Future Motion Solutions Ltd will be the data controller for the personal data that you provide us or we collect in relation to the provision of the ClearWatt service to you, which includes any services accessible through the Website (www.clearwatt.co.uk) and App. We respect your privacy and protecting your information is paramount. We want you to be informed and empowered with respect to your privacy when you use our services. Please read this Privacy Notice carefully before using the ClearWatt service. Together with the Clearwatt Terms, this Privacy Notice sets out our views and practices regarding your personal data and how we collect, process and treat it when you use the ClearWatt service.
By installing and using the Clearwatt App and Website you are accepting and consenting to the practices described in this Privacy Notice. The data controller of your information is Future Motion Solutions Ltd of County Hall, Floor 5, Westminster Bridge Road, London, SE1 7PB.
Our data controller registration number is ZB446080. You can check our registration on the Data Protection Public Register by visiting https://www.ico.org.uk/esdwebpages/search.
References in this Privacy Notice and on our website to "we", "our" or "us" are references to Future Motion Solutions Ltd. References to "you" and "your" means each natural or legal person who uses the ClearWatt service. For the avoidance of doubt, ClearWatt is a brand and product line managed, owned and operated by Future Motion Solutions Ltd.
The personal data we collect
We collect and process personal data which:
- you give to us when you register with us;
- we collect and process about you which is required for the provision of the ClearWatt service, such as your recorded Drives and driving behaviour;
- we collect and process about you based on your use of the ClearWatt services, including the App and Website; and
- we receive from other sources, such as third parties who give us information about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect and process the following personal data about you:
Personal Information you give us. When you use the ClearWatt service or when you communicate with us you may give us personal information. This includes personal information you provide when you sign up to use the ClearWatt service, provide us with feedback, participate in surveys, and when you report a problem.
The information you give us may include:
- Title
- Name
- Email address
- Date of birth
- Phone number
- Vehicle Registration Number
- Financial data
If you also hold a ClearWatt account, you may also have provided us with other personal information when you signed up for that account which we may use or link to your ClearWatt account.
Personal information we collect to provide you with our services. To provide you with our services, we will need additional personal information, such as:
- details about your vehicle, including your vehicle's licence number, age, battery warranty information, mileage, registration date and model of your vehicle.
We may also use the personal information described above to provide you with other features of the ClearWatt service, such as anonymous, aggregated comparisons with other drivers in your area and other insights which might help you to understand your vehicle’s battery performance. Anonymous aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity, if it does we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
Personal information collected through use of the ClearWatt App. In order to provide you with the ClearWatt service, the ClearWatt App will ask you to enable the collection of additional personal information after you install the ClearWatt app. This includes personal information:
- collected via your smartphone such as the accelerometer, compass and global positioning system (GPS) readings to determine when you are undertaking a drive in (or on) a vehicle (a "Drive");
- about your Drives, including your global positioning system (GPS) location, the roads you are travelling on and the distance that you travel;
- about your driving, including your acceleration and speed whilst undertaking a Drive and
- about your behaviour while undertaking a Drive, including the time of day you undertake the Drive and other activity relating to use of the smartphone the ClearWatt App is installed on. We do not monitor the content you access or how you use any apps other than the ClearWatt App.
We may also use the personal information described above to provide you with other features of the ClearWatt service, such as anonymous, aggregated comparisons with other drivers in your area and other insights which might help you to understand your vehicle’s battery performance. Anonymous aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity, if it does we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
Information we collect about you based on your use of the ClearWatt service. Each time you use the ClearWatt App or Website, we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address, your login information, operating system and platform information about your visit, products you viewed or searched for; response times, errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Notice for further details.
Personal information received from other sources. We will receive personal data about you from various third parties, including our affiliates, service providers, advertisers, Credit Reference Agencies, Fraud Prevention Agencies and Cybercheck Partners.
If you fail to provide personal data:
Where we need to collect personal data by law, or under the terms of 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 provide you with our services).
How we use the personal data
We use personal information we hold about you to provide the ClearWatt service to you, to improve the ClearWatt service, administer your ClearWatt account, communicate with you and, on an anonymous basis, for research, profiling and analytical purposes.
Personal information you give to us or we collect from third parties on your behalf to provide you with our services. We will use this personal information to:
- administer your account and relationship with us and to communicate with you by email, push notification or other electronic means;
- verify your identity as part of our identity authentication process;
- provide you with information, products and services;
- where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you;
- notify you about changes to our services;
- ensure that content from the ClearWatt App is presented in the most effective manner for you and your device;
- aggregate it on an anonymous basis with other data for analytical and reporting purposes; and
- for fraud prevention purposes.
Personal information collected through use of the ClearWatt App. When you install the ClearWatt App, and enable the required permissions, the personal data collected above will be used to develop your "ClearWatt Results"– an analysis of your EV’s battery performance which we calculate based on the information we have collected about your Drives. You should review the Drives that the ClearWatt App has recorded and flag any Drives recorded where you believe the details are inconsistent.
We may use anonymised, aggregated statistical data to improve the ClearWatt App, for example, by showing you a comparison of your ClearWatt Results compared to other ClearWatt users in your area and may provide this anonymised statistical data to third parties, such as car dealers, for improvement and development of their products and services. However, we will never share information which personally identifies you for these purposes.
Information we collect about you based on your use of the ClearWatt service, including the App and Website. We will use this personal information to:
- to administer the ClearWatt App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- as part of our efforts to keep our website safe and secure and to prevent fraud; and
- to make recommendations about products or services that may be of interest.
Personal information we receive from other sources. We may combine this personal information we receive from other sources with information you give to us and use this information and the combined information for research or statistical purposes.
What we will never do. Rest assured, we will never sell your information to third parties or access any information on your smartphone other than as set out in this Privacy Notice to provide you with the ClearWatt service.
Who we may share your personal data with
We may share your personal data with other members of our group and with other third parties, such as our service providers, partner networks, advertisers, Credit Reference Agencies, Fraud Prevention Agencies and Cybercheck Partners.
When we share your personal information, we will make sure that it is used for purposes which are compatible with those described here.
Whilst we never sell your personal data to any third parties, there may be exceptional situations where we are legally required to provide your personal information to another third party, such as a legal request from a law enforcement agency or following a court order. We will only provide your personal information to these third parties where we are legally required to do so.
Where possible, we try to only process your personal information within the UK and European Economic Area (EEA). However, we may transfer your personal data to countries outside the UK / EEA. Whenever we transfer personal data outside of the UK / European Economic Area, we ensure that appropriate safeguards are in place to protect the personal data.
What is the legal basis for us using this personal data?
We make sure we have appropriate legal bases on which to collect, use and share data about you. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data, if you have any questions about the lawful bases upon which we collect and use your personal data, you can contact our Data Protection Officer using the details set out below in the ’Contact us’ section.
Our lawful bases may include consent (where you have given consent, such as for marketing activities), contract (where processing is necessary for the performance of a contract with you,such as delivering our core services to you), to comply with a legal obligation, and our legitimate interests (or those of a third party).
Legitimate Interests. We may process your personal data for the purposes of our legitimate interests provided that such processing does not outweigh your rights and freedoms. As an example, we may process your personal data to:
- display tailored product offers to you;
- provide you with our service, including for the purpose of quality control and analysis;
- protect you and us from fraud or other threats;
- conduct analysis of your data in order to provide you with direct marketing communications;
- analyse our users' behaviour and preferences, and information collected from users' devices in order to improve the services we provide to our customers and the user experience on the ClearWatt App;
- provide anonymised or pseudonymised data or statistical information to third parties to improve their own product and service offerings; and
- improve our service and manage our customer relationships.
If you delete your account, we may also continue to store and where necessary further process information collected prior to the deletion of the account for fraud prevention purposes and for legal and compliance purposes, based on our legitimate interests in protecting our business and our other customers or where we are required to do so by law (for example, if we are required by a court order to disclose your personal data). Where we rely on legitimate interests in order to process your data, you may object at any time.
Consent. We are relying on your consent wherever we request your consent to our processing of your personal data, such as for direct marketing activities. Whenever you have given us your consent, you will be able to withdraw it at any time either by (i) visiting the 'Account' section of our App and managing your preferences or by (ii) deleting your account or deleting the ClearWatt App. If you choose to do so that will not affect the lawfulness of any processing carried out before you withdraw your consent. In addition, we may continue to use the information we collected prior to your withdrawal of consent in an anonymised form for our internal business purposes, for analysis and to improve our services based on our legitimate interests described above.
Performance of a contract. We need you to give us the personal information you provide in order for us to provide you with our services as agreed in our ClearWatt Terms with you, including the collection and processing of your driving data from your smartphone to calculate your ClearWatt results.
Legal or regulatory obligation. We will process your personal data where we need to comply with a legal or regulatory obligation, such as to comply with a legal request from a law enforcement agency or following a court order.
Direct marketing and how you can change your preferences
We offer you the opportunity to receive marketing information from us. You can easily opt-out of receiving marketing from us at any time. We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods, such as push notifications to your devices.
You may receive the following types of communications from us:
- Product recommendations: we'll get in touch with personalised, timely product recommendations that we believe will be of interest to you. We will only send these if you explicitly consented to receiving them and you can unsubscribe whenever you like.
- Content communications: we'll send you content such as tips, research, features and news, and other related content. We will only send these if you explicitly consented to receive them, you can unsubscribe from these at any time, and we will never spam your inbox.
If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing, you will be given the option to unsubscribe. You may also update your preferences on your ‘Account’ section of the App. You can also tell us that you do not wish to receive any more marketing communications at any time by email or post using the details set out below in the ’Contact us’ section.
How we protect your personal data
We take the security of your personal data very seriously and use strict procedures to protect it. Whenever we transfer personal data outside of the UK/ European Economic Area, we ensure that appropriate safeguards are in place to protect the data.
All information you provide to us is stored on our secure servers.
Once we have received your personal information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
How long do we keep your personal data for?
How long we keep your personal information will depend on the purpose for which we use it. We keep your information for no longer than is necessary to fulfil the purpose for which we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
After deletion of your account, we will retain your personal data for a period of up to seven years for fraud prevention and legal purposes (for example, if we need to defend ourselves from a legal claim).
We may continue to use aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. Anonymous aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity, if it does, we treat the combined data as personal data which will be used in accordance with this Privacy Notice. In addition, we may also keep your email address to ensure that you no longer receive any communications from us.
Links to and from third parties
Our Website and our App may, from time to time, contain links to and from third party websites, plug-ins and applications, such as our partner networks, advertisers and affiliates. If you follow a link to any of these websites, plug-ins and applications, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these privacy notices.
Automated decision making
Where permitted by law, we may use an automated decision making system to make automated decisions based on personal information we have about you. This helps us to make sure our decisions are quick and fair, based on what we know.
Tailored products and services. We may use your personal information to predict the probability that you may be accepted for a product and service, or to determine the best order or manner in which to display products to you.
Tailored communications. We want to make sure we're only sending you emails that are relevant to you, and so we will use your personal information to determine which content you may be more interested in receiving.
You have the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us via hello@clearwatt.co.uk.
We use personal information we collect about you in order to calculate your ClearWatt Results, but this information is not used by us to make any automated decisions about you.
Your rights
You can exercise specific rights with regard to the data that we hold about you. We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:
- Correct your data: It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
- Request access to your personal data: you can ask for access to the personal data that we hold about you so that you can check that we are using your personal information in accordance with data protection laws.
- Erase your personal data: you can ask us to delete your personal data/ account where there is no compelling reason for us to keep using it, although we may not be able to continue to provide our services. We may keep your email address to make sure the restriction is respected in the future. We also have the right to continue using your personal information if such usage is necessary for compliance with our legal obligations.
- Download your personal data or send it to another controller: you can obtain a copy of the personal data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
- Object to the use of your personal data: you can ask that we no longer use your personal data where that use is based on legitimate interest.
- Restrict the use of your personal data: You have the right to 'block' or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your personal information, but may not use it further.
- Right to withdraw consent: If you have given your consent for us to use your personal information, you have the right to withdraw your consent at any time.
For the exercise of any of your rights, you can contact us via email or post using the details set out below in the ’Contact us’ section.
We may need to request specific information from you to help us confirm your identity and ensure your rights. This is a security measure to ensure that personal data 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.
Changes we make to our Privacy Notice
This version was last updated on 25/05/2023. Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.
Contact us
You can address any questions, comments, complaints or requests regarding this Privacy Notice to the Data Protection Officer at hello@clearwatt.co.uk or by post at:
Data Protection Officer
Future Motion Solutions Ltd
County Hall, Floor 5, Westminster Bridge Road, London, SE1 7PB
Your right to lodge a complaint
If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details provided on the ‘Contact us’ section of this Privacy Notice.
In addition, you can make a complaint to the Information Commissioner's Office (ICO) at any time.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Please see the ICO website for further information:
