Privacy Policy Elli Smart Charging

Thank you for using our Elli Smart Charging mobile application (“app”). This information applies to the following services and functions, provided they are available in a country, an app version and depending on the mobile device and vehicle model.

Please find below information about the data controllers and their responsibilities (Section A), how your data is collected, processed, and utilized in connection with the use of the app for information purposes (Section B) and in connection with the use of Elli Smart Charging (Sections C–H), as well as about your rights and contact persons (Sections I and J).

A. Controller

If you use the Elli Smart Charging service (“Charging Service”), your data will be processed by Volkswagen Group Charging GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, e-mail: info@elli.eco, registered under No. HRB 208967 B (“Elli Germany”) in the commercial register of the Charlottenburg District Court.

Elli Germany, known as “Elli,” is hereinafter referred to as “Elli,” “we,” or “us.”

B. General information on using the app

I. General information

Unless you register or otherwise provide us with information, we collect the data described below, which is technically necessary for us to offer you the functions of the App and to ensure the stability and security of the App:

This information is processed to make it technically possible for you to use our app, since the automatically collected data is required by us in order to provide a functional app (e.g., by adapting the app to the requirements of the specific type of device you are using). In addition, this information is processed to optimize the app as well as to ensure the stability and security of the app and our IT systems. The automatically collected data is not personal data and cannot be used to identify you. It is stored for 30 days and then duly deleted, unless the law stipulates that the data be stored for a longer period or there are justifiable grounds for doing so.

II. Tracking Tools

Volkswagen Group Charging GmbH uses Microsoft App Center and Firebase to collect anonymous data on the use of the software for the purpose of improving the software, the components configured with it and the services. Documented are the frequency of use of the software, individual functions, malfunctions of the software, model, version and status information of the component as well as model, operating system, language and country of the device. No personal data will be transmitted to Volkswagen Group Charging GmbH.

III. Attribution tools

Volkswagen Group Charging GmbH uses the Adjust analytics platform for app attribution, to improve the user experience, and to optimize the scaling of the app. We collect and process the following data for this purpose:

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. For this purpose, we employ the services of the processor Adjust GmbH (“Adjust”), headquartered at Saarbrücker Str. 37a, 10405 Berlin, Germany.

IV. Analytics tools

Volkswagen Group Charging GmbH uses the Amplitude analytics platform for app analytics to gain insights into the use of the app and its features. This allows us to improve your experience by implementing updates or new features tailored to your needs. The analytics platform is provided by Amplitude, Inc. (“Amplitude”), located at 201 3rd Street, Suite 200, San Francisco, CA 94103, USA. We collect and process the following data for this purpose:

Amplitude is not able to establish the identity of an individual user. We do not receive any data on individual users from Amplitude, only statistics and analyses in an overall context, which are made available to us in aggregated form via the user interface provided by Amplitude. We make no attempt to identity or track the behavior of individual users.

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. We will also delete your personal data after three (3) years at the latest or when the purpose no longer exists. Data is transferred to the USA when data is processed by Amplitude Amplitude is certified under the EU-U.S. Data Privacy Framework, which serves as an adequacy decision of the EU as a guarantee for third-country transfers. Beyond that, we have also concluded standard contractual clauses with Amplitude. You can request information on the content of these clauses from the contacts listed in this Privacy Policy.

You can find additional information on data processing in Amplitude’s privacy policy: https://amplitude.com/privacy

V. Feature management with LaunchDarkly

We use the LaunchDarkly feature management platform in order to use feature flags in the app. This enables us to selectively enable and test various features in the app and thereby improve your experience and the quality of the app. For this purpose, we process user profile data (e.g., e-mail address, user ID, country) as well as app and device-specific data (e.g., app version, brand, operating system).

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. We will also delete your personal data after three (3) years at the latest or when the purpose no longer exists.

For this service, we use the platform of Catamorphic Co. dba LaunchDarkly, who provides the service (“LaunchDarkly”), located at 1999 Harrison St., Suite 1100, Oakland, CA 94612 U.S. Your data will be transferred to the USA for this purpose. To this end, we have concluded EU standard contractual clauses with the service provider, which act as a guarantee for this transfer of data. You can request information on the content of these standard contractual clauses at any time from the contacts listed in Section J.

VI. Remote logging

We log your use of the app by means of the remote logging function provided as a Google Cloud service. Along with that, we also log other problems beyond crashes, bugs, or residual currents. This allows us to investigate potential problems across all devices and troubleshoot them more quickly. Our aim in using remote logging is to ensure that you can use the app free of error at all times and that all content is made available to you free of any problems. We use the Google service for this purpose, which is why the following personal data is transmitted to Google:

The client ID is randomly generated when the app is downloaded and saved on the backend. If you delete the app and download it again, a new client ID will be generated.

Processing is carried out on the basis of our legitimate interest in the functionality of our service and our app environment (Art. 6(1)(f) GDPR). Your data will be deleted once the purpose ceases to apply. You can read about your right to object and how to assert it in Sections I and J.

For this service, we employ the services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S. (“Google LLC”) as a sub-processor. This means that data may be transferred to the USA. For more information on this, please read Google’s privacy policy: https://cloud.google.com/terms/cloud-privacy-notice?hl=en. The EU standard contractual clauses used by Google can be viewed under the following link: https://cloud.google.com/terms/eu-model-contract-clause

C. Processing of Your Data Upon Conclusion of the Agreement

I. Elli user ID (linking it to your user account with the manufacturer of your vehicle)

To use our service via the Elli Smart Charging app, you need an active user account with the relevant manufacturer of your vehicle. To create and manage a profile in order to use the optional online services, it is necessary to link your user account with the manufacturer of your vehicle to your Elli user ID.

You have the option of redirecting the Elli Smart Charging app to your user account with the manufacturer of your vehicle, logging in with the aforementioned account, and registering the link using your Elli user ID in this account. Please note the detailed privacy policy that applies for your vehicle manufacturer. This can be viewed on the website of your vehicle manufacturer, in the information and directions on use, or on other media provided by your vehicle manufacturer as the responsible service provider. We process the data from your user account with the manufacturer of your vehicle (your personal contact and identification data, such as your name, address, and e-mail address) for the purpose of fulfilling the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above.

When you successfully log in to your user account with the manufacturer of your vehicle, a corresponding Elli user ID is automatically generated that enables you to use our Elli Smart Charging services. To use our service via the Elli Smart Charging app, you need a linked Elli user ID. When you use our services, we process the data from your user account (your personal contact and identification data, such as your name and postal/e-mail address) for purposes of fulfilling the agreement (Art. 6(1)(b) GDPR). We use Auth0 (10800 NE 8th Street, Suite 700, Bellevue, WA 98004, U.S.) to provide your account and login with your ELLI ID. Use includes the storage of personal contact and identification data, such as name and postal/e-mail address. The standard contractual clauses drawn up by the European Commission (as an appropriate guarantee for data processing in non-European countries) have been concluded for the transfer of personal data. We will be happy to provide you with information on the content of the standard contractual clauses on request.

Once your user accounts/IDs have been successfully linked, you can access charging settings and information on the state of the charge at any time as well as manage and remotely control your vehicles (e.g., manage access options).

II. Charge at Home (only available for chargers with connectivity features)

Please note that the use of Charge at Home services and associated online services (e.g., optimized charging at home charging stations on the basis of: power generated by solar panels based on real-time data; power generated by solar panels based on forecast data; European Power Exchange prices; flexible electricity tariffs) requires that the electrical installation, configuration, and connection of a charger be carried out in advance and, depending on the services used, other devices equipped with connectivity features.

a. Linking the charger

We process the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that your charger is up-to-date and able to communicate, including the Wi-Fi connection or LTE mobile communications standard (so-called connectivity features), as part of the electrical installation and configuration process: device ID, brand, generation, device type, and software version (technical data).

Within the scope of using optional online services, we process the following personal and other technical data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention periods for your data and to “Your Rights” for more information on exercising your rights.

b. Linking the vehicle

We process the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that it is possible to communication with your vehicle during the electrical installation and configuration process: vehicle identification number (VIN), make, generation, model type, and software version (technical data).

If you want to use optional online services, you will need to authorize your vehicle and link it to your existing Elli user account/user ID by way of a user account with the manufacturer of your vehicle (see Section C., Subsection I. Elli user ID (linking it to your user account with the manufacturer of your vehicle)).

Within the scope of using optional online services, we therefore process the following personal data in order to provide and render the service described above: customer and user ID (data shared from your user account and e-mail addresses of the users you optionally unlocked). In addition, we also receive the following categories of data from your vehicle manufacturer (e.g., Volkswagen AG) for the same purpose in conjunction with the vehicle identification number (VIN) and your customer ID number:

Please note the relevant privacy policy that applies for your vehicle manufacturer. This can be viewed on the website of your vehicle manufacturer, in the information and directions on use, or on other media provided by your vehicle manufacturer.

If you want to use optional online services for intelligent charging functions (e.g., Elli Smart Charging services), your current charging settings may result in the optional online services not running optimally caused by certain vehicle modes and entries you made on the HMI vehicle control panel (charging configurations). If this is the case, we will need to carry out initial changes to the charging configuration of your vehicle. At the same time, you have the option of changing the charging configuration of your vehicle at any time to fit your requirements. If you made changes that once again affect your further use of the optional online services, we will notify you of this in the app. Please note that the optional online services may then only be used to a limited extent or they may no longer be used at all.

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

c. Linking other devices (with connectivity features if applicable)

We process, for example, the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that other devices (e.g., Modbus energy meters, smart meters/intelligent metering systems, home energy management systems) are able to communicate and are up to date as part of the electrical installation and configuration process: device ID, brand, generation, device type, and software version (technical data).

If you want to use optional online services, you will need to authorize your other devices and link them to your existing Elli user account by way of device-specific firmware/a device-specific web configuration. You can then access information about power generation/consumption (e.g., power consumed from solar panels/from the grid) at any time, remotely control your devices (e.g., manage access options, prioritize/deprioritize the supply of power to devices), as well as manage them (e.g., enable or disable electrical meters/measuring systems for use with the charger).

Within the scope of using optional online services, we process the following personal data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

d. Link to power supply contract

If you want to use optional online services that are directly linked to a power supply contract, you will need to link your electricity supplier with your Elli user ID in the relevant customer portal of the electricity supplier using your registration data.

Within the scope of using optional online services, we process, for example, the following personal data in order to provide and render the following services: customer number, contract number, meter number, and electricity meter readings.

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

E. Retention Obligations

We process your personal data for as long as is necessary for the aforementioned purposes. In the event that you object to processing based on our legitimate interests, we will erase your personal data unless further processing is permitted under the relevant statutory provisions. We also delete personal data if we are obliged to do so for other legal reasons. Applying these general principles, we delete personal data immediately after the legal basis ceases to apply if it is no longer required for the stated purposes or the stated purposes cease to apply and provided that no other legal basis exists (e.g., retention periods under commercial and tax law); otherwise, the data will be deleted after the other legal basis ceases to apply.

F. Customer Support

You have the possibility to contact us and send us a request. In the event that you do so, we process the information and data you provide (including personal data) in a ticket in order to contact you and process your request (Art. 6(1)(b) GDPR). We are supported in processing the data by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, and Majorel Berlin GmbH, Wohlrabedamm 32, 13629 Berlin, Germany, as processors. Your data is also stored and processed in our CRM system. We employ the services of Salesforce.com EMEA Limited (Floor 26 Salesforce Tower, 110 Bishopsgate, London, EC2N 4AY, United Kingdom) as the processor for this purpose. There is an adequacy decision issued by the European Commission in place for the United Kingdom, which serves as a guarantee for data transfers. Access to the information by Salesforce.com, Inc. (The Landmark @ One Market, San Francisco, CA 94105, USA) cannot be ruled out. Salesforce.com, Inc. is certified under the EU-US Data Privacy Framework, which serves as an adequacy decision as a guarantee for data transfers. In addition, Salesforce has Binding Corporate Rules in place, which are recognized by the European and British supervisory authorities as a guarantee for data transfers.

We will delete your data as soon as we have responded to your request to your satisfaction, provided there are no other retention periods (e.g., retention periods under tax law) to the contrary.

G. Data Processing by Service Providers

If service providers process personal data on our behalf, we have concluded a data processing agreement with these service providers and agreed to appropriate guarantees to ensure the protection of personal data. We also select our service providers with care. They process personal data for the sole purpose of performing their activities and are contractually bound by our instructions, have suitable technical and organizational measures in place to protect personal data, and are regularly audited by us.

I. Data processing on the Google Cloud Platform

Volkswagen Group Charging GmbH uses the Google Cloud Platform (GCP) to process the following categories of data:

This data is collected and used for the following purposes:

For this purpose, we employ the services of the processor Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google LLC”) as a sub-processor. Google LLC is certified under the EU-US Data Privacy Framework, which serves as an adequacy decision as a guarantee for data transfers.

II. Data processing at CELONIS

Volkswagen Group Charging GmbH employs the services of CELONIS to process the following categories of data:

This data is collected and used for the following purposes:

For this purpose we employ the services of processor CELONIS SE (“Celonis”), Theresienstrasse 6, 80333 Munich, Germany.

H. Data processing for purposes of analysis

Product development and business planning

Purpose of processing:

Categories of personal data for this purpose:

The data is processed exclusively pseudonymously for this purpose. Pseudonymization involves the removal of all direct personal identifiers (e.g., name, e-mail address, telephone number). Indirectly traceable identifiers (pseudonyms) are retained. Data is not analyzed in the analytics systems of Volkswagen Group Charging GmbH until it has been pseudonymized. At no time is a direct reference to a specific person re-established. The results of the analysis (in particular, metrics and KPIs) are fully anonymous. The processing of pseudonymous data is necessary because there are interactions between the user account and the relevant services. In such cases, the use of the pseudonym is absolutely necessary in order to link the data from the user account and the linked services on which the analysis is based. For this purpose, the data is stored and analyzed on the Google Cloud Platform and in CELONIS and Salesforce. The data processed for purposes of analysis will be deleted after thirty-six (36) months (three (3) years). This processing serves the legitimate interest of Volkswagen Group Charging GmbH to meet high customer demands in terms of the existing products and services and to be able to fulfill future requirements of our customers by means of new products and services that have yet to be developed (Art. 6(1)(f) GDPR).

I. Your rights

You can assert the following rights vis-à-vis Volkswagen Group Charging GmbH at any time at no charge. For more information on exercising your rights, please refer to Section G.

Right to information: You have the right to receive information from us (Art. 15 of the GDPR) regarding the processing of your personal data.

Right to rectification: You have the right to obtain from us the rectification (Art. 16 of the GDPR) of inaccurate or incomplete personal data concerning you.

Right to erasure: You have the right to obtain the erasure of your data if the conditions set out in Art. 17 of the GDPR are satisfied. You can then, for example, obtain the deletion of your data if it is no longer necessary in relation to the purposes for which it was collected. You can also obtain 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 obtain the restriction of the processing of your data if the requirements of Art. 18 of the GDPR are satisfied. This would be the case, for example, if you were to contest the accuracy of your data. You can then obtain the restriction of processing for a period enabling the controller to verify the accuracy of the data.

Right to object: If the processing is based on an overriding legitimate interest, you have the right to object to the processing of your data. You also have the right to object 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 that you object to data processing, we ask that you inform us of the reasons for your objection. You also have the right to object to data processing for direct marketing purposes. This also applies to profiling to the extent that it is related to such direct marketing.

Right to data portability: If the processing of data is based on consent or on a contract and 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 it to another controller.

Right to withdraw consent: If the processing of data is based on consent, you have the right to withdraw your consent at any time at no charge with future effect.

Right to lodge a complaint: You also have the right to lodge a complaint with respect to our processing of your data with a supervisory authority (for example, the Commissioner for Data Protection and Freedom of Information of the State of Berlin).

J. Your contact persons

Who to contact to exercise your rights

If you have any questions regarding data privacy or wish to assert your rights, please contact our data protection officer at:

How to contact our data protection officer

PROLIANCE GmbH
www.datenschutzexperte.de
Leopoldstr. 21
80802 München

datenschutzbeauftragter@datenschutzexperte.de

When contacting the data protection officer, please specify Volkswagen Group Charging GmbH as the company to which your request refers. Please refrain from including sensitive information such as a copy of your ID with your request.

Last updated: June 2024