - to provide you, or a third party you have chosen, with your personal information; and
  • right to withdraw consent – where we process your data on the basis of consent, you can notify us that you want to withdraw consent any time.

If you have any data protection complaints, you may contact the Information Commissioner's Office (ICO) by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Email: casework@ico.org.uk Telephone: 0303 123 1113

We’d like to try and help with any concerns you may have before you contact the ICO, so please get in touch with dpo@reflexorkney.co.uk in the first instance.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to: dpo@reflexorkney.co.uk

APPENDICES

APPENDIX 1

The ReFLEX EV (‘Electric Vehicle’) Support Package

Members can apply to join our EV Support Package. Members will be asked to agree to supplemental terms and conditions that apply to the EV Support Package. Participation in the EV Support Package will involve us collecting, using and sharing certain data in connection with your use of a ReFLEX Vehicle and your participation in the EV Support Package. That data may include personal data that identifies you.

As a participant in the EV Support Package, you will be asked to agree to the collection and use of your personal data by us for the purposes set out in the supplemental terms that apply to the EV Support Package and in this Privacy Notice. We will use such data to provide the service to you and improve the EV Support Package, and as further described in supplemental terms and conditions that apply to the EV Support Package.

We will collect personal data you provide to us in connection with your membership of the EV Support Package, including:

  • Your name, address, subscription data, membership number and contract information;
  • Details of your queries, correspondence with you, details of any test drive, quotes given, pricing information, support package agreement and other information;
  • Copies of your ID and proof of address;
  • Your financial data, bank details and confirmation of consumer credit checks, pre-financing requests and approvals;
  • Details of your Direct Debit mandate including bank details;
  • Your ID and password for the service;
  • The contact details of the primary driver including email and phone number;
  • Details about the Vehicle in our Vehicle Register – including but not limited to the Vehicle's identification number (VIN) and Vehicle make, model and registration details;
  • Details of Vehicle, orders and expected/actual delivery dates;
  • Confirmation of executed lease agreement with you and related information; and
  • Details of invoices and payments.

We may also collect data related to the ReFLEX Vehicle, its devices and system information, including:

  • Navigation system ID;
  • Embedded SIM IDs;
  • Operation history;
  • Diagnostic data of vehicle systems and parts;
  • State of charge, charging time and charging history;
  • Information from vehicle components;
  • Vehicle performance information e.g. fault codes, power/torque utilization, brake usage, gear shifting and fuel consumption, battery usage;
  • Distance travelled;
  • Speed; and
  • The geo-position, the location, the detection of road and ambient conditions.

For the provision of the EV Support Package and the operation of the ReFLEX Project, we may collect data regarding your use of the EV Support Package and a ReFLEX Vehicle, including navigation system behaviour and parameters data, certain location data including trip stop and start location and charging locations.

We may share some of the personal data we process about you among the Project Partners, the IES Platform, ReFLEX Vehicle providers, providers of personal contract hire (PCH) leases and brokers such as DriveElectric and insurers where we have a lawful basis to do so and subject to data sharing arrangements or contracts with them. If we are required to share information with third parties, we will enter into written data sharing arrangements and/or contracts or use other appropriate safeguards to ensure that any third party will respect and protect your data and, wherever possible, we will seek to anonymise your data prior to transfer. We may also be required to disclose data about you to fulfil a legal obligation.

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