1. Privacy statement

 

Privacy statement  

OG Group 

 

This privacy statement applies to the processing of personal data as joint controllers within the meaning of the General Data Protection Regulation ("GDPR") by the following entities: 

 

  • OG Clean Fuels B.V. (KvK number: 01127387), based at De Strubbenweg 4, 1327GE Almere; 

  • OrangeGas Amsterdam B.V. (KvK number: 59334541), based at Pluto 3, 8448CM Heerenveen; 

  • OrangeGas Utrecht B.V. (KvK number: 59410507), based at Pluto 3, 8448CM Heerenveen; 

  • OrangeGas Overijssel B.V. (KvK number: 59216867), based at Pluto 3, 8448CM Heerenveen; 

  • OrangeGas Fryslân B.V. (KvK number: 61877980), based at Pluto 3, 8448CM Heerenveen;  

  • OG H2 B.V. (KvK number: 80768644), based at Pluto 3, 8448CM Heerenveen; 

  • Groengas Bollenstreek B.V. (KvK number: 53398513), based at Pluto 3, 8448CM Heerenveen;  

  • OrangeGas Projects B.V. (KvK number: 63840901), based at Pluto 3, 8448CM Heerenveen; 

  • OrangeGas Germany GmbH, (registration number at Trade Register: 209874), based at Nikolaus- Kopernickus-Straße 12, 27283 Verden; 

  • OrangeGas Sverige AB, (registration number at Trade Register: 556669-8543), based at Norra Ågatan 10 A, 416 64 Göteborg; 

  • OrangeGas Italy S.R.I., (registration number at Trade Register 12233000962) based at Piazza Belgioioso 2, 20121 Milaan. 

 

hereinafter collectively referred to as "OG Group". Joint controllership means that the entities above, jointly determine the purpose and means of processing personal data. Based on internal policies, the different roles and responsibilities of these entities are defined. 

 

This privacy statement applies to the processing of personal data of: 

 

  1. Website and social media visitors 

  1. Customers 

  1. Visitors of refuelling locations 

  1. Applicants 

  1. Suppliers & (Fuel) Partners 

OG Group considers the protection of your privacy important. OG Group has therefore prepared, among other things, this privacy statement. The purpose of this privacy statement is to be transparent about how OG Group collects, uses and protects your personal data in accordance with Articles 13 and 14 of the GDPR.  

 

What is personal data? 

Under the GDPR, personal data is any information about an identified or identifiable natural person. This means that information is either directly about someone or can be traced back to that person.  

 

For what purposes do we process personal data? 

We process your personal data only for specified, explicit and legitimate purposes. Below you will find more information on the different purposes for each category of data subject.  

 

  1. WEBSITE AND SOCIAL MEDIA VISITORS 

 

  1. For answering your questions when you contact us, for example through the contact form on the website 

 

What does this purpose entail? 

Our website contains our contact details, and we use web forms and a chatbot. This allows you to contact us. When you contact us and/or fill in a web form, we process the personal data you provide in order to contact you and answer your question. The legal basis for this processing lies in our legitimate interest to contact you in response to your enquiry (Article 6(1)(f) GDPR).  

 

What personal data do we process for this purpose? 

We only process the personal data you provide to us, for example through a web form. This may include, for example, name, contact details (telephone number, e-mail address), and the information you provide in your message/during our contact. 

 

  1. To send our monthly newsletter 

 

What does this purpose entail? 

We think it is important to share our knowledge. That is why we process your personal data, for example, when you subscribe to our newsletter via our website. The legal basis for this purpose is your consent (article 6(1)(a) GDPR).  

 

What personal data do we process for this purpose? 

We process your name and e-mail address for this purpose. 

 

  1. For analysis and to develop our website, products and services (through functional and analytical cookies) 

 

What does this purpose entail? 

We also process personal data of yours, which you provide to us indirectly. This is because our website uses cookies for functional and analytical purposes. The functional cookies are necessary for the use of the website.  

The legal basis for analytical cookies is consent, which you give by agreeing to our cookie terms in the cookie banner on the website (Article 6(1)(a) GDPR) or, in the case of functional cookies, our legitimate interest in a well-functioning and secure website (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

To do so, we process your location data, IP address or app IDs, internet browser and device type and website language. For more information on the use of cookies on our website, please refer to our Cookie Statement. 

 

International transfer 

To process personal data through the cookies, we use Google in the United States. This means that there is an international transfer. We have put in place appropriate safeguards by agreeing the model contract as approved by the European Commission (Standard Contractual Clauses, C(2021)3972) with our processor. 

 

  1. CUSTOMERS 

 

We process personal data of customers, their employees, contact persons and third parties engaged by them. The customer is responsible for informing third parties engaged by the customer of the content of this privacy statement. A copy of this privacy statement can be found on our website.  

 

  1. To perform our services/agreement (day-to-day business operations) 

 

What does this purpose entail? 

For the performance of our fuel (fuel card) services, including facilitating our (refuelling stations) maintenance services, payments (also for car washing services), managing customer cards, providing easy access to your data through our web portal, booking sessions for payments, fuel card management and travel card management, we process personal data of the customer or her employees. This allows us to perform our services efficiently and effectively and maintain contact with you. The processing of personal data for this purpose is necessary for the conclusion or performance of a contract with you (Article 6(1)(b) GDPR), our legitimate interest in the efficient and effective performance of our services (Article 6(1)(f) GDPR) and the fulfilment of our statutory administration obligations (Article 6(1)(c) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process your name, telephone number, Chamber of Commerce number (as a business client), e-mail address, address details, account and VAT numbers, license plate, fuel card company, milage, bank account number (including SWIFT/IBAN) and other relevant information provided during the execution of the agreement. 

 

  1. For the use of our app 

 

What does this purpose entail? 

We have developed an app to provide our customers with easy access to services such as our route planner for detailed directions to our refuelling locations (through Google Maps), registering malfunctions, our loyalty program and online shop purchases. Additionally, we can send you notifications (e.g. in case of a technical malfunction or special offers). 

For this purpose, we process your personal data. The legal basis for processing your personal data for general use of our app (e.g. the route planner, registering malfunctions etc.) is the performance of a contract (Article 6(1)(b) GDPR). The legal basis for processing your personal data for marketing purposes (e.g. special offers) is our legitimate interest to carry out marketing activities through the use of an app and provide our customers with special offers (Article 6(1)(f) GDPR).  

 

What personal data do we process for this purpose? 

We process your name, telephone number, e-mail address, address details, vehicle type, order history with loyalty points, check-ins (location details when refuelling), location details when planning your route, and your self-completed notification of a malfunction. 

 

  1. For our loyalty program and online shop purchases 

 

What does this purpose entail? 

We offer our customers the possibility to purchase products and/or services online. It is also possible to take part in our loyalty program and access this program online. We process your personal data for the use of these functionalities. The legal basis for processing your personal data when you make online purchases and/or take part in our loyalty program, is the conclusion/performance of a contract (Article 6(1)(b) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process your (company) name, telephone number, e-mail address, address details, order history, and loyalty points. 

 

  1. To notify us of errors/malfunctions 

 

What does this purpose entail? 

It is important to us that all of our systems work properly. However, technical malfunctions and other errors may still occur at our refuelling locations. It is important that any errors are brought to our attention quickly, so that we can fix the problem as soon as possible. It is possible for our customers to notify us of any errors. When receiving and handling these reports, we process your personal data, for example, to keep you up to date or to contact you regarding the error/malfunction. 

The legal basis is our legitimate interest to enable customers to notify us of errors/malfunctions, so that we can solve them as soon as possible (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process your name, e-mail address, and telephone number in case you want to be kept up to date or to contact you regarding the error/malfunction. 

 

  1. Communication purposes, including customer service 

 

What does this purpose entail? 

Our website contains our contact details, and we use web forms and a chatbot. This allows you to contact us. When you contact us and/or fill in a web form, we process the personal data you provide in order to contact you and answer your question. In addition, contact during the course of our services may also be important or occur in other areas, for example to handle questions about our agreement. The legal basis for this processing lies in our legitimate interest to contact you in response to your query (article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

We process your name, telephone number, e-mail address, reservation number, and the information you provide in your message/during our contact for this purpose. 

 

  1. Marketing 

 

What does this purpose entail? 

If you give us your consent, we may use your personal data for OG Group's marketing activities. For example, we may send you marketing messages and our newsletter. In some cases, we may share pictures and videos made for case studies or positive reviews on our website, in our newsletter, or on social media platforms such as LinkedIn, Facebook or Instagram. Should you no longer wish to receive our marketing messages or newsletter, you can use the opt-out at the bottom of the e-mail. Should you wish for your pictures and/or videos to be removed from our website, newsletter or social media platform(s), you can notify us of this by withdrawing your consent via e-mail. 

The legal basis for processing your personal data for marketing messages and our newsletter is our legitimate interest in undertaking marketing activities (Article 6(1)(f) GDPR). The legal basis for processing your personal data to share pictures and videos made for case studies or positive reviews is your consent (Article 6(1)(a) GDPR). 

  

What personal data do we process for this purpose? 

We process your name, e-mail address, telephone number, and pictures and/or videos for this purpose. 

 

  1. Analytics to improve functionalities on our platform, map trends, and for forecasting 

 

What does this purpose entail? 

It is important to us to always offer our customers the best possible experience. Therefore, we use analytics to improve functionalities on our platform, map trends and make use of forecasting. The legal basis is our legitimate interest to offer our customers the best possible experience and to improve/alter our services where necessary (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process your e-mail address and customer ID. 

 

  1. To develop our business, map opportunities for business growth and contact potential customers 

 

What does this purpose entail? 

To develop our business, we process your personal data in our database to determine whether our services could be of use to you as a (potential) customer. The personal data in this database is obtained from LinkedIn, ANFIA, and other data brokers. We also use this database to decide whether to contact you to offer our services. The legal basis for this is our legitimate interest in developing our business and finding and contacting potential customers (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process your company name, the contact information of the corresponding contact person (inter alia, the fleet manager), vehicle type, license plate, brand and model of vehicle, fuel, and phone number. 

 

  1. VISITORS OF REFUELLING LOCATIONS 

 

  1. CCTV (security) 

 

What does this purpose entail? 

For the security of our refuelling locations, and to determine whether you are a regular customer, CCTV cameras have been installed that record the activities around the refuelling locations. We process the footage from CCTV cameras for the following purposes: 

  • Monitoring of the security of Customers refuelling locations, e.g. prevention or detection of crime or equivalent malpractice (including fraud), and identification of unauthorized or illegal actions or unsafe circumstances at OG Group’s refuelling locations and to assist in providing relevant evidence;   

  • The prosecution of offenders by public authorities;   

  • Ensuring that health and safety rules and OG Group procedures are being complied with; and  

  • Remote assistance of customers.  

At some of our refuelling locations, we have installed these CCTV cameras ourselves. At other refuelling locations, it is possible for us to request access to camera footage recorded by CCTV cameras installed by (fuel) partners, for example when an incident has occurred. In these cases, your personal data is obtained from our (fuel) partners. 

The legal basis for this is our legitimate interest in securing our refuelling locations and/or identifying regular customers (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process the camera footage recorded at and around our refuelling locations. 

 

  1. APPLICANTS 

 

  1. For a responsible, effective and efficient recruitment and selection process 

 

What does this purpose entail? 

To recruit and select new employees or contractors (self-employed persons without staff who perform temporary work on an interim basis by means of an assignment agreement), we process personal data. We do this to assess whether the applicant or contractor is suitable for the open position.  

 

This personal data is stored as standard for up to two months after the closing date of the vacancy. This way, we can still speak to you in detail if you have questions about the outcome of your application during this period. If the application results in an appointment, the relevant personal data are retained in accordance with our retention policy and our privacy statement for employees and/or contractors.  

 

The legal basis is our legitimate interest in carrying out the recruitment and selection procedure efficiently and to be able to speak to applicants with any questions about the outcome of the application (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

We process your contact details (such as name and address, e-mail address and telephone number), the personal data from your CV and motivation letter, an interview report, if relevant a salary proposal (benefits), and in some cases the data as a result of calling up the references you provided. 

 

  1. Saving your CV for suitable vacancies in the future 

 

What does this purpose entail? 

In order to contact you in the future if we appear to have a suitable vacancy, we process your personal data. The legal basis for this is our legitimate interest to find suitable employees for future vacancies (Article 6(1)(f) GDPR). 

 

What personal data do we process for this purpose? 

For this purpose, we process your contact details (such as name and address, e-mail address and telephone number), the personal data from your CV and your motivation letter. 

 

  1. SUPPLIERS & (FUEL) PARTNERS 

 

  1. To execute agreements, such as orders and commissions (day-to-day business) 

 

What does this purpose entail? 

For the execution and settlement of our orders and assignments with you as a supplier or (tank) partner, we process personal data of (employees of) our suppliers and/or (tank) partners. This personal data helps us to provide you with the right information for placing an order. We also process your personal data to schedule you to carry out maintenance and/or carry out repairs at our refuelling locations. The legal basis for processing personal data for this purpose is the conclusion or performance of a contract (Article 6(1)(b) GDPR).  

 

What personal data do we process for this purpose? 

For this purpose, we process your name, salutation, position, telephone number, Chamber of Commerce number, employer, e-mail address, address details, account and VAT numbers and other relevant information provided during the execution of the agreement. 

 

Your rights 

You have the right to be properly informed about what we do with your data and why we need your data. We do this through this privacy statement. In addition to the right to be transparently informed, you have the following rights: 

  • Right to access (if you want to know what personal data we collect from you); 

  • Right to rectification (we are happy to amend any personal data that is no longer correct); 

  • Right to be forgotten (in some cases, you can ask us to delete your personal data); 

  • Right to restrict processing (in some cases, you may ask us to restrict the processing of your personal data); 

  • Under circumstances, right to data portability (if you want, we can transfer your personal data to another party or give you a copy of your personal data); 

  • Right to object (in some cases, you may object to the use of your personal data). 

If you wish to exercise any of your rights, please contact us by emailing legal@ogcleanfuels.com. To prevent abuse, we may ask you to adequately identify yourself before we process your request. Circumstances may arise which prevent us from fulfilling or not fully fulfilling your request. If such a circumstance arises, we will notify you. We will always respond to your request within one month.  

 

With whom do we share personal data? 

OG Group does not sell or trade your personal data to any third party. OG Group may be required by specific laws and regulations to provide certain personal data to third parties, such as government agencies. In addition, we may share your personal data with third parties to protect our own rights or those of others.  

Internally, only employees of ours have access to personal data to the extent relevant to their work (on a need-to-know basis) and all our employees have a confidentiality clause in their employment contract. 

We also engage processors who process personal data on our behalf. We conclude processing agreements with them that meet the requirements of the GDPR. For example, with regard to reporting data breaches and taking appropriate technical and organisational measures. In addition, personal data may be shared with: 

  • Fuel card providers: through OG Group you can apply for a fuel card of OG Group or a third-party fuel card provider (for example Lodder, Allcard, DKV, Travelcard). If you apply for a fuel card through OG Group, then we will forward your registration to the relevant fuel card provider. The fuel card provider acts as data controller and will contact you to execute the agreement. Please see the privacy statement of the relevant fuel card provider for more information on their processing activities. 

  • Law enforcement agencies: if the footage recorded by CCTV cameras could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness, we could share this footage with law enforcement agencies to provide evidence and prevent/detect crime or equivalent malpractice. 

  • Line managers involved with OG Group disciplinary and performance management processes. 

  • Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders). 

  • A dispute resolution institute and/or competent judicial authority. This may apply to personal data of customers and/or third parties. 

  • Potential new shareholders and their advisers. 

  • IT service providers. While maintaining, managing and supporting our systems and applications, they may have limited access to various personal data.  

  • Other service providers involved in our services, such as external consultants, lawyers and accountants. 

  • Bailiffs and administrators. We provide your name and contact details, financial data and employment details.  

  • Insurers.  

How long do we keep your personal data? 

We keep your personal data for as long as necessary for the purpose for which we use your personal data and/or as long as the law requires us to keep the personal data. Exactly how long varies. From a few months to many years, for example because it is necessary for our accounting purposes. We have defined the retention periods for each processing activity in our retention policy. We retain personal data of job applicants for up to 4 weeks after the recruitment and selection procedure. With your consent, we keep your data for an additional 12 months for any future vacancies.  

 

Consent 

If we process your data on the basis of your consent, you always have the right to withdraw your consent. This can easily be done by sending an e-mail to legal@ogcleanfuels.com. In that case, if we have no other basis for processing, we will no longer use your data for this purpose. 

 

How do we protect your data? 

Under Article 32 GDPR, we are obliged to take appropriate technical and organisational measures to prevent the loss of personal data or unlawful processing. So we have taken physical, administrative, organisational and technical measures. Periodically, we evaluate the technical and organisational measures and adjust them if necessary. Our organisation is set up in such a way that we do everything possible to prevent data leaks. If there is a data breach, we will act in accordance with the data breach protocol. 

 

Contact and complaints 

If you have any questions about this privacy statement or wish to exercise your rights as a data subject, please contact us at legal@ogcleanfuels.com. 

 

In case of complaints about, for example, how we use your data or how we respond to privacy-related questions, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). 

 

Heerenveen, February 2025