Privacy Policy Statement

Petrolina (Holdings) Public Ltd (hereinafter “Petrolina” or “we”), owner of the pcharge application (the “pcharge App”), is committed to protecting your privacy and handling your personal data in a transparent and legal manner. This privacy notice (together with the relevant Terms and Conditions as set out at https://www.pcharge.com.cy/en/terms-and-conditions
relate to the personal data Petrolina collects from you as a data controller when you use:

the pcharge App, once you have downloaded a copy of it onto your mobile telephone or handheld device (the “Device”), and
any of the services accessible through the pcharge App (the “App Services”).

We have developed this privacy policy (“Privacy Policy’’ or “Statement”) to explain our practices regarding the personal information we collect from you when you are using the pcharge App. This Statement is supplementary to the Privacy Policy of the Petrolina Group which you can find by clicking here and which describes how we may use information you provide to us other than through the pcharge App.
Specifically, this Privacy Policy:

provides an overview of how Petrolina collects and processes your personal data when you become a user of the pcharge App and informs you about your rights under the European Union General Data Protection Regulation (“GDPR”) and the national law supplementing the GDPR;
is directed to natural persons who are current or past users of the pcharge App, and
contains important information about what personal data we collect, what we do with such personal data, who we may share it with and why and your rights in relation to the personal data you have given us when using the pcharge App.

For the purposes of this Privacy Policy:

when we refer to “personal data” we mean data which identifies or may identify you and which may include, for example, your name, address, telephone number, email address and date of birth;
when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting, and storing your personal data; and
when we say or refer to “we” or “us” or “Petrolina” we mean Petrolina (Holdings) Public Ltd as described in Section 1 below, which act as a data controller with respect to the personal data processed in connection to the pcharge App.

1. Who we are

Petrolina (Holdings) Public Ltd is a public listed company in the Cyprus Stock Exchange (CSE), registered in the Republic of Cyprus under registration number ΗΕ1018 with a registered office and head offices at 1 Kilkis, 6015 Larnaca, Cyprus.
If you have any questions about this Privacy Policy or wish to obtain more details in relation to the personal data we hold and process about you in connection to the pcharge App, please contact our Data Protection Officer in writing at 1 Kilkis, 6015 Larnaca, Cyprus or via email at DataProtection@petrolina.com.cy or via telephone at 24 84 80 00.

2. How we collect your personal data

We obtain your personal data mainly through the information you provide directly to us when registering on and using the pcharge App or through information provided indirectly by you through your Device. Below is a list of ways in which we collect your personal data.

(a) Personal data collected directly from you. This is the information you give us initially by completing the registration form on the pcharge App or by corresponding with us (for example, by email or by phone) when you have a query, concern or wish to discuss any other matter connected to the pcharge App. It additionally includes information you provide when you use the App Services such as when you input your payment details to complete your payment at the charging station.

(b) Information we collect from your Device. Upon your registration on the pcharge App, we will automatically collect some data in connection to your Device and/or stored on your Device.

3. What personal data we collect

We may process the following personal data about you:

Identity Data including your full name, date of birth and gender.
Contact Data such as your telephone number and e-mail address.
Profile Data i.e. information that we obtain from your use of the pcharge App. This includes details in connection to the actions taken by users in connection to the charging of their electrically powered vehicle including usage data such as the energy quantity used, the parking time of the vehicle at the charging station and any unsuccessful authorisation requests for charging and transaction data such as we when the charging started and ended, the duration of the charging process and electricity consumer.
Technical Data including your internet protocol (IP) address, your login information, your time zone setting and location and your operating system and platform.
Device Data including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
Location Data i.e. your location coordinates when you have selected to search for nearby charging stations.
Payment data related to the execution and billing of the charging of a user’s electrically powered vehicle such as the total amount and currency paid, credit card data, account data and billing address.
Marketing and Communications Data including your preferences in the way you wish to receive marketing from us (i.e. whether you wish to receive such marketing through email, SMS or push notifications).
Records of any correspondence and/or communications we have with you.

We do not collect any sensitive data about you nor do we collect information about criminal convictions and offences.
Where we ask you to provide us with certain personal data on the registration form and you fail to provide such data, you will not be able to complete the registration and we will therefore be unable to provide you with the App Services.

4. Why we need your personal data

4.1 Personal data

We shall process and use your information where we have your consent, or we have lawful reason for using it subject to applicable law. Most commonly, we will use your personal data in the following circumstances:

(a) Where we need to perform the contract you have entered with us under the Terms and Conditions of the pcharge App

When you register as a new member of the pcharge App and agree to the Terms and Conditions, we will process your personal data in order to:

provide you with the App Services, including facilitating the charging of your electrically powered vehicle through the administration and management of the charging process at Petrolina’s charging stations via the pcharge App.
ensure the proper operation of the pcharge App and manage our relationship with you in accordance with the Terms and Conditions, including notifying you of changes to the pcharge App or the App Services (including changes to this Statement and/or the Terms and Conditions) and liaising with you in order to resolve any issues or concerns you may have.

(b) Where we need to comply with a legal obligation

We will process your data when we are required to comply with certain legal and regulatory obligations which may involve the processing of personal data (e.g. pursuant to tax or consumer law).

We may process your personal data pursuant to our legitimate interests, provided your interests and fundamental rights are not overridden by our interests. More specifically, we may process your personal data in order to:

administer and protect our business, including the pcharge App, and develop our services (including the App Services);
manage the security of our network and information systems,
identify, prevent and investigate fraud and manage our risk exposure,
maintain our accounts and records,
receive professional advice (e.g. tax or legal advice),
defend, investigate or prosecute legal claims,
send you marketing communications with respect of the pcharge App. You can opt-out of receiving such information by adjusting your marketing options in the pcharge App, by contacting us using the contact details in section 1 above or by following the opt-out links on any marketing message we send you.

(d) Where you have given us your consent

When you complete any of the optional fields we provide on our registration form in the pcharge App, you give us your consent to use them for statistical analysis and in order to provide you with marketing which is more customised to your own preferences or characteristics. You can withdraw such consent by deleting such information from your account on the pcharge App or by asking us to delete it for you by contacting us using the contact details in section 1 above.

We may also seek your consent before we enrol you to the MyPetrolina Loyalty Scheme or before we connect your myPetrolina account with your account in the pcharge App. Further details of myPetrolina can be found here https://www.petrolina.com.cy/en/mypetrolina.

5. With whom we may share your personal data

We may share your personal data with third parties as listed below. When we do so, we request from such third parties to have appropriate technical and organisational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this Privacy Policy, nor will we sell your personal data to anyone.
Service providers we have chosen to support us in the overall management of the charging infrastructure for electrically powered vehicles. We work closely with ChargePoint Network (Netherlands) B.V. which is responsible for the development and operation of this infrastructure. Their own privacy policy with respect to how they process personal data can be found here https://eu.chargepoint.com/privacy_policy;

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
Tax authorities, regulators and other governmental bodies or agencies who may require reporting of our processing activities in certain circumstances; and
Governmental and regulatory bodies, including law enforcement authorities in connection with enquiries, proceedings, or investigations by such parties.

When we need to share your personal data with recipients located in third countries (i.e. countries outside the European Economic Area (EEA)), we require them to comply with European data protection standards and to provide appropriate safeguards in relation to the transfer of your data in accordance with GDPR.

6. Safeguarding your data

We use a range of administrative, technical, and technological measures to keep your information safe and secure both physically and electronically. We require our staff and any third parties who carry out any work on our behalf or at our premises or servers to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.

7. How long we keep your personal data (retention)

We will retain all personal data collected about you in connection to the pcharge App for a period of six (6) years from the date of deletion of your account on the pcharge App for any reason and/or from the date when you stopped using your account on the pcharge App. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the 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 requirements.

In rare circumstances, such as for example in anticipated or ongoing litigation proceedings, we may retain your personal data for longer than the six-year retention period.

8. Your rights

You have the following rights in terms of the personal data and information we hold about you:

Receive access to your personal data. This enables you to receive a copy of the personal data we hold about you and to be informed on how we are lawfully processing it.
Request correction (rectification) of the personal data we hold about you. This enables you to have any incomplete, inaccurate, or out of date information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to erase or remove your personal data where there is no good reason for us continuing to process it. This may be the case for example when you wish to delete your account. However, we may continue to retain your information if we are entitled or required to retain it under applicable law or if there is legitimate interest (e.g. there is a claim against you or Petrolina).
Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. In such a case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interest, rights, and freedoms.
Request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if:
- it is not accurate;
- it has been used unlawfully but you do not want us to delete it;
- it is not relevant anymore, but you want us to keep it for use in possible legal claims concerning you;
- you have already asked us to stop using your personal data, but you are waiting for us to confirm if we have legitimate grounds to use your data.
Request to receive a copy of the personal data concerning you in a format that can be easily re-used or request the transfer of such data to other organisations.
Withdraw the consent you gave us regarding the processing of your personal data for certain purposes, such as to allow us to promote our products and services to you.

Exercise of Your Rights: To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact our Data Protection Officer using the contact details set out in Section 1 of this Privacy Policy or by visiting our offices or by telephone. We aim to respond to your request as quickly as possible. In some instances, this could take up to one month (if legally allowed). Should we require more time to complete your request, we will let you know how much longer we need and provide reasons for the delay.
In certain cases, we may not be able to satisfy your request. If it is legally permitted, we will let you know in due course why we cannot not satisfy it. We endeavour to address all requests promptly. Should you not be satisfied with the way we have responded to your concerns you have the right to submit a complaint to us (please refer to Section 10. Right to complain).

Accuracy of personal data information: We endeavour to keep personal data collected as accurate, complete, and current taking into consideration the purposes for which it was collected and is being used.

We rely on you to maintain the accuracy and completeness of the personal data provided by you and so you should inform us if your personal details change. You can do this yourself by changing your personal data on the pcharge App.

9. Right to complain

If you have exercised any or all of your data protection rights, or otherwise still feel that your concerns about the use of your personal data have not been adequately addressed by us, you have the right to complain by contacting our Data Protection Officer using the contact details set out in Section 1 of this Privacy Policy or visiting the Data Protection section on our website.
You also have the right to complain to the Office of the Commissioner for Personal Data Protection. You can visit their website at https://www.dataprotection.gov.cy.

10. Changes to this Privacy Policy

We keep our Privacy Policy under regular review. This version of the Privacy Policy was last updated on 26/02/2024.

If we update our Privacy Policy in the future, the changes will be posted on the pcharge App and, where appropriate, notified to you either by email or when you next start the pcharge App. The new statement may be displayed on-screen and you may be required to read and accept the changes to continue your use of the pcharge App or the App Services.

We do however encourage you to review this Privacy Policy periodically so as to be always informed about how we are processing and protecting your personal information.

11. Automated Decision Making

We do not use automated decision making as such is defined in the General Data Protection Regulation. Automated decision making means a decision that produces legal effects concerning you or which significantly affects you and which is based solely on automated processing of data (i.e. no human intervention in the process).