1. Important information about this privacy notice
This privacy notice was last updated on 20 November 2023.
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.
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.
Lunar Energy also 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 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:
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:
– British Gas, which provides you with the electric vehicle charger and its installation;
– Octopus, which provides you with electricity; and
– Vattenfall, which provide charge-point operator services in relation to chargers used with e:PROGRESS.
Please review the privacy policies of British Gas, Octopus and Vattenfall 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):
● Identity Information includes your first name and surname and your MyHonda+ profile.
● Contact Information includes your telephone number, residential address, and email address.
● Content of communications which you send to us.
● Applications and contracts you submit when you subscribe for e:PROGRESS which, in addition to your identity information and contact information, may include your Honda e order status, dealership details, off street parking confirmation and homeowner permissions.
● Service eligibility information, namely confirmation that you have purchased a charger from British Gas.
● Usage Information is comprised of information generated when you access and use our services, namely your charging preferences and plan, charging status, charge level, charger model (received from British Gas) and applicable tariff (received from Octopus).
● Technical Information that identifies:
– Your chargepoint, namely the type of chargepoint you have, including manufacturer and model name, the serial number of your chargepoint, your chargepoint identification code, and other physical features pertaining to your chargepoint, such as whether it is tethered or untethered.
– Your vehicle, namely your vehicle ID, VIN, state of charge, vehicle name, colour, model details, doors, and fuel type.
● Financial Information includes a limited amount of bank account and payment card details to enable us to administer payment transactions.
● Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us.
● Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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:
● Direct interactions. You may give us your Identity, Contact and Financial Information by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal information you provide when you:
– register your interest in our services via our website;
– subscribe to our services including our intelligent charging services;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us some feedback or otherwise communicate with us.
● Lunar Energy and Honda. Lunar Energy and Honda will share the personal data described in this notice with each other to provide you with e:PROGRESS, including in particular to link the intelligent charging service with the app. The data includes vehicle data from your Honda vehicle and your user profile from the MyHonda+ App.
● Charger. We automatically collect information about whether the vehicle is plugged into the charger (including a timestamp), whether the charger has a stable data connection, and how much energy is used by the charger. We obtain this information from Vattenfall. Vattenfall operate the charger which connects to e:PROGRESS and they receive this information directly from the charger.
● Third parties. We may receive personal information about you from the following third parties:
– Identity, Contact Information and Applications from third parties such as Honda Dealerships where you have expressed an interest in our services to them and have applied for our services through them.
– British Gas, who confirm that you have purchased a vehicle charger from them and provide us with commissioning and installation information such as customer name, address, and contact details, charging device make, model, station ID, serial number, connection type, survey and installation details and date and details in order to enable us to provide you with e:PROGRESS.
– Vattenfall, who provide us with information from your charger as described above (see “Charger”).
– Octopus, who confirm your contract status, fuel type and also provide us with tariff information in order to enable us to provide you with e:PROGRESS.
– Technical Information from the following parties:
– analytics providers;
– advertising networks; and
– search information providers.
– Contact, Financial and Transaction Information from payment services providers (currently Stripe), and banks involved in payments.
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:
● Where we need it to enter into or to perform the contract we have entered into with you.
If we use your personal information for performance of a contract this means processing your 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 a contract.
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
If we use your personal information for our legitimate interests this 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. Whenever we use legitimate interests, we give careful consideration to and balance any potential impact on you (both position and negative) and your rights. We do not use your personal information 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
● Where we need to comply with a legal or regulatory obligation.
● Where you have provided your consent for us to use your personal information.
For example, if you are not an existing customer and you request to receive marketing emails about e:PROGRESS products and services which may be of interest to you, we only send you these emails on the basis of your consent, which you may withdraw at any time by contacting us using the contact details in this notice, changing your marketing preferences in the website, or clicking the “unsubscribe” link we include in every marketing email.
You may always withdraw your consent when we process your data on the basis of consent (although this would not affect the validity of processing carried out with your consent).
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.
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.
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
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).
● Lunar Energy and Honda will share the personal data described in this notice with each other to provide you with e:PROGRESS, including in particular to link the service with the app.
● Internal third parties – companies in the Lunar Energy Group and the Honda Group who are based in the UK and undertake leadership reporting.
● Honda Motor Co. Ltd. (Japan) who provides some of the systems for e:PROGRESS.
● Honda and Lunar Energy may both share data with the following external third parties:
– Service providers acting as processors who provide IT and system administration services.
– Professional advisers including lawyers and auditors who provide consultancy, legal, and accounting services.
– Data management and analytics providers to improve our services.
● Lunar Energy may also share data with the following external third parties:
– Electrical and engineering contractors who install and maintain the chargepoints.
– Providers of vehicle chargers, namely British Gas, to notify them of any vehicle charger repairs or maintenance required.
– Payment services providers, namely Stripe, and banks who process payments due to us.
– Insurers in connection with claims.
– Providers of CRM and marketing platforms, namely Salesforce.
– Government agencies, regulators and other public authorities, such as HMRC, the Police and the Courts, for performing regulatory obligations or investigating any actual or suspected criminal activity.
● Third parties to whom we may choose to (or offer to) sell, transfer, or merge parts of our business or our assets, or who may finance or consider financing our business or 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 information in the same way as set out in this privacy notice.
● We may also share aggregated data with our third party partners 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. As set out above, aggregated data is data which is anonymised and from which we are unable to identify any individual, and we combine this information with other non-personal data.
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.
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
● Request access to your Personal Information
You have the right to request access to the personal information that we have collected about you and to confirm that your personal information is being processed by us. This is often referred to as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
● Request correction of your Personal Information
This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
● Request erasure of your Personal Information
This enables you to ask us to delete or remove personal information 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 information 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 information 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..
● Request restriction of processing your Personal Information
You can ask us to suspend the processing of your personal information in the following circumstances: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
● Request to transfer your Personal Information
You have the right to obtain and reuse your personal information. We will provide to you, or a third party you have chosen, your personal information 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.
● Object to processing of your Personal Information
You have the right to object to the processing of your personal information 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 information 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.
● Right to withdraw consent
Where we rely on consent to process your personal information for certain purposes, as set out in section 5 (for example, where we ask you to consent to us sending you marketing materials) you have the right to withdraw your consent at any time.
Please note the following:
– You may correct, update, restrict or limit your account information at any time by adjusting that information via your account settings.
– You may request that your account, together with the personal information within your account, is deleted by contacting e:PROGRESS Customer Support (please see below).
– You can object to our processing of your personal information when we rely on legitimate interests as a legal basis, and we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
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 firstname.lastname@example.org 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:
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/.
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.