Privacy policy

BUZZ is committed to protecting and respecting your privacy rights. This Privacy Policy, which applies whether you use our website  www.buzzpowerbanks.nl  and the BUZZ mobile application, or contact us by telephone or email, provides you with information about:

What personal data do we collect;

How we use that personal data;

Disclosures of your personal data to third parties; and

The legal bases on which we rely to process your personal data.

For the purposes of this Privacy Policy, both the website and application shall be referred to as the “Platform”.

You do not need to take any action as a result of this Privacy Policy, but you may have certain legal rights as described below.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

This Platform is not intended for children and we do not knowingly collect or solicit data relating to children.

This Privacy Policy is intended to provide you with the information required by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Dutch data protection laws.

  1. IMPORTANT INFORMATION AND WHO WE ARE

BZZZ BV (referred to in this Privacy Policy as “BUZZ”, “we”, “us” and “our”) is the “data controller” of your personal data. BZZZ BV is registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under number 89649656, with its registered office at Haarlemmermeerstraat 168-1. In simple terms, this means that we: (i) “control” your personal data, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or are otherwise permitted by law.

How to contact us or make complaints

If you have any concerns or questions regarding our use of your personal data (including any requests to exercise your legal rights) or this Privacy Policy please contact charging@buzzpowerbank.com 

Our full contact details are:
Email:charging@buzzpowerbank.com 

 

Postal address: Haarlemmermeerstraat 168-1, 1058 KK, Amsterdam

You also have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority). You can find their contact details on their website.

 

BZZZ BV has not appointed a data protection officer (“DPO”) as it is currently not required to do so under Article 37 GDPR given the nature and scope of our processing activities. All privacy-related queries may be addressed to us using the contact details above. 

Changes to this privacy policy and your personal data

This Privacy Policy is regularly reviewed and was last updated on December 29, 2023. We may amend or update our Privacy Policy from time to time. We will provide you notice of amendments to this Privacy Policy and update the “last updated” date.

It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.

  1. THE PERSONAL DATA THAT WE COLLECT ABOUT YOU

The types of personal data we collect, use and store about you will depend on the product or service you have requested from us and/or the nature of your interaction with us. When using the Platform, we collect and process the following types of personal data:

your name, phone number, email address and limited credit/debit card details necessary to process your payment;

personal, device and business contact information (such as your email address, mobile number and IP address);

login and account information (including mobile number, password and unique user ID);

location data (including the location, date and time a power bank was hired and returned and places and preferences that you submit);

payment or credit card information;

technical information (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, the type of mobile browser you use and time zone setting);

your communication and marketing preferences;

your interests, preferences, feedback and survey responses;

other personal data that you submit to us, such as information you provide to register for email alerts or correspond with us in relation to inquiries; and

other publicly available personal data, including any that you have shared via a public platform (such as a Twitter feed or public Facebook page).

The Platform is not intended for children, and we do not knowingly collect or solicit personal data from anyone under the age of 16.

We do not collect any special category personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. HOW WE OBTAIN YOUR PERSONAL DATA

Information you provide to us:
We collect information about you directly that you provide to us via the Platform in online forms and conversations and in other correspondence (including via email and telephone).

Information we get from other sources:

We will automatically collect data from you accessing the services via the Platform (including if you register as a user of the Platform, subscribe to any service or upload or submit any material via the Platform). This information includes information relating to your device, as well as location information (if you have permitted us to collect such information).

We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and will notify you when we receive information about you from them, the purposes for which we intend to use that information and the legal bases for doing so. We also collect personal data from publicly available sources.

In connection with an employment inquiry, we collect data from third parties regarding your work authorisation status, education history, employment history and professional designations, and other information about your qualifications.

We may combine personal data that you provide to us with information that we collect from, or about you, in some circumstances. This will include information collected in an online or offline context.

Where we receive personal data about you from third parties (for example, payment providers, analytics providers or publicly available sources), we will provide you with the information required by Article 14 GDPR within the timeframes set out therein, including the categories of personal data concerned, the source of the data and the purposes for which we use it.

  1. HOW WE USE YOUR PERSONAL DATA

We will use your personal data for the following purposes, and pursuant to the corresponding legal bases:

To enter into, and perform, contracts with you that you have requested, including sending you welcome and periodic emails that provide details on how to use our service and the mobile application and regarding the administration of your account (e.g., updating payment card details); building a profile of your preferences so that we can ensure our services are provided when you need them; processing payments for the services we provide; and processing payment of fees to use the power banks.

Performance of a contract with you

To track your pickup and drop off locations and where the nearest power banks to you are.

  1. a) Performance of a contract with you
  2. b) Necessary for our legitimate interests (to track the power banks that we own).

To manage our relationship with you, including 

(a) notifying you about changes to our terms of service to this Privacy Policy,

(b) communicating with you in relation to your account, your rentals and other service-related matters; and

(c) inviting you to leave a review or participate in a survey.

Legal bases:

– for the processing activities under above mentioned (a) and (b): the processing is necessary for the performance of the contract to which you are a party and, where applicable, for compliance with our legal obligations to provide information to consumers and data subjects.

– for the processing activity under above mentioned (c): the processing is necessary for our legitimate interest in monitoring, maintaining and improving our services and customer experience. You have the right to object at any time to processing based on our legitimate interest as described in Section 6.

To improve the Platform and products and services that we offer, including recognising when there is a higher demand for our services; tailoring our Platform to the needs of all users; recommending options that match any stated preferences; and notifying you about changes to our services.

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

To enable us to manage customer service interactions with you.

Necessary for our legitimate interests (to understand how our customers use our products and services and improve our business).

To keep a record of your relationship and purchase history with us.

Necessary for our legitimate interests.

To verify your identity and to identify and prevent fraudulent transactions.

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

No automated decision making, including profiling, is used when processing your personal data.
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, as described in this Policy, and to comply with our legal and contractual obligations. This means that, for example, account information and profile data are kept for the duration of your account being active. If you delete your account (or it is terminated), we will either delete or anonymize your personal data within a reasonable period after account deletion, in accordance with Section 8 of this Privacy Policy. In all cases, we periodically review the data we hold and erase or anonymize personal data when the legal basis for it no longer exists. 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us or purchased products or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have expressly consented to receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside BUZZ for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at support@debzzz.nl

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions (which we will continue to process in order to perform a contract with you or as a result of our regulatory or legal obligations).

Where we rely on your consent to process your personal data for direct marketing purposes, you may withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You may do so by following the unsubscribe instructions in our marketing communications or by contacting us at support@debzzz.nl

  1. WHO WE SHARE YOUR PERSONAL DATA WITH

We will disclose your personal data with third parties if required to do so by law or regulation.

We will also share your personal data with the following categories of recipients, strictly as necessary for the purposes set out in this Privacy Policy:

(a) Payment service providers and financial institutions, in order to process payments and handle refunds and chargebacks.

(b) IT and system administration service providers, including providers of hosting, cloud storage, analytics, communication and customer support tools.

(c) Professional advisers, including lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services to us.

(d) Affiliates and group companies of BUZZ (if any), where this is necessary for internal administrative purposes or to provide our services to you.

(e) Third parties in connection with a business transaction, such as in the context of a merger, sale or transfer of (part of) our business, provided that appropriate safeguards are in place.

In each case where we share your personal data with third parties who process personal data on our behalf, we enter into data processing agreements that meet the requirements of Article 28 GDPR, and we require such parties to keep your personal data confidential and secure. We do not sell your personal data to third parties. 

  1. YOUR DATA PROTECTION RIGHTS

Right of access: You have the right to ask for a copy of the personal data that BUZZ holds about you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive or manifestly unfounded, to help us cover the costs of locating the information you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month, unless an extension is permitted by law.

Right to rectification: If there are any inaccuracies in the information we hold about you, please contact us and we will correct them.

Right to erasure: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Right to restriction of processing: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal data, override your own rights.

Right to object: You have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request the transfer: If you wish to transfer your personal data to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdrawal consent: If you previously gave us your consent to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights by contacting us using the contact details set out in Section 1. You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens as described in Section 1.

  1. COOKIES

Our website uses cookies. A cookie is a small file of letters and numbers stored by computer after being sent to your computer when you visit a website. Whenever you visit the same website again, the information stored in the cookie can be retrieved to notify the website of your previous activity. We use cookies to facilitate website navigation, maintain quality of online service, provide additional security, allow the customisation of your access to the website, and remember you when you return to the website.

We only use cookies or similar technologies that are not strictly necessary for the functioning of our website or app (such as certain analytics or advertising cookies) with your prior consent. When you first visit our website or app, we will present you with a cookie banner explaining the types of cookies we use and asking you to make a choice. You can give or withhold consent separately for different categories of cookies where applicable, and you can withdraw your consent at any time via the cookie settings on our website or app. 

A cookie cannot give us access to your computer or to information beyond what you provide us, and we don’t store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the website.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off/on certain cookies. You do this through your web browser settings. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookie settings. Please note that if you disable or refuse cookies, some parts of the website or app may become inaccessible or may not function properly, but we will not condition access to our services on your consent to non-essential cookies.

When you visit our website, you may notice some cookies that aren’t related to BUZZ. If you go on to a web page that contains embedded content you may be sent cookies from these websites. We don’t control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

  1. HOW LONG WE KEEP YOUR PERSONAL DATA

We will not retain your personal data for longer than is necessary for the purposes of satisfying any legal, accounting or reporting requirements. In particular: 

(a) Account information (such as your name, contact details and login credentials) is retained for as long as your account is active. After you close your account, we will retain this information for a period up to two (2) years, unless we are required by law or have a legitimate interest to retain it for a longer period.

(b) Transaction and rental information (such as details of your power banks rentals and payments) is retained for as long as necessary to provide the relevant service and thereafter for a period of seven (7) years in order to comply with our legal obligations under applicable tax and bookkeeping law, unless we are required by law or have a legitimate interest to retain it for a longer period.

(c) Marketing information (such as marketing preferences and a record of your consents) is retained for as long as you remain subscribed to our marketing communications and for a reasonable period thereafter to document that we have complied with your request.

Where personal data are no longer required for the purposes for which they were collected and no legal obligation or legitimate interest requires further retention, we will delete or anonymise the data in a secure manner.

  1. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

 

  1. GLOSSARY

“Personal data”

means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (‘anonymous data’).

“Legitimate interest”

means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

“Performance of a contract”

means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation”

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

If you have any questions, please contact our support team charging@buzzpowerbank.com