Jedlix B.V. (hereafter: “Jedlix”) values your privacy very highly. It processes your personal data carefully and in a manner compliant with the terms of the law. Jedlix is responsible for collecting and processing data via its smart charging platform and mobile application (hereafter the “Jedlix App”). The purpose of this privacy statement is to inform you about how Jedlix processes and uses your personal data, and to inform you of your rights under the European General Data Protection Regulation (“GDPR”).
This privacy statement is divided into the following sections.
- The Purposes of the Personal Data Collected by Jedlix
- Your Freedom to Choose Your Smart Charging Services
- How Your Data is Collected, Processed and Shared
- Jedlix’ Partners
- Retaining and Deleting Personal Data
- Personal Data Necessary for Your Account Settings and Smart Charging Services
- Specific Personal Data Necessary for Generating Savings on Your Energy Bill
- Specific Personal Data Necessary for Generating Earnings in Partnership with Your Energy Supplier
- Specific Personal Data Necessary for Generating Earnings from Grid Balancing Service Providers in Eligible Countries
- Security Measures to Protect Your Data
- Your Rights
- Data Portability
- Contact Us
- Amendments to this Privacy Statement
1. The Purposes of the Personal Data Collected by Jedlix
Jedlix collects and processes your personal data to deliver its smart charging services (hereafter the “Services”). The purposes of the Services are:
- To help you save money on your electricity bill by charging your electric vehicle (EV) at times when the lowest electricity tariffs apply, typically during off-peak times.
- To generate earnings from your Energy Supplier by charging your EV at favourable times, for example when your Energy Supplier benefits from lower electricity purchasing costs, or when it needs to reduce an imbalance between the electricity consumption and production of its customers.
- To generate earnings from your national or regional grid operator by charging your EV at times when there is a need to reduce an imbalance in the levels of power consumption or production, thereby ensuring the stability and security of the grid.
More specifically, Jedlix will process your personal data to:
- Identify and verify its customers in collaboration with its automotive and energy partners.
- Calculate and implement an optimal charging plan for the EV(s) linked to your account.
- Provide proof to its energy partners of the smart charging services it delivers, thereby allowing it to claim and process any benefits.
- Calculate any smart charging benefits (both savings and earnings) and provide pay-outs for any earnings, assuming this is necessary under the terms of the contract between Jedlix and you.
- Offer customer support and answer any queries about Jedlix and Jedlix’ Services.
- Improve our Services by conducting research and development on people’s charging patterns and on the Services themselves.
2. Your Freedom to Choose Your Smart Charging Services
In the Jedlix App, you are free to choose whether you want to charge your car using Jedlix smart charging services. You are also free to choose whether you want to generate savings based solely on your energy tariffs, and/or to generate earnings through our Energy Suppliers partners, and/or to generate earnings by allowing us and our partners to provide balancing services to grid operators. You must provide your explicit consent for us to collect and process the necessary personal data related to each service so that we can deliver that service to you.
3. How Your Data is Collected, Processed and Shared
Your personal data is either collected from you directly when you provide information manually in the Jedlix App, or it is collected indirectly, from publicly available sources, or, with your explicit consent, it is collected from our partners in the energy and automotive industries.
We ask for your explicit consent in the Jedlix App for the right to collect and share the data necessary to deliver each smart charging service. Specifically, we ask for data regarding the historic load curve of your home meter for the relevant time period, as well as data to connect your home to the balancing services perimeter of the Balancing Service Providers (BSPs) we partner with. Our usage does not go beyond the stipulations of the energy code and regulations of your country of use. In the Jedlix App, you can decide whether or not to authorize Jedlix to access the data relevant to each particular service.
4. Jedlix’ Partners
In delivering its Services, Jedlix acts as the Data Controller for those Services. It also partners with several companies (Data Processors or Data Sub-processors, as the case may be) to enable the technical and financial operations of the Services. An up-to-date overview of the e-mobility stakeholders we partner with can be found here. These partners are:
- EV Manufacturers who have developed connected EV services to enhance the mobility experience of their customers. Our partnership with EV manufacturers allows us to offer our smart charging services.
- Energy Suppliers and the associated Balance Responsible Party (BRP) that your Energy Supplier uses to purchase electricity on the energy market (larger Energy Suppliers also often act as BRPs).
- Balancing Services Providers (BSPs). BSPs, also known as ‘aggregators,’ combine different electricity sources (large batteries, windmills, etc.) and make them available to the Transmission System Operator (TSO) or Electricity System Operator (ESO) responsible for maintaining the frequency of the high voltage energy grid in a specific country, province or state. To maintain a constant balance between the total consumption and production levels at high voltage levels, TSOs and ESOs manage open and regulated markets and mechanisms of grid balancing services. They procure flexible power capacity from BSPs to offset temporary imbalances provoked by excess consumption or production compared with the national or regional volume that they had forecasted. Jedlix and its BSP partners work together to offer the TSO or ESO flexibility when charging your EV, allowing you to earn benefits through smart charging, even when your Energy Supplier is not partnered with Jedlix. .
- Distribution System Operators (DSOs). DSOs are responsible for the load management and security of the energy grid in your local area. They are also responsible for managing the metering data of your home (for both your energy consumption and/or your energy production). In some countries, DSOs have developed secured data platforms that can be accessed by third-party service providers like Jedlix with the express consent of the home energy contract owner. In these cases, Jedlix uses these provisions to automatically collect the meter code for your home’s meter (in some countries this is called the EAN, MPAN or PDL code). Jedlix also collects some technical data concerning your energy contract, such as the power subscription of your home, the off-peak periods applicable to your metre, and your historic electric consumption indexes. Jedlix does this to comply with national open data regulations and to enable it to develop new digital energy management services.
5. Retaining and Deleting Personal Data
Jedlix only retains your personal data for as long as it is necessary for us to fulfil the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the data. We also consider the potential risk of harm from any unauthorized access to or disclosure of your personal data. In all matters, we take into account the purposes for which we process your data, and we consider whether we could achieve this purpose through any other means while still meeting all the necessary legal requirements.
For example, the GPS location of your EV is never stored by Jedlix, and this information is never shared with any other parties. This information is only used to verify whether or not the vehicle is at your designated smart charge location.
Details of your payments are kept as long as is necessary for us to comply with our legal and regulatory requirements. This is generally seven years unless the law prescribes a longer period.
6. Personal Data Necessary for Your Account Settings and Smart Charging Services
We collect the following data:
- Identity Data used to identify you. This includes your first name, last name, nickname, email address, and an encrypted version of your chosen password.
- Address Data used to determine your smart charge location. This includes your country, address, postcode and house number.
- Profile Data used to provide you with customized services. This includes the name of your Energy Supplier name, the make and model of your EV, your charging preferences and settings in the Jedlix App, and any information you provide in response to surveys or through customer feedback.
- Connected Car Account Data used to establish the connection with your EV. Depending on the make and model of your EV, this includes your Vehicle Identification Number (VIN), and/or your connected car credentials (this data is used only once to verify your account with the car manufacturer and retrieve an access token for our Services; your credentials are never stored by us). Jedlix also processes the data required for us to access the services provided by your car manufacturer which are needed for smart charging; you must authorize us to access this data on your behalf.
- EV Data used to calculate an optimal charging schedule for your EV and to monitor the performance of our smart charging Services. This includes information about your vehicle status, the state of charge of your battery, telemetry data, and information about your vehicle’s GPS location. We use this to make sure that we only smart charge your EV at the location you designate in the app. We validate this by measuring your energy consumption and telemetry data. We never store data about your EV’s GPS location.
- Pay-out Data used to pay earnings to you directly or through our partners. This includes your initials and your last name, the IBAN for your bank account, the amount to be paid to you, information about your charging data, and your contract number with your Energy Supplier.
- Technical Data used to improve our Services. This includes information about your mobile device type and Jedlix App version, time zone,country of use, browser type and version, operating system, mobile platform, and other information about the technology used by your device solely to access our Services.
- Tracking Data used to improve our Services. This includes information that we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
- Marketing and Communications Data used to communicate with you. This is based on your preferences for receiving marketing from us and our partners.
We share the following data:
- Connected EV Account Data shared with your EV manufacturer to allow us to connect your EV to the Jedlix App, if eligible for our Services. This allows us to optimize the smart charging schedule for your EV, and when necessary to investigate technical customer support issues.
7. Specific Personal Data Necessary for Generating Savings on Your Energy Bill
If you have a time-of-use/off-peak tariff with your Energy Supplier, regardless of whether or not it has a partnership with Jedlix in your country, then Jedlix may collect the following data:
Data that is collected if you are with a non-partnered Energy Supplier:
- Your kWh Tariff Information by periods of the day/week, which is usually indicated in your Energy Supplier bill, to calculate your savings and charge your EV using the lowest tariffs at off-peak times.
Data that is collected if you are with a partnered Energy Supplier:
- Your Energy Contract Number used to obtain information about the kWh tariff applicable to your energy contract directly from your Energy Supplier.
Data that is shared:
- Energy Contract Number and Address Data if your Energy Supplier partnered with Jedlix. This is used to validate the existence of your energy contract and, assuming the energy contract is validated, to automatically retrieve from the relevant information systems the applicable energy tariffs and off-peak times. This prevents Jedlix from having to ask you to fill in the same information manually in the Jedlix App.
8. Specific Personal Data Necessary for Generating Earnings in Partnership with Your Energy Supplier
Data that is collected:
- Your Energy Contract Number used to obtain information about the kWh tariff applicable to your energy contract directly from your Energy Supplier.
Data that is shared with your Energy Supplier:
- Identity Data, Energy Contract Number and Address Data is used to validate the existence of your energy contract and to allow you to generate earnings. With your explicit consent as the energy contract owner, your Energy Supplier can collect data on your historical electricity consumption from your smart meter.
- Energy Contract Number and EV Data used by your Energy Supplier to validate and arrange for any financial settlement with its BRP. This is also used to validate any generated earnings. It includes the energy consumption calculated from your EV’s telemetry data.
- Pay-out Data, in cases where the pay-out of earnings is handled by the Energy Supplier and the Energy Supplier has no access to the relevant pay-out data.
9. Specific Personal Data Necessary for Generating Earnings from Grid Balancing Service Providers in Eligible Countries
Data that is collected:
- Electricity Meter Point Data including the full name of the energy contract owner linked to the electricity meter point at the home charging location, as well as the electricity meter code (in different countries, this is known variously as the EAN, MPAN or PDL code). With your explicit consent, Jedlix will also collect the following data:
- Your historical electricity consumption data for the relevant meter point. This allows your designated grid operator to cross-validate the balancing effect of smart charging your EV with information related to the grid itself.
- Your explicit consent to link your meter point to the balancing perimeters of the relevant BSP, including the right to collect from your Energy Supplier, your DSO or the national meter data platform whether your home electricity meter point is under a profiled or smart meter allocation. This allows the BSP to deliver grid balancing services to the regional or national grid operator, thereby allowing you to generate earnings in accordance with the code and regulations for your specific grid.
Data that is shared with the DSO, and when necessary with your Energy Supplier:
- Address Data and Electricity Meter Point Data used to identify and validate the electricity meter point at your home charging location. This is also used to collect specific data from your meter, such as the relevant off-peak hours and your home electricity meter point allocation status (profiled or smart allocation) that need to be taken into account to deliver grid balancing services
Data that is shared with the BSP and the TSO or DSO:
- Electricity Meter Point Data used by the DSO or TSO to add your meter point to the relevant balancing perimeters of the BSP. This is also used to collect specific data from your meter, such as your historical electricity consumption data, and when necessary your home electricity meter point allocation status (profiled or smart allocation). This allows the relevant grid operator to cross-validate the performance of the grid balancing services and reach a financial settlement with the BSP
- EV Data used to cross-validate the performance of the grid balancing services and reach a financial settlement between Jedlix, the BSP, and the designated grid operator. This data is calculated by Jedlix on behalf of the BSP.
10. Security Measures to Protect Your Data
The security of your personal data is very important to us. Given the risks connected to processing personal data, we take all material, logical, administrative, and organizational steps necessary to secure your personal data. This ensures that your data is not misconstrued or damaged, and it guarantees that your data is not made available to any unauthorized third parties. These protections extend to the storage of your personal data on the secure servers issued by our provider.
Cookies are small parts of data that are not used for identification purposes but that learn about your usage and browsing behaviour based on how you interact with the Jedlix website and the Jedlix App.
12. Your Rights
You have the right to request Jedlix to access, modify, restrict, or remove your personal data.
13. Data Portability
Where Jedlix is processing your personal data based on the performance of a contract, you also have the right to data portability.
14. Contact Us
If you would like to ask any questions, submit any requests, or make any complaints regarding Jedlix’ processing of your personal data, you may do so via e-mail at firstname.lastname@example.org, or by writing to us at Jedlix B.V., Stationsplein 45, 3013 AK Rotterdam. Please address your enquiry to the Data Protection Officer.
If requested, Jedlix will share your personal data as a user in a digital format that you can be reasonably expected to be able to access. If necessary, Jedlix may request that you verify your identity as a user before releasing your data.
15. Amendments to this Privacy Statement
This privacy statement can be modified or adjusted at any time. In such a situation, you as a user will be notified at least two weeks in advance of any changes. You will also be notified via the Jedlix App once any changes go into effect.
Most recent version: October 2020