Privacy Notice

1. Important information about this privacy notice

This privacy notice was last updated on 03 June 2024.

About this notice

In this privacy notice, we aim to give you information on how e:PROGRESS collects and processes your personal data, including when you subscribe for and use the e:PROGRESS Intelligent Charging Service, the e:PROGRESS App and also this website.

This notice is limited to the data processing carried out to provide you with e:PROGRESS. However, please note that the same data, such as your user profile and vehicle information, may be needed and used by Honda for other purposes, such as to provide you with the MyHonda+ App, as described in the MyHonda+ Privacy Policy. Please refer to that policy for an explanation of Honda’s other uses of your personal data.

e:PROGRESS is not intended for children and we do not knowingly collect data relating to children.

It is really important that you read this privacy notice together with any other privacy 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.

‍Who we are

e:PROGRESS is an end-to-end service operated by Lunar Energy Limited (“Lunar Energy“) and established by Honda Motor Europe Limited (“Honda“) (together, “e:PROGRESS” or “we” or “us”).

The main element of e:PROGRESS is the “e:PROGRESS Intelligent Charging Service” which is a smart charging service provided to you by Lunar Energy. Lunar Energy is therefore a controller of your personal data.

Honda operates the e:PROGRESS website (https://www.honda-eprogress.co.uk).

The smart charging service works with the “e:PROGRESS App”, which allows you to set your charging preferences and check your charge progress. This app is provided to you by Honda who is also therefore a controller of your personal data.

This notice explains how Lunar Energy and Honda process your personal data to provide you with e:PROGRESS.

In section 5 we set out in more detail the activities which Lunar Energy and Honda carry out to provide you with e:PROGRESS.

So that you have a clear point of contact, we have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data privacy manager using the contact details set out below:
Email: GDPR@honda-eu.com

Third party services required by e:PROGRESS

Lunar Energy works with other parties who provide you the services required for e:PROGRESS to work. Each of these other parties is a controller of your personal data in relation to the relevant element of e:PROGRESS. These parties are:

Please review the privacy policies of Pod Point to understand how they may process your personal data to provide you with their            services.

2. Information that e:PROGRESS collects

In this privacy notice, when we talk about personal data or personal information, we’re referring to any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data). We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows (the purposes for which we use this data are set out in section 5):

The e:PROGRESS 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 information 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 notice of every website you visit.

We often use aggregated data to provide insights that are commercially valuable to us because, for example, they give us insights into how customers use our services or the ways in which we can improve our services. Aggregated data is derived from the data described above, which is anonymised such that we are unable to identify any individual, and we combine this information with other non-personal data.

‍What happens if you don’t provide personal data

If we need to collect personal data by law, or to enter into or perform a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to ensure that your intelligent charging subscription is working correctly). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

The data which we need to enter into or perform a contract with you is set out in the table in section 5 (below).

3. How e:PROGRESS collects your personal information

We use different methods to collect information from and about you including through:


4. How e:PROGRESS uses your personal information

We need to collect your information so that we can tell you about our services where you request us to do so, provide services to you, improve these services and manage the accounts of all our customers.  This includes creating statistics and carrying out data analysis. Section 5 contains a more detailed description of the purposes for which Lunar Energy and Honda process your data in the context of e:PROGRESS.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

5. Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. The table also explains whether Lunar Energy or Honda carries out each activity.

Party which carries out the activity Purpose/Activity Type of information Lawful basis for processing including basis of legitimate interest
Lunar Energy and Honda To communicate with you about the goods and services you have ordered or where you have requested such information (e.g. through a dealership) (a) Identity (b) Contact (c) Transaction (d) Contract (e) Content of communications Performance of a contract with you
Lunar Energy and Honda To respond to queries you send us (a) Identity (b) Contact (c) Content of communications Necessary for our legitimate interests (to provide a good customer experience)
Lunar Energy To assist you with the process of arranging installation services using our recommended third party chargepoint installer (a) Identity (b) Contact (c) Content of communications Performance of a contract with you
Lunar Energy To register you as a new customer of the e:PROGRESS Intelligent Charging Service (a) Identity (b) Contact (c) Contract Performance of a contract with you
Honda To register you as a user of the e:PROGRESS App (a) Identity (b) Contact (c) Contract Performance of a contract with you
Lunar Energy and Honda To provide you with e:PROGRESS and administer our contract with you, including the e:PROGRESS Intelligent Charging Service and the e:PROGRESS App. This includes sending you service communications. (a) Identity (b) Contact (c) Usage (d) Technical (e) Content of communications Performance of a contract with you
Lunar Energy To manage payments, fees and charges (Payments to us are processed by our payment services providers, Stripe, who may also process your data as an independent controller, in accordance with its privacy policy. Please refer to the “Payments” section below this table for more information.) (a) Identity (b) Contact (c) Financial (d) Transaction (e) Contract (f) Content of communications Performance of a contract with you
Lunar Energy To collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Contract (f) Content of communications Necessary for our legitimate interests (to recover debts due to us)
Lunar Energy and Honda To administer our relationships with dealerships (a) Identity (b) Contact (c) Applications Necessary for our legitimate interests (to offer our products and services and maintain our relationships with dealers)
Lunar Energy To notify you about changes to the e:PROGRESS Intelligent Charging Service terms (a) Identity (b) Contact (c) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation
Lunar Energy To notify you about changes to the e:PROGRESS App terms (a) Identity (b) Contact (c) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation
Lunar Energy and Honda To notify you about changes to this privacy notice (a) Identity (b) Contact (c) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation
Lunar Energy To enable you to leave a review or complete a survey (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Content of communications Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Lunar Energy and Honda To administer and protect our business and the e:PROGRESS Intelligent Charging Service and App (a) Identity (b) Contact (c) Financial (d) Transaction (e) Contract (f) Technical 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)
Lunar Energy To administer and protect the e:PROGRESS website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical 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)
Lunar Energy To deliver relevant content and advertisements to you and measure or understand the effectiveness of the content and advertising we serve to you on the e:PROGRESS website (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical Consent
Lunar Energy To use data analytics to improve: (i) the e:PROGRESS Intelligent Charging Service, including the customer experience; (ii) the e:PROGRESS website; and (iii) marketing relating to e:PROGRESS (a) Technical (b) Usage Where we use tracking technologies such as cookies – Consent Where we do not use tracking technologies – Necessary for our legitimate interests (to provide a good service, a good customer experience, and effective marketing)
Lunar Energy and Honda To tell you about and make suggestions and recommendations to you about e:PROGRESS goods or services that may be of interest to you (other than service communications) (a) Identity (b) Contact (c) Technical (d) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business) With respect to electronic direct marketing, unless you are an existing customer of e:PROGRESS and you have not opted out of receiving such marketing, we will only send you such marketing if you have given us consent
Lunar Energy and Honda To tailor our e:PROGRESS marketing communications to you, based on our understanding of your interests and needs (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications Where we use tracking technologies – Consent Where we do not use tracking technologies – Necessary for our legitimate interests (to provide you with relevant marketing information)
Lunar Energy and Honda To provide ongoing technical support services (a) Identity (b) Contact (c) Usage (d) Technical Performance of a contract with you
Lunar Energy and Honda To help secure and to provide you with access to e:PROGRESS’s services (a) Identity (b) Contact (c) Technical Performance of a contract with you
Lunar Energy and Honda To sell, transfer, or merge parts of our business or our assets, or to obtain financing All data described in this notice Necessary for our legitimate interests (to ensure the viability and profitability of our business)

 

Payments

Payments to us are processed by our payment services providers, Stripe.

To provide this service, Stripe will process information about your payment method (such as credit or debit card number, or bank account information), purchase amount, and date of purchase. This may include your payment card number, CVC code and expiration date. We do not normally have access to this data although we do receive statements of payments made to us which would include data such as the transaction reference and the amount paid.

Note that Stripe may also process your personal data for other purposes as an independent controller, in accordance with Stripe’s Privacy Policy. These may include: anti-fraud activity; back-end verification and compliance activity (e.g., KYC requirements, relationships with financial partners and regulators, AML and sanction screening); and improving Stripe products and services. We have no control over such processing and we recommend that you review Stripe’s privacy policy. If you have any queries or concerns about the processing carried out by Stripe, please contact them directly using the contact details in their privacy policy.

Payment card providers such as VISA and Mastercard, as well as card issuing banks may also process data in the course of processing payments. These would act as controllers therefore the data processing they carry out will be governed by their own respective privacy policies

Cookies

With the exception of cookies which are necessary to provide you with the service you have requested, including in particular the e:PROGRESS website, we will only use cookies and similar tracking technologies if you give us consent, which you may freely refuse or withdraw at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the e:PROGRESS website may become inaccessible or not function properly.

For more information about the cookies we use and how to withdraw your consent, please see our cookie policy.

Change of purpose‍

We will only use your personal information for the purposes for which we collected it, specifically the purposes set out in the table above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We will inform you about any such processing by updating this privacy notice and we will provide you with an explanation as to how the processing for the new purpose is compatible with the original purpose.

We will only use your personal information for an unrelated purpose if you have given us your consent to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosure of your Personal Information

We may have to share your personal information with the parties set out below for the purposes set out in the table above (see section 5).

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

7. International transfers

Honda may transfer your personal data to Japan. Japan is deemed to provide an adequate level of data protection by the European Commission and the UK Government.Our payment processors, Stripe, use data processors based in the United States to provide their services. Therefore, when you make payments to us, the data which is needed to process those payments may be transferred to and processed in the United States. Stripe transfers data to the U.S. on the basis of standard contractual clauses (issued by the EU Commission and applicable under UK law) which provide appropriate safeguards for the data which is transferred. You can find more information about this on Stripe’s website.

Lunar Energy CRM and marketing services provider, Salesforce, may transfer personal data outside of the UK or the EEA (See Salesforce Locations) to provide its services. This data is transferred on the basis of Salesforce’s binding corporate rules which are approved by the competent supervisory authorities and provide appropriate safeguards for the data which is transferred. In cases where the binding corporate rules do not apply, standard contractual clauses (as described in the previous paragraph) are used.

Lunar Energy also uses Google Analytics, which involves data being transferred to the United States. Such transfers are made on the basis of standard contractual clauses, as described above.

Otherwise, we do not transfer your personal data outside of the UK or the European Economic Area (EEA).

8. How does e:PROGRESS keep your Personal Information secure?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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.

9. How long does e:PROGRESS retain your Personal Information?

We will only retain your personal information for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 of our relationship with you.

Generally, unless the data is needed to provide you with another service (for example, if you use the MyHonda+ service, Honda will continue to process your MyHonda+ profile to provide you with that service), we will retain your data for the periods set out in the list below. The list describes specific retention periods for each category of data described in section 2.

Category of data Retention period
Identify information 6 years from the end of your subscription unless you have not subscribed for e:PROGRESS in which case we will retain it for 2 years from the date of your enquiry.
Contact information 6 years from the end of your subscription unless you have not subscribed for e:PROGRESS in which case we will retain it for 2 years from the date of your enquiry.
Content of communications If you make a complaint or if your communication may be relevant to a potential claim, the data will be retained for 6 years from when the issue is finally resolved. Otherwise, we will retain it for 2 years.
Applications and contracts 6 years from the end of your subscription.
Service eligibility information Until the end of your subscription.
Usage information 2 years from the end of your subscription.
Technical information (Your computer or mobile device information) Except for essential cookies, all cookies will expire after 180 days. 6 years from the end of your subscription unless you have not subscribed for e:PROGRESS in which case we will retain it for up to 26 months from the date of your visit.
Technical information (Your chargepoint) Most of this data will be retained for 6 years from the end of your subscription. This is because it may be needed to deal with potential claims. If specific items of data forming part of this category are not needed for claims, we will retain such data for 2 years from the end of your subscription or, if you do not have a subscription, from the date of your enquiry.
Technical information (Your vehicle) 2 years from the end of your subscription.
Financial information Until the end of your subscription.
Transaction information 6 years from the end of your subscription.
Marketing and communications 2 years from the end of your subscription.

There may be exceptions in specific situations, for example, if the data is relevant to an ongoing dispute or if we are required to retain it by law.

10. Your Rights

Data protection laws give you certain rights in relation to your personal data which you can exercise under certain circumstances. To help you understand your rights, we’ve included information which you can access by clicking on the links below. If you’d like more information on your rights, please visit the ‘Your Data Matters’ campaign on the ICO’s website: www.ico.org.uk/your-data-matters

Please note the following:

In addition, you may request an explanation of the data protection arrangements between Lunar Energy and Honda by contacting our data privacy manager.

‍No fee usually required

‍You will not have to pay a fee to access your personal information (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 may refuse to comply with your request in these circumstances.

‍What we may need from you

‍We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

‍Time limit to respond

‍We try to respond to all legitimate requests within one month. Occasionally it may 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.

11. Contacting e:PROGRESS

You may contact us at any time by sending an email to enquiries@honda-eprogress.co.uk or by telephoning 0330 223 5339. Our support team are available between 9.30am and 6pm on weekdays (excluding Bank Holidays). e:PROGRESS aims to respond any request within 3-5 business days.

If your query relates to the processing of your personal data, you may also contact our data privacy manager using the contact details set out below:
Email: GDPR@honda-eu.com

12. Your right to make a complaint

If you have a concern or complaint about how we use your personal information, please contact us using the details in ‘Contacting e:PROGRESS’ above.

You can also raise any concerns or complaints you have about how we use your personal information with your local supervisory authority. In the UK, this is the Information Commissioner’s Office (the ICO) and you can contact them by calling 0303 123 1113 or via the ICO’s live chat function available here https://ico.org.uk/make-a-complaint/.

13. Privacy Policy Information

e:PROGRESS reserves the right to modify this Privacy Notice at any time. If e:PROGRESS makes changes to this Privacy Notice, the updated Privacy Notice will be posted online via https://www.honda-eprogress.co.uk.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

    Stay informed

    If you are interested in learning more about the e:PROGRESS app, our home EV chargers, new offers or the incredible savings available, please enter your email below.

    Opt-in to receive additional marketing communication via email about e:PROGRESS from Lunar Energy Ltd. You can withdraw your consent at any time by contacting enquiries@honda-eprogress.co.uk or calling 0330 223 5339.