We are Motor Fuel Limited (MFG, we, us or our) a company registered in England and Wales under company registration number 05206547. Our registered office is at 10 Bricket Road, Marlborough Court, St Albans, Hertfordshire, AL1 3JX (MFG). References to you or your are references to any person whose personal data we process, including anyone who has downloaded and uses our MFG Connected App (the “App”).
Introduction to this Privacy Policy
MFG takes privacy seriously and we are committed to protecting your privacy in compliance with data protection laws and regulations in the United Kingdom, including the Data Protection Act 2018 and the General Data Protection Regulation (EU 2016/679) (as this was amended and incorporated into UK law by the UK European Union Withdrawal Act 2018) together with associated guidance (the Data Protection Laws).
This Privacy Policy explains how we use, store and share the personal data we collect about you, how you can exercise your rights in respect of that personal data and the procedures that we have in place to safeguard your privacy. In particular, this Privacy Policy describes:
This Privacy Policy supplements any other fair processing or privacy notice that may be provided to you from time to time. Please contact us by email at customercare@motorfuelgroup.com or by phone on 01727 898890 during Monday to Friday between 9.00 and 17.00 hours if you have any questions, comments or concerns about this Privacy Policy or how we handle your personal data, or if such information changes at any time.
We reserve the right in our sole discretion to amend this Privacy Policy from time to time. In this event, we will post the revised policy on our website. We will notify you of any material changes via a notification by email or in the App (if you are an App User). Please check back frequently to see any updates or changes to this Privacy Policy.
If you do not agree to your personal data being used in the manner described in this Privacy Policy then please do not provide this to us. If you are an App User, personal data will be collected during your use of the App, so please do not use the App if you do not want us to use your data in the manner described in this Privacy Policy. For Website Users, please note that we may be unable to fulfil your requests if you do not provide us with any personal data we request.
Please note: this Privacy Policy does not cover third party websites that we may link to from our website or the App, unless specifically mentioned in this Privacy Policy. We are not responsible for the privacy policies and practices (including use of cookies) of such third parties even if you accessed the third party website using links from our website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
The personal data we collect and how we use it
Under the Data Protection Laws, we are required to explain what personal data we collect from you and how and why we use your personal data (the processing activity). We are also required to have a lawful basis on which to process your personal data. This information is set out in the tables below.
We collect and process the following personal data when you use the App:
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What personal data do we collect about App Users? |
Where is this personal data collected from? |
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Contact details: We will collect your name, email address and phone number which we require in the course of doing business with you, or when you apply to purchase our Services. |
You will be asked for this information when you create an account using the App or become an MFG member using the App or when you correspond with us by phone, email or otherwise during the course of our relationship. |
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Vehicle information: We will collect your registration number, vehicle make and model. |
You will be asked for this information when you use the App. |
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Payment data: If you want to make payments through the App, you will need to provide credit or debit card details. |
This information will be collected on the App, but MFG will not be able to view it or otherwise process it. Your payment data and your payments will be processed by our third party payment services provider. |
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Purchase history: We will keep a record of your purchases made through the App. |
This information is collected when you purchase products or services using the App. |
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Location data: We will collect your location if you have turned on your location services settings on your mobile device. |
This information is collected by the App if you use the functionality which allows you to plan a trip to MFG charging facilities. This information will also be used to show you promotions at nearby sites. |
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Photographs / Camera: You may share a profile picture, or provide images of QR codes. |
You can choose whether to share these images with us. |
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Usage data: We will collect information about how you use the App. For example, how often you use the App and what you use the App for. |
This information is collected when you use the App. |
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Device data: We will collect information about your device type and your IP address. |
This information is collected when you use the App. |
We may combine the personal data that we collect and will use this in the ways set out below:
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Why do we use App Users’ personal data? |
What is our lawful basis for using App Users’ personal data? |
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Contractual Relationship: To provide you with the App and the services made available through our App, for example, when you make a payment through the App. |
The processing is necessary for the performance of a contract with you, or to take steps at your requests prior to entering into a contract. |
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Services Communications: To send you information about our services. For example, if we plan to carry out maintenance at a charging station that you use or if there is a problem with your account. |
This processing is necessary for the performance of a contract with you, or to take steps at your requests prior to entering into a contract. |
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Marketing: To carry out marketing and advertising activity, including for the purpose of special offers, running competitions or as part of loyalty programmes. Please see section marketing and promotional material below. |
The processing is necessary for the purposes of pursuing our (or a third party’s) legitimate interests. Please see further details about our legitimate interests in the “What are our Legitimate Interests” section below. |
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Service Improvement: To improve and personalise our App and services to you and other customers, and to develop new products and services. |
The processing is necessary for the purposes of pursuing our (or a third party’s) legitimate interests. Please see further details about our legitimate interests in the “What are our Legitimate Interests” section below. |
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Compliance with laws: To comply with laws and to respond to and comply with requests from the government, regulators and other third parties with legal authority. For example, to fulfil our anti-money laundering obligations. |
The processing is necessary for our compliance with a legal or regulatory requirement. |
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Legal claims: To provide evidence where this is required to exercise or defend legal claims. |
The processing is necessary for the purposes of pursuing our (or a third party’s) legitimate interests. Please see further details about our legitimate interests in the “What are our Legitimate Interests” section below. |
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Preventing fraud or crime: To investigate, detect and prevent fraud or crime and carry out related risk assessments. |
The processing is necessary for compliance with a legal obligation to which we are subject. |
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System security: To keep the App and our systems safe and secure. For example, to investigate security breaches, debug or fix errors that impair the Services. |
The processing is necessary for the performance of a contract with you, or to take steps at your requests prior to entering into a contract. |
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Feedback or Complaints: To request information from you about the App and our products and services, or if you report issues with the App or our products and services. |
The processing is necessary for the purposes of pursuing our (or a third party’s) legitimate interests. Please see further details about our legitimate interests in the “What are our Legitimate Interests” section below. |
We collect and process the following personal data from our Customers:
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CCTV footage |
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What personal data do we collect? |
We may collect your image (including images of your vehicle) if you travel to one of our sites. |
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Where is this personal data collected from? |
We will collect this information using CCTV cameras located at our sites. |
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Why do we use this personal data? |
We use this data to keep our sites secure, complying with laws (e.g. health and safety), to defend legal claims, or preventing crime or fraud. |
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What is our lawful basis for using this personal data? |
Our lawful basis may be one of the following, depending on the reason for using the CCTV footage:
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Payment data |
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What personal data do we collect? |
If you purchase any of our products or services using a credit or debit card or device, we may collect transaction data from you. |
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Where is this personal data collected from? |
This information will be collected by our payment terminals (if you are not using the App to make payments), but MFG will not be able to view it or otherwise process it. Your payment data and your payments will be processed by our third party payment services provider. |
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Why do we use this personal data? |
We pass this data onto our payment services provider in order to carry out a transaction you have requested. |
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What is our lawful basis for using this personal data? |
The processing is necessary for the performance of a contract with you, or to take steps at your requests prior to entering into a contract. |
We may combine the personal data that we collect and will use this in the ways set out below:
We may collect and process the following personal data from Website Users:
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What personal data do we collect about Website Users? |
Where is this personal data collected from? |
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Contact details: We may collect your name, email address and phone number and other contact details. |
You may provide this to us when you contact us via our website, or the contact details provided on our website. |
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CVs and other information in connection with a job application or application to be a contract manager: This may include details of your career, references, date of birth. |
This information will be provided by you when you complete the online application form on our Website. |
We may combine the personal data that we collect and will use this in the ways set out below:
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Why do we use Website Users’ personal data? |
What is our lawful basis for using Website Users’ personal data? |
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Assessing Job Applications: If you have applied for a vacancy advertised on our website, we will use the information you provide us with to evaluate your application and possibly contact you. |
The processing is necessary for the performance of a contract with you, or to take steps at your requests prior to entering into a contract. |
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Responding to your requests: If you get in touch with us via the Contact Us page of our Website, we will use the information you provide us with to deal with your request and contact you about it. |
The processing is necessary for the purposes of pursuing our (or a third party’s) legitimate interests. Please see further details about our legitimate interests in the “What are our Legitimate Interests” section below. |
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Feedback or Complaints: If you provide us with feedback or make a complaint about any of our products or services via our website, we will use your information to respond to you and address your concerns. |
The processing is necessary for the performance of a contract with you, or to take steps at your requests prior to entering into a contract. |
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Compliance with laws: To comply with laws and to respond to and comply with requests from the government, regulators and other third parties with legal authority. For example, to comply with tax requirements. |
The processing is necessary for our compliance with a legal or regulatory requirement. |
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Legal claims: To provide evidence where this is required to exercise or defend legal claims. |
The processing is necessary for the purposes of pursuing our (or a third party’s) legitimate interests. Please see further details about our legitimate interests in the “What are our Legitimate Interests” section below. |
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Preventing fraud or crime: To investigate, detect and prevent fraud or crime and carry out related risk assessments. |
The processing is necessary for compliance with a legal obligation to which we are subject. |
What are our Legitimate Interests?
We have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interests as the lawful basis on which to process your personal data in certain circumstances (we have stated this above and set out our legitimate interests). We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest does not override your privacy rights as an individual. MFG documents the balancing exercises it carries out when relying upon this lawful basis for processing your personal data.
We consider that it is reasonable for us to process your information for the purposes of our legitimate interests outlined above as: (a) we process your information only so far as is necessary for such purpose; and (b) it can be reasonably expected for us to process your information in this way.
In addition to the above, we may pseudonymise or anonymise your personal data and use it in an aggregated way to help us to identify patterns which we can use to help us develop, administer, support and improve our services.
When you use the App and our website, we use cookies that are stored temporarily (“session” cookies) or for a longer period of time (“persistent” cookies) by your browser and/or the App on the device that you use. Cookies are small files that contain information sent by our server (or a third party’s server) to your browser. Information will be sent back to our (or the third party’s) server during a subsequent visit. We only use cookies to perform and improve our website, App and relevant services.
We take steps with a view to permanently deleting, destroying or anonymising your personal data (which means that we are no longer able to identify you from it) when it is no longer necessary for its purpose and we are not required by law to keep it.
How long we keep your personal data depends upon the purpose for which your personal data was collected was provided. Generally, we will keep the information no longer than is necessary to fulfil the purpose for which the data was collected (for example, to provide the App to and our services to you or for our legitimate internal business purposes). After that, we will only keep information about you if it is necessary for us to do so to comply with our legal obligations.
In particular, we will keep the following information for the following periods:
Marketing and promotional materials
If you are an App User, we may use your personal data to provide you with marketing and promotional materials (as stated above). We do so for our own purposes and will never sell or share your personal data with third parties for marketing purposes without your explicit prior consent.
You may opt-out of receiving marketing and promotional emails or texts from us at any time by emailing us at customercare@motorfuelgroup.com, using the 'unsubscribe' link in the marketing or promotional email, or texting 'STOP' and the relevant number in the text.
Security
We have in place appropriate policies, rules and technical and organisational measures to protect your personal data from unauthorised or unlawful processing, and against accidental loss, destruction or damage.
We also have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.
However the Internet and email are not secure. Your communications may route through a number of countries before being delivered, may be intercepted by third parties and may not always reach the intended recipient – this is the nature of the Internet. We cannot accept responsibility for any such unauthorised access or loss of personal data that is beyond our control.
If you are an App User, you are responsible for protecting your username and password and must not share it with, or disclose it, to anyone.
If you want you to learn more about how to protect your data and your devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Sharing your personal data
We will only disclose your personal data to:
companies within our company group;
our professional advisors and auditors (including without limitation tax, legal or other corporate advisors who provide professional services to us);
other third party suppliers, business partners and sub-contractors for business administration, support, processing, services, or IT purposes. This includes our hosting services provider, Microsoft Azure, our third party payment provider, Squareup Europe Limited, and our third party job applicant tracking system (or such other providers as we may choose to use from time to time);
other third party suppliers of EV charging back office services, for example Swarco AG and Driivz, Inc.;
other third party suppliers for marketing purposes (for example, third party survey tools, analytics tools or tools for pushing messages to you);
third parties that you approve (including social media sites);
our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters; and
HMRC or other tax bodies or agencies to comply with our legal and regulatory obligations.
We will disclose your personal data to third parties:
in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
in the event we are the subject of any insolvency situation (e.g. the administration or liquidation);
if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
in order to enforce or apply the Website and App Terms and Conditions or any other contract we have in place with you;
to protect our rights, property, or safety, or that of our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation HMRC, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
International transfers of your personal data
We may transfer personal data to countries other than the country in which the data was originally collected (for example, outside the UK) in order to provide you with our services. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.
If we transfer personal data to countries outside of the UK, we may rely on a decision from the Secretary of State (or other mechanism permitted under the Data Protection Laws) determining that the country provides an adequate level of protection to the Data Protection Laws. Alternatively, we may rely on appropriate safeguards in respect of transfers of personal data to a country outside of UK (for example, by requiring the recipient of the personal data in the other country to agree to the set of standard contractual clauses approved under the Data Protection Laws).
Your rights
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Right |
Description |
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To be informed |
A right to be informed about the personal data we hold about you. |
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Of access |
A right to access the personal data we hold about you. |
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To rectification |
A right to require us to rectify any inaccurate personal data we hold about you. |
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To erasure
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A right to ask us to delete the personal data we hold about you. This right will only apply where (for example):
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To restrict processing
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In certain circumstances, a right to restrict our processing of the personal data we hold about you. This right will only apply where (for example):
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To data portability
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In certain circumstances, a right to receive the personal data you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request. |
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To object
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A right to object to our processing of the personal data we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal data which override your rights or which are for the establishment, exercise or defence of legal claims. |
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In relation to automated decision making and profiling |
A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. We do not carry out any automated processing or profiling. |
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To withdraw |
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with brochures and newsletters). |
We welcome your views about this Privacy Policy. If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please email us at customercare@motorfuelgroup.com or write to us at: Motor Fuel Group, 10 Bricket Road, Marlborough Court, St Albans, Hertfordshire, AL1 3JX.
If you would like this notice in another format (for example audio, large print, braille) please contact us using the details above.
An organisation is only required to appoint a Data Protection Officer (DPO) under the Data Protection Laws if it is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of personal data on a large scale. Based on these criteria, we have determined that MFG does not require a Data Protection Officer to be appointed.
We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal data. However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to our supervisory authority, which is the UK's Information Commissioner's Office. Their address is: First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
This Privacy Policy was last updated on 26/04/2023.