Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) provides information on the personal data being processed by Threeforce B.V., trading under the name Last Mile Solutions, a private company with limited liability established under Dutch law, having its statutory seat in Rotterdam, and its registered office at Zeemansstraat 11A, 3016CN, Rotterdam, The Netherlands as well as its European subsidiaries and affiliate companies (hereinafter individually and collectively referred to as: “Last Mile Solutions“).

Last Mile Solutions can be reached via the following contact details:

Threeforce B.V.
Trading under the name Last Mile Solutions
Zeemansstraat 11A
3016CN Rotterdam, The Netherlands

Telephone number:  +31 10 3126000
Email address: privacy@lastmilesolutions.com

This Policy applies for all personal data processed by Last Mile Solutions and/or on behalf of Last Mile Solutions, which identify or may identify a person (“Personal Data”). These persons involved are hereinafter collectively referred to as data subjects (“Data Subjects”).

Last Mile Solutions reserves the right to review and/or alter the Policy periodically, in order to comply with local and/or European legislation, and for any other purpose deemed reasonably necessary by Last Mile Solutions.

For queries and inquiries about this Policy, please contact the Privacy contact person at: privacy@lastmilesolutions.com


2. Handling of Personal Data

Last Mile Solutions complies with all the Dutch and European laws and regulations relating to the protection of personal data, including but not limited to the Dutch GDPR Act (Algemene Verordening gegevensbescherming) (“AVG”) relative to the protection of the personal data and to (EU) General Data Protection Regulation of 27 April 2016 (hereinafter “GDPR“) (“Applicable Laws”).

The Policy is an external policy, and is directed towards Data Subjects whose Personal Data are being processed by Last Mile Solutions for the purpose of producing and delivering products and services. This Policy applies to the processing of Personal Data, in which Last Mile Solutions acts as the data controller within the meaning of the Applicable Laws. This is the case when Last Mile Solutions determines the purpose and the means for the processing of Personal Data of Data Subjects within the scope of this policy.

For business purposes, Data Subjects may be asked to provide their Personal Data. If this is the case, Last Mile Solutions its affiliates and partners shall be required to keep such information confidential.


3. Personal Data

Personal Data mentioned herein and defined by Last Mile Solutions refers to information of all kinds related to each Data Subject – their name, address, email address, mobile phone number, and so on – that are transmitted to Last Mile Solutions by Data Subjects.

The categories of Personal Data Last Mile Solutions processes are:

  • name;
  • last name;
  • title;
  • family name;
  • e-mail address;
  • telephone number (business and private);
  • bank account number;
  • address;
  • business, invoice and delivery address;
  • working experience;
  • role in the organization;
  • department;
  • nationality;
  • IP address;
  • log in history;
  • video images of natural persons;
  • digital pictures of natural persons at events;
  • payment order/history;
  • statistics on the app usage
  • visitor information (date and time);
  • tariffs and prices contained in contracts;
  • invoices and transaction data;
  • password;
  • energy consumption;
  • user (serial) number; and
  • user login ID or username;
  • Charge points ID;
  • Card ID.


4. Purpose and legal basis of data processing

The purposes of the processing of Personal Data by Last Mile Solutions are:

  • sales and material management;
  • marketing and PR activities;
  • payment of invoice and debt management;
  • legal aid (review of contracts);
  • relationship management;
  • maintaining contact with potential business partners;
  • create Purchase Order (PO);
  • camera surveillance;
  • provide service and support;
  • visitor registration;
  • quality control;
  • training customers;
  • package delivery; and
  • contract management;
  • evaluate customer satisfaction;
  • ensure promotion and direct marketing operations;
  • comply with legal and regulatory requirements;
  • carry out market analysis and establish statistics.

In case of video surveillance and in compliance with GDPR rules, Threeforce B.V. shall take care of the following obligations:

  • Duly inform the people that they are being recorded and why;
  • Hold the footage securely;
  • Properly delete the footage when no longer necessary, normally after a 30 day period;
  • Carry out a DPIA.

For more information on the purposes of the processing of Personal Data by Last Mile Solutions, please refer to Annex 1 to this Policy, which includes a table with the purposes, legal grounds and retention periods for the processing of Personal Data.

Legal grounds
Last Mile Solutions is obligated to process the Personal Data in accordance with these purposes and in compliance with the Applicable Laws. The data processing by Last Mile Solutions is necessary for the operation of activities, for which the Data Subject has given its explicit consent, or for the performance of a contract between Last Mile Solutions and the Data Subject, or for the performance of a legal obligation, or it is necessary for the purposes of a legitimate interest pursued by Last Mile Solutions. The Data Subjects have the right to withdraw consent at any time. Also, when the processing is necessary for the performance of the contract between Last Mile Solutions and the Data Subject, the Personal Data processed is necessary to enter into a contract. The legitimate interests for which Last Mile Solutions processes Personal Data are: relationship management, marketing and PR activities contact form for offers and orders, and safeguarding the security of customers and visitors.

Retention period
Last Mile Solutions will not use and store Personal Data longer than necessary to fulfil the above mentioned purposes, and shall remove the collected Personal Data after the necessary period to achieve the purposes described in this Policy has passed, or to comply with contractual obligations or as permitted or required by the Applicable Laws. Annex 1 of this Policy refers to the retention periods for each purpose of processing of Personal Data.

 

5. Purpose limitation

The Personal Data may only be processed to the extent necessary for the described purposes. Personal Data may in principle not be processed for purposes other than that for which the Personal Data were collected. If there is a necessity or need to process Personal Data for other purposes, it shall be investigated by Last Mile Solutions whether the purposes of the intended data processing are compatible with the original purposes. Prior to this further processing, Last Mile Solutions shall provide the Data Subject with information on the new purpose.


6. Security of Personal Data

Last Mile Solutions handles Personal Data carefully and confidentially, and uses all suitable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data.


7. Transfer of Personal Data

Personal Data is being accessed or transferred by Last Mile Solutions and other third parties such as creditors, governments, accounting companies, banks, insurance companies, auditors, package delivery companies (e.g. DHL) data storage servers and security service companies.

In all cases, Last Mile Solutions will expressly state why such information is necessary, so that Data Subjects may provide the information at their own discretion. Last Mile Solutions will not disclose Personal Data provided by Data Subjects to any party, other than Last Mile Solutions itself, without prior permission from the Data Subjects.

Last Mile Solutions implements all the technical and organizational measures to ensure that the processing of your data remains secure and confidential.  To this regard, Last Mile Solutions takes all the necessary precautions, by taking into account the nature of the data and the risks posed by the processing, to keep data secure and, in particular, to prevent it from being distorted, damaged, or that unauthorized third parties have access thereto (physical protection of premises, authentication processes with personal and secure access via confidential identifiers and passwords, connection logging, encryption of certain data).

Last Mile Solutions discloses Personal Data in case such disclosure is mandatory under Applicable Laws or is reasonably judged to be essential in order to protect and safeguard the rights, property and safety of other parties, Last Mile Solutions itself, and/or Last Mile Solutions’ affiliates.

Last Mile Solutions may use the IP addresses of Data Subjects recorded in the system in order to explore the cause of or solution to any problem arising in its servers, or to administer its website.

Circumstances may arise where, whether for strategic or other business reasons, Last Mile Solutions decides to sell, buy, merge or otherwise reorganize businesses. Such a transaction may involve the disclosure of Personal Data to prospective or actual purchasers, or receiving it from sellers. It is Last Mile Solutions’ practice to seek appropriate protection for information in these types of transactions.

Last Mile Solutions may receive/transfer Personal Data to a third country or international organizations outside of the European union/European Economic Area (“EU/EEA”), which shall take place only in compliance with the Applicable Laws, and where appropriate safeguards are in place that ensure the level of protection of Data Subjects as required by the Applicable Laws (e.g. transfers on the basis of an adequacy decision or standard EU Model clauses). The EU Model Clauses are attached to the Data Processing Agreement between Last Mile Solutions and its data processors.

In certain circumstances, it is possible that Personal Data may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.


8. Rights in relation to Personal Data

Data Subjects have the right of information, access, rectification, addition and erasure of Personal Data, and the right to object against or restrict the processing of Personal Data (or withdraw an earlier given consent), as well as the right to data portability. The procedure of Last Mile Solutions that enable Data Subjects to exercise these rights, is described below.

Data Subjects may file a request for access with Last Mile Solutions, and Last Mile Solutions shall promptly respond, and in any event within one (1) month, about:

a) whether Last Mile Solutions holds any Personal Data relating to the respective Data Subject; and,

b) if so, information is provided on the purposes of the processing, the categories, the recipients (if applicable) the envisaged period for which the Personal Data will be stored, or the criteria used, the existence of the right to request rectification, erasure, restriction or to object to such processing, the right to lodge a complaint with a supervisory authority, the existence of automated decision-making, where the data is transferred to a third country, the appropriate safeguards and the source(s) of the Personal Data.

After a Data Subject has accessed the Personal Data, he/she may request Last Mile Solutions to correct, restrict, amend, add, erase and/or transport the Personal Data. Last Mile Solutions informs the Data Subject within one (1) month after receiving the request whether the request shall be complied with (in time), and if not, accompanied with the reasons for the delay or rejection.

Information provided shall be free of charge. Data Subjects can exercise these rights at reasonable intervals. Data Subjects can exercise their rights by contacting Last Mile Solutions’ Privacy contact person in writing (see address above) or by sending an e-mail to: privacy@lastmilesolutions.com

Last Mile Solutions will comply with a legitimate request of a Data Subject for correction, restriction or erasure, if the Personal Data are factually incorrect, incomplete, or irrelevant for the purpose(s) of the data processing, or otherwise processed in violation with the Applicable Laws.

With regard to a request to erase Personal Data, it should be taken into account that Last Mile Solutions shall not comply with such request, if it is incompatible with any legal obligations of Last Mile Solutions.

If a request is allowed, Last Mile Solutions shall execute the decision to correct, amend, erase and/or transport the Personal Data as soon as possible.

In the event of concerns about the handling of Personal Data, Data Subjects also have the right to lodge a complaint with a local supervisory authority, [in the Netherlands: Autoriteit Persoonsgegevens].

 

9. Google Maps

Google Maps can be used on our website, for example in order to calculate the route to our office. Last Mile Solutions in such a case process Data Subject’s location data to find out where Data Subject is and to determine the route. We ask separately whether we are allowed to do this and only use this information with Data Subject’s permission. We use Google’s navigation and location software for this service. When using the Google Map you accept to be bound by Google Maps / Google Earth Additional Terms of Service which are available at: https://www.google.com/intl/pl_US/help/terms_maps/. We use Google Maps under the terms determined by Google (https://developers.google.com/maps/documentation), and, at the same time, we have no control of what the makers of this software (Google) do with it. Data Subject shall always read their privacy statement. More information about data processing by Google can be found in their privacy statement, which is available at: https://policies.google.com/privacy.

When using our mobile apps you can also use Google Maps with information on location of charging stations and, while using this service, the mobile app collects data on your location (without however the possibility to use other functionalities as navigation). Our mobile apps collects data on your location only on the basis of your separate previous consent and only for the purpose of using this service. Data on your location is stored in your devices’ memory and is not transferred to Last Mile Solutions. Using Google Maps in our mobile apps is subject to the abovementioned Google Maps / Google Earth Additional Terms of Service which are available at: https://www.google.com/intl/pl_US/help/terms_maps/ and abovementioned Google privacy statement, which is available at https://policies.google.com/privacy.

 

10. Affiliates

Threeforce B.V., trading under the name of Last Mile Solutions, might also share personal data with its affiliates. Nevertheless, Threeforce is and remains the data controller and owner of all shared and processed personal data. This transfer of personal data is based on the legitimate interest of Threeforce in cooperation with the individual affiliate companies in commercial affairs (Article 6 para. 1 lit. f GDPR) and shall help Threeforce to improve its services.

In order to ensure a level of data protection in line with the requirements of European data protection law and pursuant to Art 46 GDPR, Threeforce has entered into an agreement with its affiliates on intra-group data transfers including EU Standard Contractual Clauses and Transfer Impact Assessment with the respective affiliates.

The respective affiliates are listed in the table below:

Name and address:

Last Mile Solutions SAS
73, rue du Château
92100 Boulogne-Billancourt (France).

Threeforce UK Limited
1 The Sanctuary, Westminster
London, SW1P 3JT (United Kingdom).

Last Mile Solutions Deutschland GmbH
Unter den Linden 21,
10117 Berlin (Germany).

Last Mile Solutions sp. z o.o.,
ul. Stefana Rogozińskiego 6,
31-559 Kraków, Poland.


11. Questions and inquiries

For queries and inquiries about this Policy of Last Mile Solutions, please contact: the Privacy contact person at: privacy@lastmilesolutions.com

Annex 1: purposes of processing, legal grounds and retention periods.*

Purpose of processing Legal ground Retention period
Sales and material management Legitimate interest 7 years after expiration of contract
Offers and orders of the specific services Necessary for the performance of a contract 7 years after the end of the contract
Marketing and PR activities Legitimate interest (marketing and PR) 1 year after the person leaves the position
Payment of invoice and debt management Necessary for performance of a contract 7 years
Legal aid (review of contracts) Legitimate interest (review of contracts) 7 years after expiration of contract
Relationship management Consent and necessary for performance of a contract 7 years, or 2 years after end of the relationship with the customer
Maintaining contact with potential business partners Consent 1 year
Create Purchase Order (PO) Necessary for performance of a contract 5 years after creating PO
Camera surveillance Legitimate interest 30 days, or in case of an incident as long as needed for handling a legal claim
Provide service and support Necessary for performance of a contract 10 years after the purchase, or 2 years after the end of Last Mile Solutions’ contractual obligations.
Visitor registration Legitimate interest (security) 6 months
Package delivery Necessary for performance of a contract 7 years
Contract management Necessary for performance of a contract 7 years after the end of the contract
Commercial cooperation with affiliates and improvement of services quality Legitimate interest 7 years after expiration of contract
Quality control Necessary for the performance of a contract and necessary for compliance with legal obligation For the duration of the warranty (12 years or 25 years performance warranty)
Training customers Legitimate interest For duration of concession, every two years

 

*Retention periods will always follow the legal requirements.