VOLTA AUTOMOTIVE
PRIVACY AND COOKIE POLICY
‍

Introduction
1.1
This is the privacy and cookie policy of Volta Automotive Limited, a company registered in Scotland under company number SC857073 with its registered office at 15 Tollbraes Road, Bathgate, Scotland, EH48 2SH(we, us or our). We are the controller responsible for your personal data.
1.2
This website and our services are not intended for children under 16, and we do not knowingly collect data relating to children.
1.3
We comply with our obligations under the DataProtection Act 2018 and the EU law retained version of the General Data Protection Regulation ((EU) (2016/679). If any of these laws are replaced or superseded, we will also comply with those.
1.4
We are registered with theInformation Commissioner's Office (ICO), the UK supervisory authority for data protection issues,and our registration number is ZC026923. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. For data protection matters, please email us at kevin.mckay@volta-automotive.co.uk.
1.5
We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data.
1.6
This policy applies when you visit our website, contact us, book or take an Aviloo Flash or Aviloo Premium test, receive a test certificate, purchase other assessment services, or other wise interact with us.
The data we may collect about you
2.1
Personal data/information means any information about an individual from which that person can be identified. It does not include anonymous data.
2.2
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a)
Identity Data includes your name, title, and, for certain bookings, photographic ID(e.g. driving licence photo) and address verification (e.g. utility bill photo)required for Aviloo Premium tests.
(b)
Contact Data includes home address, billing address, email address and telephone number
(c)
Vehicle Data includes information about your vehicle such as registration number, VIN, make, model, manufacturing year and, where applicable, diagnostic and battery information (for example, battery size and model codes). This information is treated as personal data where it can be linked to you or your vehicle.
(d)
Financial Data includes bank account and payment card details.
(e)
Transaction data includes details about payments to and from you and other details ofthe goods and services you have purchased from us.
(f)
Technical Data includes internet protocol (IP) address, your login data, time of access, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
(g)
Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
(h)
Usage Data includes information about how you use our website and services.
(i)
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
(j)
Aggregated Data such as statistical or demographic data for any purpose, is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
(k)
Special Category Data means special categories of personal data and includes information about your health, race or ethnicity, criminal convictions, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data. Please note that we do not automatically include any such data.
How is your personal data collected?
We may use different methods to collect data from and about you including through:
3.1
Direct interactions. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise.This includes personal data you provide when you:
(a)
visit our website;
(b)
contact us;
(c)
book or take an Aviloo Flash or Aviloo Premium test;
(d)
receive a test certificate;
(e)
purchase other assessment services, or otherwise interact with us;
(f)
apply for our products or services;
(g)
request marketing to be sent to you;
(h)
enter a competition, promotion or survey; or
(i)
give us feedback or contact us.
3.2
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies including third-party website tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We also receive limited test telemetry and booking metadata fromAviloo GmbH to enable diagnostic analysis and certificate generation.
3.3
Third parties or public services. We may collect personal data about you from public sources, such as Google, CompaniesHouse, or the electoral register. We may also receive data from payment processors (NatWest Tyl), courier/logistics providers, our web-hosting platform(Webflow) or booking system (Airtable), email and cloud service provider(Google Workspace), and social media or marketing platforms where you interact with us.
How we use your personal data
4.1
We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:
(a)
Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
(b)
Legitimate Interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
(c)
Legitimate Obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
(d)
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter
4.2
We do not carry out solely automated decision-making that produces legal or similarly significant effects.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of yourpersonal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Use / Purpose
Type of Data
Lawful basis for processing including basis of legitimate interest
To enable you to submit an enquiry to us, whether via email, through our website or via social media, including but not limited to LinkedIn, Facebook and Instagram
Identity

Contact

Vehicle
1. Contract
2. Necessary for our legitimate interests (to enable us to respond to your enquiry)
To book and carry out Aviloo Flash and Premium battery tests, analyse test results and issue certificates
Identity

Contact

Vehicle
1. Contract
2. Necessary for our legitimate interests (to perform and deliver the requested test service)
To verify customer identity and address for Aviloo Premium tests and to protect equipment sent for hire or collection
Identity

Contact

Vehicle
1. Contract
2. Necessary for our legitimate interests (to prevent fraud and protect company assets)
To arrange delivery and collection of Aviloo BOX devices for Aviloo Premium tests
Identity

Contact

Vehicle
1. Contract
2. Necessary for our legitimate interests (to coordinate safe delivery and return of equipment)
To enable you to sign up to or use our services, or purchase goods from us, including:
‍
(a) Manage payments, fees, and charges
‍
(b) Collect and recover money owed to us
Identity

Contact

Transaction

Marketing and Communications
1. Contract
2. Necessary for our legitimate interests (to enable us to recover debts due to us)
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms and conditions or this privacy and cookies policy

(b) Dealing with your requests, complaints, and queries
Identity

Contact

Profile

Marketing and Communications
1. Contract
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
To enable you to register for our mailing list/email marketing
Identity

Contact

Marketing and Communications
Necessary for
our legitimate interests (to carryout direct marketing, develop our products/
services and grow our business)
To enable you to partake in a prize draw, competition or complete a survey
Identity

Contact

Usage

Profile

Marketing and Communications
1. Contract
2. Necessary
  for our
  legitimate
  interests
  (to study how customers use our products/
  services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity

Contact

Technical
1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity

Contact

Technical

Usage

Profile

Marketing and Communications
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 use data analytics to improve our website,services, marketing, customer relationships and experiences
Technical

Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Identity

Contact

Technical

Usage

Profile

Marketing and Communications
Necessary for our legitimate interests (to carryout direct marketing, develop our products/services and grow our business
To carry out market research through your voluntary participation in surveys
Identity

Contact

Technical

Usage

Profile

Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
Direct marketing
6.1
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
6.2
We may also analyse your Identity Data,Contact Data, Technical Data, Usage Data and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
6.3
Marketing may include information about AvilooFlash and Premium tests, service updates and special offers. We will only send electronic marketing where you have given consent or where we can rely on legitimate interests for B2B communications.
Third party marketing
7.1
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
7.2
We do not sell or rent customer data to other organisations. Where we use marketing or analytics platforms (for example Meta or LinkedIn for re-marketing audiences), any matching or profiling is carried out in accordance with applicable privacy settings and consent mechanisms.
Opting out of marketing
8.1
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at kevin.mckay@volta-automotive.co.uk.
8.2
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our terms and conditions and checking that your contact details are correct.
Cookies
9.1
Our website uses cookies and similar technologies to distinguish you from other users, help us improve the website and show advertising according to your interests. We use a cookie-consent manager to obtain your preferences before setting any non-essential cookies.
9.2
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Some emails and pages contain a tiny graphic file that lets us see when you open a message or visit a page. Web beacons work together with cookies; if you disable cookies, they may stop working.
9.3
We display a cookie banner the first time you visit, allowing you to accept or reject non-essential cookies.
9.4
We use the following cookies:
(a)
Strictly necessary cookies. These are cookies that are required for the operation of our website. Theyinclude, for example, cookies that enable you to log into secure areas of ourwebsite, use a shopping cart or make use of e-billing services.
(b)
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We use Google Analytics, a web-analytics service provided by Google that tracks and reports website traffic. This service uses cookies to collect information about how users interact with our website, including the number of visitors, pages visited, duration of visits and referral sources (for example, search engine, direct link or referral from another website). This helps us understand our audience and improve the website experience. Google Analytics is configured with IP anonymisation where required, and analytics data is aggregated and retained for 14–26 months depending on configuration.
(c)
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d)
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.
9.5
When you first visit, a cookie banner lets you accept, reject or customise non-essential cookies. You can change your choices at any time by clicking “Cookie Settings”in the website footer. Most browsers also let you block or delete cookies through their settings; see www.allaboutcookies.org for instructions.
Disclosures of your personal data
10.1
We may disclose your information in the following cases:
(a)
We can disclose your personal data to our staff members and our subcontractors in order to facilitate the provision of services to you.
(b)
We can disclose your personal data to whom we may choose to sell, transfer or merge parts of our business or our assets.Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
(c)
We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006.
(d)
We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights.
(e)
We can exchange information with others to protect against fraud or credit risks.
10.2
We use a variety of third party services(sub-processors) as part of our business activities and you/we will therefore share your personal data with these sub-processors. The types of sub-processors we might use fall into different categories, as follows:
(a)
Payment processing services;
(b)
Booking system;
(c)
Order fulfilment service providers;
(d)
Courier and logistics providers;
(e)
Analytics service providers;
(f)
Event/campaign management service providers;
(g)
Website management service providers;
(h)
Information technology and related infrastructure provision;
(i)
Email delivery services; and
(j)
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
10.3
In particular, the sub-processors we use are:
(a)
Aviloo GmbH for platform and test processing, which is an independent controller for its own processing, as detailed in section 10.4 below;
(b)
NatWest Tyl for payment processing;
(c)
Airtable for booking management;
(d)
Google Workspace / Gmail and Google Drive for email, calendar and document storage; and
(e)
Webflow for website hosting and management;
10.4
Aviloo GmbH as a separate controller
(a)
Aviloo GmbH (IZ NÖ Süd, Straße 16 Objekt 69,2355 Wiener Neudorf, Austria; business.info@aviloo.com acts as a separate data controller for certain processing activities carried out when you book and take Aviloo Flash or Aviloo Premium tests.
(b)
Aviloo processes personal and technical test data collected through the Aviloo Box and its platform, including vehicle diagnostic telemetry, GPS location traces, VIN, manufacturing year, battery size (kWh), and model codes required to analyse battery condition and issue certificates.
(c)
Aviloo may also require limited shipping-coordination details for Aviloo Flash or Aviloo Premium tests deliveries and collections.
(d)
For information on Aviloo’s processing, lawful bases, retention and how to exercise your rights in relation to Aviloo’s processing, please consult its privacy policy or contact business.info@aviloo.com.
(e)
You may exercise your data-protection rights with either controller for the processing they perform. If you are unsure which controller to contact, email us at kevin.mckay@volta-automotive.co.uk and we will assist.
10.5
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data security
11.1
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect.
11.2
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11.3
Where we use third-party providers such asAviloo, Google Workspace or Webflow, we rely on their certified security frameworks and contractual obligations to ensure adequate protection.
11.4
If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.
11.5
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.
International transfers
12.1
We may transfer your personal data outside of the UK or the European Economic Area (EEA) where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a)
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
(b)
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the UK International Data TransferAddendum to the European Commission’s standard contractual clauses for international data transfers.
12.2
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
Data retention
13.1
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
13.2
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.
13.3
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
13.4
We apply the following typical retention periods:
(a)
Booking records, test results and Aviloo certificates: 7 years;
(b)
Website contact form submissions: 2 years after last contact or resolution;
(c)
Verification documents (for Aviloo Premium tests, such as driving licence or utility bill): retained only as required for identity and address verification and fraud prevention, up to a maximum of 12months;
(d)
Payment metadata (excluding full card details): 6–7 years for accounting and dispute-handling purposes;
(e)
Courier and delivery records (Premium service deliveries and proof of delivery): retained for 12 months unless required longer for warranty or dispute resolution;
(f)
Email provider caches and mail archives(Google Workspace): retained per provider policy; exports or deletions available on request;
(g)
Logs, diagnostics and analytics data:typically 90 days for operational logs and 12 months for aggregated or anonymised logs;
(h)
Backups and archives: retained per backup policy (for example, 90-day rolling backups and up to two years’ archive retention); and
(i)
Marketing consents and preferences: retained while consent is valid and for a reasonable audit period (typically 2 years).
13.5
In some circumstances you can ask us to delete your data: see section 14 below for further information.
13.6
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
14.1
You have a number of rights under data protection laws in relation to your personal data. You have the right to:
(a)
Request access to your personal data (commonly known as a "subject access request").This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
(b)
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c)
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d)
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
(e)
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in section 8 for details of how to object to receiving direct marketing communications).
(f)
Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
(g)
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 5 for details of when we rely on your consent as the legal basis for using your data). 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.
(h)
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
i.
If you want us to establish the data's accuracy;
ii.
iWhere our use of the data is unlawful but you do not want us to erase it;
iii.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
iv.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
14.2
If you wish to exercise any of the rights set out above, please contact us at kevin.mckay@volta-automotive.co.uk.
14.3
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.Alternatively, we could refuse to comply with your request in these circumstances.
14.4
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14.5
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Changes to this privacy and cookies policy and your duty to inform us of changes.
16.1
We keep our privacy policy under regular review.
16.2
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.