Spirii Privacy Notice for the Use of Connect for TruckCharge
Section A. Spirii’s Notice to Users
The controller responsible for data processing is:
Spirii ApS, Bragesgade 8 A, DK-2200 Copenhagen, Denmark
How is Data Collected?
Spirii processes and uses data in the context of platform usage.
If necessary for Daimler Truck for the respective purposes (e.g., for network management, billing, reporting, governance, or in the context of incident investigations), Spirii may transmit the personal data relevant to Daimler Truck to Daimler Truck.
Categories of Data
Within the TruckCharge Network, Spirii processes exclusively the following categories of personal data:
- Contact Data: Name, business email address of contact persons at hosts and guests
- Organisation-related Data: Company affiliation, role/function within the company
- Billing and Usage Data:
- Charging histories of individual drivers, assignment of charging sessions to individual users/drivers (e.g., time, location), insofar as necessary for incident tracking, network governance, or billing
- Feedback Data: If you participate in surveys or feedback activities, your responses regarding opinions and experiences related to the TruckCharge Network
- Support and Service Data: Information on support cases, processed insofar as transmitted to Daimler Truck for governance or analysis purposes (e.g., ticket number, subject, status)
Purposes and Legal Basis of Processing
Spirii processes your personal data within the TruckCharge Network for the following purposes and on the following legal basis:
- Legal Basis: Legitimate interest pursuant to Art. 6(1)(f) GDPR
- Network Governance and Membership Management: Administration of membership, communication within the framework of network rules, enforcement of participation conditions, tracking of incidents (e.g., misuse or vandalism)
- Billing and Commission Settlement: Verification and processing of commission payments to network partners and ensuring proper billing
- Analysis, Reporting, and Network Development: Evaluation of aggregated and individual usage data, creation of reports (e.g., on charging points, usage figures, contract status, support cases, charging histories), and targeted further development of the TruckCharge Network
- Feedback and User Surveys: Analysis of feedback and improvement of services offered, provided you have consented to being contacted
Transfer to Third Countries
Your data is not transferred to third countries.
Duration of Storage
Data required to fulfil the respective purposes is stored only as long as necessary or as legally required. In principle:
- Data for network governance and membership management (e.g., contact data of contact persons) is stored for the duration of membership and up to 3 years after termination of participation, to handle any queries or legal claims.
- Data for billing and commission settlement (e.g., contract and billing information) is stored for 5 years in accordance with statutory retention obligations.
- Data for analysis and network development (e.g., usage and charging history data) is generally stored for 3 years. Thereafter, the data is anonymised or deleted.
- Data from feedback and user surveys is stored for 1 year from the date of collection.
After expiry of the respective periods, the data is deleted or anonymised.
Rights of Data Subjects
In connection with the processing of personal data, data protection law provides rights to data subjects:
- Right of Access: You have the right to obtain information about the personal data stored about you, in particular the purpose of processing and the duration of storage (Art. 15 GDPR).
- Right to Object: Under certain conditions, you have the right to object at any time, on grounds relating to your particular situation or if personal data is used for direct marketing purposes, to the processing of your personal data where the processing is based on Art. 6(1)(f) GDPR. We will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or if the processing serves the establishment, exercise, or defence of legal claims (Art. 21 GDPR). If personal data is processed for direct marketing purposes, you have the right to object at any time to such processing, including profiling related to such direct marketing. In this case, your personal data will no longer be processed for these purposes..
- Right to Restriction of Processing: Under certain conditions, you have the right to demand restriction of the processing of your personal data, especially for the duration of verification if you have contested the accuracy of your data, or if you require the data for the establishment, exercise, or defence of legal claims, or if the successful exercise of an objection is disputed between us and you (Art. 18 GDPR).
- Right to Rectification: You have the right to demand the immediate rectification of inaccurate personal data concerning you (Art. 16 GDPR).
- Right to Data Portability: Under certain conditions, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format (Art. 20 GDPR).
- Right to Erasure: You have the right, under certain conditions, to demand the erasure of your personal data. This applies, for example, if the data is no longer necessary for the purposes for which it was collected or otherwise processed, if we process the data unlawfully, if you have lawfully objected to the processing, if you have withdrawn your consent, or if there is a legal obligation to erase (Art. 17 GDPR).
If you wish to exercise any of your rights or obtain further information, please send an email to dataprotection@spirii.com.
Right to Lodge a Complaint with a Supervisory Authority
If you believe that we are processing your personal data in violation of the General Data Protection Regulation, you have the right to lodge a complaint with a supervisory authority.
Provision of Personal Data Due to Legal or Contractual Requirement
The provision of this data is voluntary. However, if you do not provide your personal data, we may not be able to provide services for which the processing of your personal data is required.
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Section B. Daimler Truck AG’s Notice to Users
Information on the Controller
The controller responsible for data processing is:
Daimler Truck AG, Fasanenweg 10, 70771 Leinfelden-Echterdingen, Germany contact@daimlertruck.com
1.2 Data Protection Officer
The appointed Data Protection Officer is:
Group Data Protection Officer of Daimler Truck AG
HPC DTF2B
70745 Leinfelden-Echterdingen dataprivacy@daimlertruck.com
How is Data Collected?
We process and use the data collected by our service partner Spirii, as the operator of the TruckCharge platform, in the context of platform usage. The personal data relevant to Daimler Truck is subsequently transmitted to us, provided this is necessary for the respective purposes (e.g., for network management, billing, reporting, governance, or in the context of incident investigations). Direct data collection by Daimler Truck (e.g., via its own forms or apps) does not generally take place within the TruckCharge Network.
Categories of Data
Within the TruckCharge Network, Daimler Truck processes exclusively the following categories of personal data transmitted by Spirii:
- Contact Data: Name, business email address of contact persons at hosts and guests
- Organisation-related Data: Company affiliation, role/function within the company
- Billing and Usage Data:
- Charging histories of individual drivers, assignment of charging sessions to individual users/drivers (e.g., time, location), insofar as necessary for incident tracking, network governance, or billing
- Feedback Data: If you participate in surveys or feedback activities, your responses regarding opinions and experiences related to the TruckCharge Network
- Support and Service Data: Information on support cases, insofar as transmitted to Daimler Truck for governance or analysis purposes (e.g., ticket number, subject, status)
Purposes and Legal Basis of Processing
Daimler Truck processes your personal data in the TruckCharge Network for the following purposes and on the following legal basis:
- Legal Basis: Legitimate interest pursuant to Art. 6(1)(f) GDPR
- Network Governance and Membership Management: Administration of membership, communication within the framework of network rules, enforcement of participation conditions, tracking of incidents (e.g., misuse or vandalism)
- Billing and Commission Settlement: Verification and processing of commission payments to network partners and ensuring proper billing
- Analysis, Reporting, and Network Development: Evaluation of aggregated and individual usage data, creation of reports (e.g., on charging points, usage figures, contract status, support cases, charging histories), and targeted further development of the TruckCharge Network
- Feedback and User Surveys: Analysis of feedback and improvement of services offered, provided you have consented to being contacted
Transfer to Third Countries
Your data is not transferred to third countries.
Duration of Storage
Data required to fulfil the respective purposes is stored only as long as necessary or as legally required. In principle:
- Data for network governance and membership management (e.g., contact data of contact persons) is stored for the duration of membership and up to 3 years after termination of participation, to handle any queries or legal claims.
- Data for billing and commission settlement (e.g., contract and billing information) is stored for 5 years in accordance with statutory retention obligations.
- Data for analysis and network development (e.g., usage and charging history data) is generally stored for 3 years. Thereafter, the data is anonymised or deleted.
- Data from feedback and user surveys is stored for 1 year from the date of collection.
After expiry of the respective periods, the data is deleted or anonymised.
Rights of Data Subjects
In connection with the processing of personal data, data protection law provides rights to data subjects:
- Right of Access: You have the right to obtain information about the personal data stored about you, in particular the purpose of processing and the duration of storage (Art. 15 GDPR).
- Right to Object: Under certain conditions, you have the right to object at any time, on grounds relating to your particular situation or if personal data is used for direct marketing purposes, to the processing of your personal data where the processing is based on Art. 6(1)(f) GDPR. We will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or if the processing serves the establishment, exercise, or defence of legal claims (Art. 21 GDPR). If personal data is processed for direct marketing purposes, you have the right to object at any time to such processing, including profiling related to such direct marketing. In this case, your personal data will no longer be processed for these purposes..
- Right to Restriction of Processing: Under certain conditions, you have the right to demand restriction of the processing of your personal data, especially for the duration of verification if you have contested the accuracy of your data, or if you require the data for the establishment, exercise, or defence of legal claims, or if the successful exercise of an objection is disputed between us and you (Art. 18 GDPR).
- Right to Rectification: You have the right to demand the immediate rectification of inaccurate personal data concerning you (Art. 16 GDPR).
- Right to Data Portability: Under certain conditions, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format (Art. 20 GDPR).
- Right to Erasure: You have the right, under certain conditions, to demand the erasure of your personal data. This applies, for example, if the data is no longer necessary for the purposes for which it was collected or otherwise processed, if we process the data unlawfully, if you have lawfully objected to the processing, if you have withdrawn your consent, or if there is a legal obligation to erase (Art. 17 GDPR).
If you wish to exercise any of your rights or obtain further information, please use the following web form: https://daimlertruck.com/privacy/2725 or send an email to kundenrechte_dt@daimlertruck.com.
Right to Lodge a Complaint with a Supervisory Authority
If you believe that we are processing your personal data in violation of the General Data Protection Regulation, you have the right to lodge a complaint with a supervisory authority.
Provision of Personal Data Due to Legal or Contractual Requirement
The provision of this data is voluntary. However, if you do not provide your personal data, we may not be able to provide services for which the processing of your personal data is required.
Source of Data
The personal data processed by Daimler Truck within the TruckCharge Network is not collected directly from you, but is transmitted by our service partner Spirii. Spirii collects this data in the context of using the TruckCharge platform (e.g., during registration, execution of charging sessions, or use of TruckCharge Connect) and makes it available to Daimler Truck solely for the purposes specified in section 1.5.