True Energy takes good care of your personal data and never shares it with anyone unless you have given us your consent or there is another legal basis for the processing of your personal data. This can for instance be True Energy’s fulfillment of a legal obligation, or performance of a contract to which you are a party.
Our policy is that we use your personal data solely to provide you with the best and most relevant user experience so that we can make your electricity consumption more climate-friendly and cheaper. We also make every effort to ensure that the processing of your personal data becomes more transparent to you.
True Energy’s App and Services process some of your personal data, and in the following, you can read the category of personal data processed and how these personal data are processed.
The privacy policy is divided into the following sections:
1. Who are we?
2. What personal data do we collect?
3. What do we use your personal data for?
4. Legal basis for the processing of your personal data
5. Who do we share your personal data with?
6. How long do we store your personal data?
7. Your rights
8. Contact
When you sign up for the app “True Energy” (Hereinafter referred to as “The App” or “True Energy App”), you enter into an agreement with True Energy A/S, Agern Allé 5A, 2970 Hørsholm, Denmark, CVR no. 39406764 (hereinafter referred to as “True Energy” or “we”), which is also the entity responsible for processing your personal data.
Every time you use a website, an app, your car, mobile phone, or internet service, personal data about you is automatically processed and stored. The same applies when you use the True Energy App and Services. Certain personal data is mandatory for us to process, other personal data is voluntary, but have an impact on what services True Energy can offer. Below are the types of personal data that True Energy processes outlined:
Personal data you provide yourself: rules, then personal data are stored, including your preferences for the battery’s minimum and maximum charge, the vehicle’s starting time, and the geographical location of your charging points, telephone, and vehicle.
For SmartHome devices, your preferences for starting and stopping the devices are also stored.
Electricity customers
The users who are also True Energy electricity customers, will, in connection with placing orders also enter name, address, telephone number, e-mail, CPR number, and any partner’s name and CPR number. When paying via Betalingsservice (BS), the bank registration number and bank account number are also registered.
Personal data we collect when you use True Energy’s App and Services:
Information about vehicles, charge boxes, and devices
If you have registered one or more electric vehicles in the True Energy App, we will receive the following personal data, or a subset of it depending on the car model, the charging box model, and their communication standards:
Token: The login and password for your Tesla are used once for a split second to create a token, which is subsequently used in connection with contacting the vehicle.
Login and password for other electric vehicles and charging boxes: For some brands and vehicle models, a token cannot be generated. In these cases, login and password will be stored. For other brands and vehicle models, login and password are only used to generate a token which is subsequently used in connection with contacting the vehicle.
Charging cable: attached or not.
Battery % and kilometre: If the battery’s capacity is below the minimum limit, we immediately begin charging. If the electric vehicle’s battery is above the minimum limit and the vehicle is at a charging station where we have Smart Charge, we will stop charging and wait for a later time when the electricity is cheap.
Charge speed: Enables us to create a charge plan that is optimal in relation to the desired ready time. If a user has set a 6 AM ready time, and the vehicles´’s battery needs three hours of charging, we will identify and charge during the three cheapest hours.
GPS when the charging cable is inserted into the vehicle: Used to identify at what charging point the vehicle is located. This is for instance used to start charging immediately at SuperChargers, but is potentially delayed it if the charging cable is attached at home.
The vehicle’s name: To display in the True Energy App.
VIN number: For the unique identification of the vehicle.
Battery max: To end charging when, for instance, the battery is 80% charged.
Daily max: For optimising participation in Big Battery and Kabelrabat™.
Placement of your phone when you start and stop driving.
Active/Inactive Bluetooth connection you have provided between our App and your vehicle/device.
Consumer data
We collect data about your use of True Energy’s App and Services, including how many kWh you have charged your car, how many hours you have had the charging cable inserted at your selected charging points, how much money and CO2 you have saved, and how much Kabelrabat ™ you have earned.
For Smart Home, we collect data on how many plans and events you have running. We also collect data about when we started and stopped your Smart Home devices and whether they were started or stopped by other control systems.
True Energy electricity customers
If you are an electricity customer with True Energy, we collect information about the measurement point as well as your historical and expected consumption in order to prepare consumption and account settlements. Thus you will avoid paying too much or receiving large post-collection charges on your annual statements.
Technical data when you use True Energy’s App and services:
Log data and user statistics
When you use True Energy’s App and Services, we proceed log data about you that we receive automatically from the App. Log data includes information about your mobile device (device type, model, and OS version number) as well as the time of use. Log data is collected for the purpose of validating our visitor statistics.
Cookie data
True Energy uses cookies when you visit our website or similar technologies to record log data. We use so-called persistent cookies, which are stored until you or your browser delete them. You can read more about our cookie policy at trueenergy.io/cookies/.
We use WP Statistics and Google Analytics to analyze the traffic on our website, trueenergy.io, and to develop new services.
True Energy uses your personal data to optimize your electricity use and make it more climate-friendly and/or cheaper.
Contact information
We use your contact information to contact you and identify you (e.g. your email address or telephone number). If we have your consent, we can send you messages regarding the electric vehicles and devices for which we optimize your power consumption. If you have consented to receiving direct electronic marketing, we may also send you marketing material via email and push notifications, depending on the settings in your account or operating system. Every time we send marketing material to you, we give you the option of unsubscribing.
If you have provided information about your electricity provider and your customer number in this connection, we will use this information to ensure the transfer of Kabelrabat™ so that the discount you have earned will be deducted from your electricity bill by your electricity provider.
Information about vehicles, charge boxes, and devices
Your own information on preferences and the information we automatically collect are used to optimize the electricity consumption of the vehicles and devices that you have chosen to integrate with True Energy’s App and Services.
Consumer data
Consumer data is used to show the energy consumption of your electric vehicle or other devices as, well as a number of supporting energy analyses, such as estimating CO2 savings. In addition, your consumption data is used as input by profiling and energy optimization algorithms, which will ultimately help you to better energy utilization.
Support
We process your inquiries with the purpose of offering you the best possible customer service.
True Energy electricity customers
Generally, True Energy processes the personal data you provide to deliver and invoice the goods and services you order. The CPR number is processed for notification in Energinet’s Datahub.
We process your personal data in order to fulfill our obligations towards you and thereby fulfill the contract we have entered into with you cf. Article 6(1)(b) of the General Data Protection Regulation.
In addition, we will process your personal data when we have determined that our legitimate interests override any conflicting interests you may have, cf. Article 6(1)(b) of the General Data Protection Regulation. This could, for instance, be to ensure optimization of your electricity consumption or when we answer your questions and other inquiries in order to offer you the best possible customer service.
We process your CPR-number, as this is a legal requirement in the energy sector.
Only True Energy employees will have access to your personal data. True Energy does not disclose your personal data to third party suppliers unless True Energy is required by law or True Energy has entered into an agreement with third party suppliers to provide our customers with their services (for instance, phone services for you to contact us outside regular customer service hours).
To obtain Kabelrabat™ (Cable Discount) we transfer data about your e-mail, telephone number, customer number and other data you added when you created your user account in the App. This data as well as the App ID and saved Kabelrabat™ are passed on to True Energy’s partners so that they can identify you in their customer list and include the Kabelrabat™ on your electricity bill. The partner is an independent data controller.
Local Battery users: True Energy shares the location of your charging points with the buyer of the Local Battery service – typically the DSO (the local electricity grid company). In addition, data is shared regarding App ID, charge box id, the start time of charge sessions and how fast the car charges. The buyer uses this information to verify the delivered services.
We share your personal data with our data processors who support True Energy’s operations. Below you can read about the data processors we use:
Development and operations partners that are engaged to further develop and support True Energy’s services (including troubleshooting). Our development and operations partners may need to, for instance, access your measurement data or contact information.
Hosting partners that host the True Energy platform, which is the foundation of The App. These partners can only be granted access to selected personal data when explicitly agreed upon in connection with troubleshooting.
Systems for consumption billing, which are used to administration and invoicing of True Energy’s electricity customers.
Marketing partners. True Energy engages marketing partners to support our marketing activity, such as emails containing marketing information. In connection with such campaigns, our marketing partners may need access to personal data, such as your name and email address. The information is solely used in connection with marketing of the True Energy App and Services, and marketing partners are prohibited from using the information for any other purpose.
True Energy’s partners collect specific consent to contact you, for example, when you install The App.
We process and store your personal data for as long as it is necessary in order to provide you with the relevant services of True Energy’s App and Services, as well as carry out the legitimate interests described in this Privacy Policy.
To the extent that the personal data are necessary to process in relation to a monetary claim, we may store the personal data for up to 3 years in pursuance of applicable limitation rules. If your personal data appears in accounting material, it is stored for 5 years from the end of the financial year to which the bookkeeping material relates in pursuance of applicable rules in the Danish Bookkeeping Act. Your consent to receive electronic marketing may be retained for 2 years after you unsubscribe.
Upon termination, or if your personal data no longer serves a purpose, such personal data will be deleted from True Energy, or your personal data will be anonymized so that we will not be able to refer them back to you. Deletions and anonymization are carried out within 180 days from the termination of the contract with you.
You have the following rights:
Right to access
You have the right to access your personal data, including receiving a copy of your personal data that we process and certain information about the processing of your personal data, such as the purpose of the processing, etc.
You can access most of your personal data directly through The App.
Right to data portability
When our processing is carried out automatically and is based on your consent, or performance of a contract to which you are subject to, you have the right to receive your personal data in a structured, commonly used and machine-readable format as well as to request that this personal data be transmitted to another data controller, if technically feasible.
Right to rectification
You have the right to have incorrect personal data about yourself corrected. You also have the right to have your personal data supplemented with additional personal data if this will make your personal data more complete and/or up to date. We encourage you, as far as possible, to correct personal data in the App if you notice any incorrect personal data.
Right to erasure
In some cases, you have the right to have personal data deleted earlier than our regular deletion period.
Right to restriction
In some cases, you have the right to restrict the processing of your personal data.
Right to objection
In some cases, you have the right to object to our lawful processing of your personal data. You may object at any time object to the processing of your personal data for direct marketing purposes.
If you wish to exercise your rights, you can contact us at support@trueenergy.io.
Complaints to Datatilsynet
You have the right to file a complaint with the Danish Data Protection Agency (Datatilsynet) if you are unsatisfied with the processing of your personal data. You can find the Danish Data Protection Agency contact information at www.datatilsynet.dk.
At True Energy, we are always ready to help if you have questions about The App or the personal data we process. You are always more than welcome to contact us.
True Energy ApS
CVR 39406764
Email: support@trueenergy.io
Phone: (+45) 31 78 77 30
Updated: November 6, 2020.
