Privacy Policy

- concerning client’s personal data (including Battery Empire.co.uk online shop)

and

- shipment receipent from Battery Empire.co.uk online shop

Introduction

We (hereafter ‘Greencell’ ‘We’, ‘Us’, ‘Our’) are Greencell.Global Ltd (Company Number: 13147773) with
our registered office at Fidelity House, Fengate, Cambridgeshire, PE1, Peterborough.

Welcome to Our Privacy Policy.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy aims to
provide a comprehensive overview and explain how We collect and use any personal information and data
We may obtain from you and about you.

1. Important information and who We are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how We collect and process your personal data through
your use of the Website (https://batteryempire.co.uk/), any data you may provide when you purchase a
product or service or any data you provide to Us during our business relationship.

It is important that you read this Privacy Policy together with any other policies We may provide on specific
occasions when We are collecting or processing any additional personal data about you so that you are
fully aware of how and why We are using your data. This Privacy Policy supplements other notices and
policies and is not intended to override them.

Controller

We are the controller and are responsible for your personal data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights,
please contact us by email [email protected] or telephone us at +44 808 196 5006.

You have the right to make a complaint at any time to the Information Commissioner's Office (‘ICO’), the
UK regulator for data protection issues (see www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact Us in the first instance.

Changes to the Privacy Policy and your data

We keep our Privacy Policy under regular review.
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 your relationship with Us.

2. The data We collect 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 markers have been removed (anonymous
data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:

• - Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• - Contact Data includes billing address, delivery address, email address and telephone numbers.

• - Financial Data includes bank account and payment card (whether credit or debit) details.

• - Transaction Data includes details about payments to and from you and other details of products you have purchased from Us.

• - Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.

• - Profile Data includes your username and password, purchases or orders made by you, yourinterests, preferences, feedback and survey responses.

• - Usage Data includes information about how you use the Website and our products.

• - Marketing and Communications Data includes your preferences in receiving marketing from Us and our third parties and your communication preferences.

We do not collect, use or share any Aggregated Data such as statistical or demographic data for any
purpose.

We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data). Nor do We collect any
information about criminal convictions and offences.

If you fail to provide personal data

Where We need to collect personal data by law, in order to provide the products under the contract We
have with you, or to enforce or perform its terms, 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 goods). In this case, we may have to cancel a product you have with Us but We will notify you if this is
the case at the time.

If you have made a notification that there is illegal content in our services provided on the World of Batteries online shop, pursuant to Article 16(1) of Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on the Digital Single Market for Digital Services and amending Directive 2000/31/EC (Digital Services Act) (OJ EU.L.2022 .277.1 as amended , DSA") ("Application") or you have lodged a complaint against a decision issued as a result of an Application ("Complaint"), we process your personal data in order to comply with our legal obligations (Art. 6(1)(c) RODO):

- as set out in Article 16(1), (4), (5) and (6) of the DSA consisting of (i) accepting a Complaint from you, (ii) processing the Complaint, (iii) informing you of the decision made on your Complaint, (iv) informing you of the possibility to appeal our decision made on your Complaint,

- as set out in Article 16 (1), (4), (5) and (6) and Article 17 (3) (f) DSA to (i) receive a complaint from you, (ii) process your complaint, (iii) inform you of the decision we have made regarding your complaint,

- relating to identifying you as the person authorised to represent the entity on whose behalf you made the Application or filed the Complaint (if applicable),

- as set out in Article 18(1) of the DSA to inform the law enforcement authorities or judicial authorities of the Member State(s) concerned of any suspicion that a criminal offence endangering the life or safety of a person or persons has been, is being or may be committed and to provide all available information on this subject.

If, on the other hand, you submit or publish content (e.g. reviews of our products) within the World of Batteries online shop, we may also process your data in order to inform you of the decision we have made regarding the content you have submitted/published to which the Submission or Complaint relates and to comply with our legal obligations set out in Article 18(1) of the DSA referred to above.

To the above extent, we will also process your personal data for the purposes of establishing, asserting or defending claims, on the basis of Article 6(1)(f) of the DPA.

We process the following personal data of persons who have made a Report of Illegal Content in the services provided by the Battery World online shop or made a Complaint:

1. first name, last name,

2. e-mail address,

3. data concerning the entity on whose behalf you are making the submission and your position (if applicable),

4. other data provided in your Application or Complaint.

Our website, like most modern websites, uses functions provided by third parties, which involves the use of cookies from third parties.

Analysis and statistics. We use the following tools in this regard:

Google Analytics. The information collected by this tool is completely anonymous and does not allow you to be identified. Google LLC cookies associated with the Google Analytics service are used for this purpose. The use of Google Analytics involves the implementation of a tracking code provided by Google in the code of our website. This code is based on cookies, but may also use other tracking technologies. Detailed information about Google Analytics can be found at https://www.google.com/intl/en_us/analytics/.

You can prevent your personal data from being processed in this way (block Google Analytics) by making the appropriate choices on the website available here: https://tools.google.com/dlpage/gaoptout

Hotjar. The information collected by this tool is completely anonymous and does not identify you, but nevertheless may be considered personal data under the RODO. Cookies from Hotjar Ltd. regarding the Hotjar service are used for this purpose. The use of the Hotjar service involves the implementation of a tracking code provided by Hotjar in the code of our website. This code is based on cookies, but may also use other tracking technologies. Detailed information about Hotjar can be found at https://www.hotjar.com/legal.

Marketing. We use the following marketing tools:

We have implemented the so-called Facebook Pixel in the code of our website, which remembers your visits and also monitors your purchases and shopping preferences. Facebook cookies are used for this purpose. This results, among other things, in Facebook displaying our advertisements to you or sending you a reminder to complete your purchase (so-called remarketing). For information on the purpose and scope of the collection of your personal data, the further processing and use of your data by Facebook, as well as your rights and the possibility of making appropriate settings to protect your privacy, please refer to the Facebook Data Policy: https://www. facebook.com/policy.php and the Facebook Cookie Policy: :https://www.facebook.com/policies/cookies

If you do not want Facebook to collect data about you via our website, you should log out of Facebook before visiting our website.

Customer Interaction. We use the following marketing tools:

Smartsupp. We have included a chat tool on the website provided by Smartsupp.com, s.r.o. based in Brno, Czech Republic. Cookies from this provider are used precisely to manage the chat service. If you contact us using it with your separate consent (implicitly given, i.e. by providing us with your contact details) we may process your personal data to provide you with an appropriate level of service, in particular to reply to your message.

The legal basis for processing your personal data is therefore Article 6(1)(a). RODO (the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes), pursuant to Article 10(2) of the Act on the provision of electronic services.

You may withdraw your consent at any time (without affecting the lawfulness of the processing carried out on the basis of consent prior to its withdrawal) by contacting us via the chat tool, as well as by email or telephone.

Site functionality. We use the following tools to improve the functioning of the World of Batteries online shop website:

OneSignal. Cookies from this provider are linked to sites using CloudFlare and are used to speed up page load times. They do not contain any data that identifies the user.

With separate consent, we may also process your personal data for other marketing purposes (i.e. to invite you by email to take advantage of an organised promotion and to send you other marketing information.

You can withdraw your consent at any time (without affecting the lawfulness of processing carried out on the basis of consent before withdrawal) by unchecking the relevant checkbox in your account settings.

If you are the person indicated as the recipient of the goods purchased by customers of the online shop Świat Baterii (sometimes the customer indicates a family member, a neighbour, a porter, an employee, their own customer - in the case of so-called dropshipping), the processing of your personal data is based on the legal premise of Article 6(1)(f) RODO, i.e. on the premise of the controller's legitimate interest. This legitimate interest is our desire to perform a contract with a customer who has indicated you as the recipient of the purchased goods. We assume in good faith that the customer has agreed this with you before providing us with your data, or that collecting shipments is part of your job duties. We conclude from this that when we process your data in the manner described here, we do not do so for purposes other than those for which it was obtained from you by our customer.

Where you include consent to receive marketing content from us at the email address you have provided, your personal data will be processed on the basis of Article 6(1)(a) of the DPA based on your informed and voluntary consent, and on the basis of Article 6(1)(f) of the DPA based on our legitimate interest as an Administrator in the event that we target you with content tailored to your interests.

We process the following personal data of persons who have made a Report of unlawful content in the services provided by the Battery World online shop or made a Complaint:

1. first name, last name,

2. e-mail address,

3. data concerning the entity on whose behalf you are making the submission and your position (if applicable),

4. other data provided in your Application or Complaint.

Your data may also be communicated to entities whose disclosure is required by applicable law or by an order of a court or other authority, including public administration authorities, including law enforcement agencies, who request access to your personal data from us as part of an entitlement under the law or to whom we provide personal data on the basis of an obligation under the law, in particular Article 18 DSA.

To the above extent, we will also process your personal data for the purposes of establishing, asserting or defending claims, on the basis of Article 6(1)(f) of the DPA.

3. How We collect the data.

We use different methods to collect data from and about you including through:

• - Direct interactions. You may give Us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. apply for Our products whether when using the Website or otherwise;

2. request marketing to be sent to you;

3. give Us feedback or contact Us.

• - Automated technologies or interactions. As you interact with Our website, We will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies

• - Third parties or publicly available sources. We will receive personal data about you from publicly available sources, such as Companies House or the electoral register in the UK.

We process the following personal data of persons who have made a Report of Illegal Content in the services provided by the Battery World online shop or made a Complaint:

1. first name, last name,

2. e-mail address,

3. data concerning the entity on whose behalf you are making the submission and your position (if applicable),

4. other data provided in your Application or Complaint.

4. How We use your personal data

We will only use your personal data when the law allows Us to. Most commonly, we will use your personal
data in the following circumstances:

• - Where We need to perform the contract we are about to enter into or have entered into with you.

• - 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.

• - Where we need to comply with our legal obligation.

Generally, We do not rely on consent as a legal basis for processing your personal data although We will
get your consent before sending third party direct marketing communications to you via email or text
message. Where consent applies, you have the right to withdraw consent to marketing at any time by
contacting Us.

Purposes for which We will use your personal data

We have set out below, in a table format, a description of all the ways We plan to use your personal data,
and which of the legal bases We rely on to do so. We have also identified what our legitimate interests are
where appropriate.

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. Please contact Us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in
the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing
and advertising.

Promotional offers from us

We may use your identity, contact, technical, usage and profile data to form a view on what We think you
may want or need, or what may be of interest to you. This is how We decide which products, services and
offers may be relevant for you (we call this marketing). The marketing communications from us will be in
respect of the products similar to one you have purchased from us already.

Third-party marketing

We will get your express opt-in consent before We share your personal data with any third party for
marketing purposes.

Opting out

You can ask Us or third parties to stop sending you marketing messages at any time by contacting US using the contact details in this Privacy Policy. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a product purchase, warranty registration, product experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of the Website may become
inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which We collected it, unless We reasonably
consider that We need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact Us.

If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the
legal basis which allows Us to do so.

Please note that We may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

5. Disclosure of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in
section 4 of this Privacy Policy:

Legal advisors that provide services to us;

• - Payment services companies;

• - Accounting companies;

• - Hosting companies, in particular who operate the Website on Our behalf;

• - Insurance companies;

• - Companies responsible for Our software;

• - Couriers and haulage companies.

We may share your personal data whenever We are legally obliged to do so. Nevertheless, We assure you
that every request to disclose your personal data is analysed very carefully and thoroughly, to avoid
passing any information inadvertently to unauthorised persons.

We may change the suppliers We use. If you wish to obtain a full list of our suppliers or require any further
information with this regard, please contact Us using the contact details in this Privacy Policy.

International transfers

We do not routinely transfer your personal data outside of the UK, with the exception that we will transfer
your personal data to:

• - CSG S.A. of 33 Kalwaryjska street, Kraków, Poland (‘CSG’) – this is because CSG operate the Website on Our behalf and it is critical for Us to be able to share your personal data with them for reasons as set out in this Privacy Policy, in particular in order to enter and perform the contract with you.

• - ECOVIS Wingrave Yeats: Waverley House, 7-12 Noel Street, London, W1F 8GQ, UK (‘Ecovis’) –this is because Ecovis are Our accountants and We may share your personal data with Ecovis for reasons as set out in this Privacy Policy, in particular in order to comply with Our legal obligations.

• - Google LLC, Google Ireland Limited and Google Asia Pacific Pte. Ltd. (jointly as ‘Google’) – this is because your personal data may be stored in cloud computing systems operated by Google.

• - Any courier, the name of which will be indicated on the Website, for the purposes of delivering the products to you if you are based outside of the UK.

Where We transfer your data outside of the UK, We will ensure that the protection afforded to your personal
data, by any third party processor who may receive your personal data, is not less comprehensive than the
protection afforded by this Privacy Policy.

We process your personal data to invite you to give feedback on a transaction completed in
Our shop, on feedback aggregation services such as TrustMate (https://trustmate.io/), which
includes disclosing to this service your email address (to enable Us to send you an invitation
to give feedback after a completed transaction), order number and ID and the number of
products purchased. Thanks to the feedback we receive from customers, We can improve
our shop, tailor our offer to your needs and improve the quality of our goods. The
processing of this data is therefore necessary for the purposes of the legitimate interests
pursued by the Administrator.

Insofar as we are concerned with fulfilling our legal obligations in connection with your Notification that there is illegal content in the services provided by the Battery World online shop, your personal data will be processed until the time limit for filing a Complaint has expired and, if a Complaint has been filed, until you have been informed of the decision taken on the Complaint.

Your personal data will be processed for the purposes of complying with our legal obligations and we will process it for the duration of such obligation.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your
personal data to those employees, agents, contractors and other third parties who have a business need to
know. They will only process your personal data on Our instructions and they shall 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
the ICO of a breach where We are legally required to do so.

7. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes We
collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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 to Our relationship with you.

To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your ersonal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.Typically, we may retain your personal data for a period of up to six years from the date of conclusion of our contract with Us or from closing of your account on the Website.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• - Request access to your personal data.

• - Request correction of your personal data.

• - Request erasure of your personal data.

• - Object to processing of your personal data.

• - Request restriction of processing your personal data.

• - Request transfer of your personal data.

• - Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact Us using the contact information in
this Privacy Policy.

No fee usually required

You will not have to pay a fee to access your personal data (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 could refu se 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 data (or to exercise any of your other 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.

Time limit to respon

We try to respond to all legitimate requests within one month. Occasionally it could 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.

YOUR LEGAL RIGHT

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data We hold about you and to check that We are lawfully processing it.

Request correction of the personal data that We hold about you. This enables you to have any incomplete
or inaccurate data We hold about you corrected, though We may need to verify the accuracy of the new
data you provide to Us.

Request erasure of your personal data. This enables you to ask Us to delete or remove personal data
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 data 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 yourpersonal data to comply with local law. Note, however, that We may not always be able to comply with yourrequest of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 data 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.

Request restriction of processing of your personal data. This enables you to ask Us to suspend the
processing of your personal data in the following scenarios:

• - If you want Us to establish the data's accuracy.

• - Where our use of the data is unlawful but you do not want Us to erase it.

• - Where you need Us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• - You have objected to our use of your data but We need to verify whether We have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party
you have chosen, your personal data 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.

Withdraw consent at any time where We are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you
withdraw your consent, We may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.

If you make a Report of Illegal Content on our service or submit a Complaint, providing your data is a legal obligation. Your failure to provide personal data may also result in our inability to process your Report or Complaint.

Last update: February 17, 2024

The version of the Privacy Policy valid until August 31, 2022 can be found here

The version of the Privacy Policy valid until 2023 can be found here

The currently valid version of the Privacy Policy in pdf can be found here