1. Who we are
1.1 Roadwise Group B.V., located at Oudegracht 294, 3511 NX Utrecht, the Netherlands, is responsible for the processing of personal data described in this privacy policy. Roadwise Group B.V. is registered with the Dutch Chamber of Commerce under number 90577434. In this privacy policy, Roadwise Group B.V. is referred to as the Company.
1.2 This privacy policy applies when personal data is processed through Tollvignettes.com, a Roadwise account, an e-vignette order, customer service or another service described in this privacy policy.
1.3 Questions about privacy or requests relating to personal data can be submitted through the available contact form or by email to [email protected].
2. Personal data we collect
2.1 The personal data needed for an e-vignette differs per country and product. This is because each country and vignette provider may have different registration requirements. The Company only asks for data that is needed for the order or for applicable legal, administrative or tax requirements.
2.2 Depending on the e-vignette ordered, the Company may collect:
a. country of vehicle registration;
b. licence plate number;
c. vehicle identification number (VIN);
d. email address;
e. telephone number;
f. first name and last name;
g. address;
h. passport number; and
i. company name, where relevant.
2.3 The Company also processes information about the order. This may include the country, e-vignette type, start date, validity period, amount paid, registration fee, currency, order number, invoice details, order status and information received from the vignette provider.
2.4 Payments are handled by external payment providers. The Company does not store full payment card details or the bank details used to make the payment. The Company may receive information such as the payment method, amount, payment status and transaction reference.
2.5 When someone uses Tollvignettes.com or a Roadwise account, technical information may also be collected. This may include the IP address, browser and device information, date and time of access, pages viewed, clicks, interactions and technical logs.
2.6 Some personal data is required to create a Roadwise account or process an e-vignette order. Where information is required, this will be indicated when the information is requested. If the Customer does not provide the required information, the Company may be unable to create the Roadwise account, process the order or provide the relevant service.
3. Roadwise account
3.1 When a Roadwise account is created, the Company initially stores the verified email address and the order history linked to that email address.
3.2 The email address must be verified before previous orders are shown in the Roadwise account. Orders previously placed with the same verified email address may then automatically be linked to the account.
3.3 Customers can later add or change information in their Roadwise account, including their first name, last name, telephone number, address and passport number. This information may be used for future orders where it is needed.
3.4 Data that is only needed for the Roadwise account is kept for as long as the account remains active, unless the Company has another lawful reason to keep it for longer.
3.5 If a Customer closes their Roadwise account, access to the account is removed. This does not automatically delete order, invoice or other information that the Company must or is permitted to keep.
4. Why we use personal data
4.1 The Company processes personal data where this is necessary to provide a service requested by the Customer or to perform an agreement with the Customer. This includes using account and contact information to create and manage a Roadwise account, and using contact, vehicle and order information to process, register and deliver an e-vignette. Payment and transaction information may also be used to handle payments, refunds, disputes and chargebacks, and relevant contact and order information may be used to provide customer support.
4.2 The Company processes certain personal data because it must comply with legal obligations. This mainly applies to order, invoice, payment and customer information that must be kept or processed for tax, accounting, administrative or other legal requirements.
4.3 The Company may process personal data where this is necessary for its legitimate interests, provided that the Customer's rights and interests do not outweigh those interests. This may include using technical and usage data to keep the Company's services secure and functioning properly, using relevant account, order and technical information to prevent or investigate fraud and misuse, using service and usage information to improve the Company's services, using limited order and contact information to obtain customer feedback and using relevant information to establish, exercise or defend legal claims.
4.4 The Company processes personal data based on consent where consent is required. This applies in particular to marketing emails and certain analytics, advertising and tracking technologies. The Customer can withdraw their consent at any time.
4.5 Withdrawing consent does not affect processing that already took place lawfully before the consent was withdrawn. Where the Company processes personal data on another legal basis, withdrawing consent does not affect processing that is necessary on that other basis.
5. E-vignette registration
5.1 To process an e-vignette, the Company sends the information required for the order to the relevant vignette provider. Only the information needed for that particular country and order is shared.
5.2 Depending on the country, a vignette provider may be a public authority, toll operator, authorised distributor, reseller or another organisation involved in the registration or administration of the e-vignette.
5.3 The Company currently uses or may use the following vignette providers:
Switzerland
Bundesamt für Zoll und Grenzsicherheit (BAZG)
Czech Republic
Státní fond dopravní infrastruktury (SFDI)
Slovakia
Národná diaľničná spoločnosť (NDS)
Slovenia
Družba za avtoceste v Republiki Sloveniji (DARS)
Romania
Scala Assistance SRL
barely digital GmbH & Co. KG
SMS Ticketing SRL
Bulgaria
Intelligent Traffic Systems AD
Yettel Bulgaria EAD
Moldova
S.A. Administrația Națională a Drumurilor
Hungary
Nemzeti Mobilfizetési Zrt.
5.4 The vignette providers used by the Company may change over time. Where more than one provider is available for a country, the Company may choose which provider is used to process the order.
5.5 A vignette provider may process personal data under its own legal responsibility where this follows from its role or applicable law.
6. Payments
6.1 The Company currently uses Nuvei, PAY.nl, PayPal and Revolut Pay to process payments. The provider used depends on the payment method selected by the Customer.
6.2 Payment providers process the information they need to complete, verify and administer the payment. For some processing they act on behalf of the Company, while for other processing they may have their own legal responsibilities.
6.3 The Company only receives the payment information it needs to manage the order, payment, refund, dispute or chargeback. The Company does not store full payment card details.
7. Customer service
7.1 If a Customer contacts the Company, the Company processes the information needed to answer the question or resolve the issue. This may include contact details, correspondence, order information and other information provided by the Customer.
7.2 The Company uses Trengo to manage customer service communications. Customer service data may therefore be processed through Trengo on behalf of the Company.
8. Reviews
8.1 After an order, the Company may share the Customer's email address and order ID with Trustpilot. Trustpilot uses this information to send a review invitation on behalf of the Company.
8.2 The Company uses this information to collect genuine customer feedback and improve its services. Where permitted by law, this processing is based on the Company's legitimate interest in receiving feedback from its Customers.
8.3 Customers can object to the use of their data for review invitations by contacting [email protected] or by using the options provided in the invitation.
8.4 If a Customer chooses to post a review, Trustpilot may process information relating to that review under its own privacy terms.
9. Marketing
9.1 The Company only sends marketing emails where the recipient has given the required consent.
9.2 The Company uses Klaviyo to manage marketing emails, mailing lists and communication preferences. Klaviyo may process information such as the Customer's email address, marketing preferences and interactions with emails.
9.3 Marketing consent can be withdrawn at any time by using the unsubscribe link in an email or by contacting [email protected].
9.4 Withdrawing marketing consent does not stop service messages that are needed for an order or Roadwise account.
10. Cookies and analytics
10.1 Tollvignettes.com and the Roadwise account use cookies and similar technologies. Some are needed for the website, account, security or other basic functionality.
10.2 Analytics, advertising and other non-essential technologies are only used after consent where the law requires this.
10.3 Depending on the Customer's cookie choices, the Company may use Google Analytics, Google Ads, Google Tag Manager, Hotjar and Converge. These services help the Company understand how its services are used, improve the user experience, measure performance and measure or optimise advertising.
10.4 These technologies may process information such as IP address, online identifiers, browser and device information, pages viewed, clicks, interactions and session information.
10.5 Customers can change or withdraw their cookie choices through the cookie settings provided by the Company.
11. Hosting and technical providers
11.1 The Company uses Google Cloud for hosting, infrastructure and technical storage. Personal data may therefore be stored or processed using Google Cloud systems.
11.2 The Company may also use other technical suppliers that are needed to operate, secure, maintain or develop its services. These suppliers only receive access to personal data where this is needed for the service they provide.
12. Who we share personal data with
12.1 The Company does not sell personal data.
12.2 Depending on the services used, personal data may be shared with:
a. vignette providers and public authorities;
b. payment providers;
c. hosting and technical service providers;
d. customer service providers;
e. analytics and tracking providers;
f. marketing providers;
g. review platforms; and
h. professional advisers where necessary.
12.3 Personal data may also be disclosed where the Company is required to do so by law, a court or a competent authority. The Company may also disclose information where this is reasonably necessary to handle or defend a legal claim.
13. Transfers outside the EEA
13.1 Some of the Company's service providers or vignette providers may process personal data outside the European Economic Area.
13.2 When personal data is transferred outside the EEA, the Company uses a transfer mechanism permitted under applicable data protection law. Depending on the country and recipient, this may include:
a. an adequacy decision of the European Commission;
b. the EU-US Data Privacy Framework for certified organisations;
c. Standard Contractual Clauses approved by the European Commission, together with additional safeguards where required; or
d. another transfer mechanism allowed by applicable law.
13.3 Customers can contact [email protected] for more information about the safeguards used for a specific international transfer.
14. How long we keep personal data
14.1 The Company does not keep personal data for longer than necessary, unless the law requires or permits it to be kept for longer.
14.2 Order, invoice and customer information that forms part of the Company's tax or administrative records is generally kept for seven years.
14.3 Information that is only connected to a Roadwise account is kept while the account remains active. After the account is closed, information that is no longer needed for another lawful purpose is deleted or anonymised.
14.4 Information that must still be kept because of a legal obligation, such as order or invoice records, remains stored for the applicable retention period even after a Roadwise account is closed.
14.5 Marketing information is kept until consent is withdrawn or the information is no longer needed for marketing. The Company may keep limited information to record that someone has unsubscribed so that marketing is not sent again without a new opt-in.
14.6 Technical, analytics, cookie and customer service data is kept only for as long as it is reasonably needed for the relevant purpose. The exact period may depend on the type of data, the settings of the service used and applicable legal or security requirements.
15. Security
15.1 The Company takes appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, unauthorised disclosure and other unlawful processing.
15.2 The Company reviews its security measures and updates them where appropriate, taking into account the type of personal data processed and the risks involved.
15.3 No online system can be guaranteed to be completely secure. Customers are also responsible for keeping their Roadwise account login details secure and should contact the Company if they believe someone has accessed their account without permission.
16. Automated decision-making
16.1 The Company does not make decisions about Customers solely through automated processing where those decisions have legal or similarly significant effects on them.
17. Your privacy rights
17.1 Customers have the right to ask the Company what personal data it holds about them and to receive a copy of that data.
17.2 Customers can ask the Company to correct personal data that is inaccurate or incomplete.
17.3 Customers can ask the Company to delete personal data where the law gives them that right. The Company may still keep information that it is legally required or otherwise legally permitted to retain.
17.4 Customers may also have the right to ask the Company to restrict how their data is used, object to certain processing or receive certain data in a portable format.
17.5 Where processing is based on consent, consent can be withdrawn at any time. This does not affect processing that already took place before the consent was withdrawn.
17.6 Privacy requests can be submitted through the available contact form or by email to [email protected]. The Company may ask for information needed to verify the identity of the person making the request.
17.7 The Company will respond within the time limits required by applicable data protection law.
17.8 Customers also have the right to submit a complaint to a data protection authority. Because the Company is established in the Netherlands, a complaint can be submitted to the Dutch Data Protection Authority, Autoriteit Persoonsgegevens. Depending on the circumstances, a Customer may also be able to complain to the data protection authority in their own country.
18. Age
18.1 The Company's e-vignette services and Roadwise accounts are intended for people aged 18 or older. The Company does not knowingly offer Roadwise accounts or e-vignette services to people under the age of 18.
19. Changes to this privacy policy
19.1 The Company may update this privacy policy if its services, processing activities, service providers or legal obligations change.
19.2 The latest version will be available through Tollvignettes.com and through the Company's Roadwise services. Where required by law, material changes that significantly affect existing Roadwise account holders will also be communicated to them.