The personal information we collect about you depends on the particular context in which it is processed. We collect personal information about you only where we have a reason for doing so and only where that reason is permitted under data protection law (see the section below ‘Legal basis for processing’). This section of this Privacy Policy sets out what personal information we collect about you as well as how we collect and use that personal information.

When we provide services directly to a business (including Energy Suppliers)  

Where we provide services directly to your business, including providing services relating to gas an electricity meters on your behalf and services relating provision of data, bill validation and other services including digital energy platforms to deliver data services and consumption data to energy suppliers. These services will be governed by a contract between us.

We may require to process personal information relating to your end consumers to enable us to carry out certain services for you, in relation to energy meters or data relating to them. We may also require to process your employee’s personal information in the course of carrying out these services.

The details we collect may include name, address, telephone number, meter reference numbers, meter readings and usage information, details relating to the property, energy consumption data (including half hourly energy consumption data), tariff data and export data, where applicable. We may also require details of any employees or customer’s needs or needs of others in a household such as age, health or vulnerability status to the extent it may be relevant for the carrying out of the services (for example, a disability), to ensure that the service we provide and health and safety considerations are tailored to such circumstances.

Where we are providing services on your behalf, we are acting as a data processor.

In some cases, we may own the gas and/or electricity meters or other assets installed at your properties and/or the premises of consumers. Where that is the case we may require to retain personal information to allow us to maintain and manage the assets. In those cases, we may be the data controller. We may also wish to make our services available, to customise them, to understand individuals’ needs, and to provide improved services, newsletters and other communications. In those cases, we are the data controller.

When we provide services to your energy supplier (Domestic Consumers) 

We may process your personal information in connection with services which we provide on your behalf or in connection with services we provide to a third party (such as energy suppliers or registered social landlords). These services are governed by a contract between us and the third party.

We require to process your personal information when these services are to be carried out at your property or in relation to your energy meters or other assets installed at your property or data relating to them (because you have a contract with, or are entering into a contract with, the energy supplier or other third party).

The details we collect may include name, address, telephone number, gender, meter reference numbers, meter readings and usage information, details relating to the property, energy consumption data (including half hourly energy consumption data), tariff data and export data, where applicable. We may require to carry out identity verification of you on behalf of your energy supplier in connection with the services which we provide (including where we require to obtain your half hourly energy consumption data).  We may also require details of any of your needs or needs of others in your household such as age, health or vulnerability status to the extent it may be relevant for the carrying out of the services (for example, a disability), to ensure that the service we provide and health and safety considerations are tailored to such circumstances.

Where we are providing services on behalf of a third party, we are acting as a data processor.

In some cases, we may own the gas and/or electric meters or other assets (such as solar PV panels,  battery storage systems, heat pumps or electric vehicle charges) installed at your property. Where that is the case, we may require to retain personal information to allow us to maintain and manage the assets and provide associated services in connection with them (such as software applications) which you may choose to use. In those cases, we may be the data controller.

We may also wish to make our services available, to customise them, to understand individuals’ needs, and to provide improved services, newsletters and other communications. With your agreement, we may request to contact you about our or our business partners’ promotions, products and services or other information which we think you may find interesting, or for customer satisfaction purposes (including contact by email), and for market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to us). In those cases, we are the data controller.

When we provide services to your energy supplier (Industrial and Commercial Energy Consumers)  

We carry out services relating to gas and electric meters on behalf of energy suppliers (these services include meter installations, maintenance, data services, and management and support services). These services are governed by a contract between us and the energy supplier.

We require to process your employee’s personal information when these services are to be carried out for an energy supplier at your premises/site, or in relation to your energy meters or data relating to them (because you have a contract with, or are entering into a contract with, the energy supplier).

The details we collect may include, name, address and telephone number of your employees which will normally be business contacts details unless the employee chooses to provide us with personal contact details, meter reference numbers, meter readings and usage information, details relating to the premises or site (such as access information) and details of any vulnerability status of any of your employees or persons on site, to the extent it may be relevant for the carrying out of the services (for example a disability) to ensure that the service we provide and health and safety considerations are tailored to such vulnerability.

Where we are providing services on behalf of a third party, we are acting as a data processor.

In some cases, we may own the gas and/or electricity meters installed at your premises/site. Where that is the case we may require to retain your employees’ personal information to allow us to maintain and manage the assets. In those cases, we may be the data controller.

We may also wish to make our services available, to customise them, to understand individuals’ needs, and to provide improved services, newsletters and other communications. With your agreement, we may request to contact you about our or our business partners’ promotions, products and services or other information which we think you may find interesting, or for customer satisfaction purposes (including contact by email), and for market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to us). In those cases, we are the data controller.

When you purchase products or services from us 

Where you purchase products and/or services from us directly, including electric vehicle chargers and other energy assets, we will use your personal information to complete your purchase and/or to continue to provide services to you, as well as complying with consumer protection law and the contract between us.

The details we may collect may include, your name, address, date of birth, gender, email address, phone number, meter information, energy consumption data (including half hourly energy consumption data), tariff data and export data, where applicable, payment details such as credit or debit card information or direct debit details, information to enable us to undertake credit or financial checks on you, vehicle details (including vehicle registration numbers), details relating to your property, purchase and account history, records of your discussions with us (including customer service or support teams), billing information and your employment information.  We may require to pass your information onto third parties who are engaged in providing the products and services to you, including payment providers or third party providers of energy schemes relating to the products or services purchased by you.

We may also require details of any needs of you or others in the household such as age, health or vulnerability status to the extent it may be relevant for the carrying out of the services (for example, a disability), to ensure that the service we provide and health and safety considerations are tailored to such circumstances.

Where we are providing products or services to you directly, we are acting as a data controller.

When you use products or services provided by us to a third party (such as your landlord)   

Where you use products or services provided by us such as electric vehicle chargers, battery storage systems, heat pumps or solar panels installed at your property, we will use your personal information to deliver these products or services and to continue to improve these products or services, as well as complying with the terms of the agreement between us and a third party (such as your landlord) or with you.

The details we may collect may include, your name, address, date of birth, gender, email address, phone number, energy consumption data, vehicle details (including vehicle registration numbers), RFID hex card or digital tokens,  details relating to your property (including images where required for design and installation purposes), purchase and account history, records of your discussions with us (including customer service or support teams) and billing information.

If you use our electric vehicle charge point services, we may receive your location data in line with the location settings on your phone.

In using products or services provided by us, you are consenting to us processing your personal data for the purposes set out in this Privacy Policy.

In the circumstances where we have an agreement with you directly, we are acting as a data controller and where we are providing these products or services as part of an agreement between us and a third party, we are acting as a data processor.

Half-hourly smart meter data 

As set out in this Privacy Policy, if you permit us to in connection with the products or services provided by us to you, your energy supplier or other third party, we may require to collect your energy consumption data on half hourly basis (every half an hour).

This information will be used to provide the products or services to you, your energy supplier or other third party including to produce improved calculations of your energy consumption.

You are entitled to withdraw your consent to us obtaining your half hourly consumption data at any time however this may impact our ability to continue to deliver products and services to you in the same way.

We may also require to verify your identity in order to obtain your half-hourly consumption data through obtaining  a copy of your energy bill and/or photographic ID and to do this, we may use third party service providers.

When you phone, email or contact us

When you phone or email us with general queries (i.e. not those related to products or services provided to us or services provided by us to a third party, such as your energy supplier), we may process your personal information in order to provide us with the information your have requested.

The details we may collect include, your name, email address, telephone number and other personal information you have given us. This may also include us keeping a record of your interaction with us including recording telephone calls or taking a record of correspondence.

In these circumstances, we are acting as a data controller.

Marketing communications

This section will only apply if you have opted in to receive marketing communications from us or have previously expressed an interest in our products or services.

The details we may collect may include, your name, address, contact details and other information you have given us to provide you with marketing communications in line with any marketing preferences you have told us about.

Where you have opted to receive marketing communications, we rely on your consent to contact you for these purposes or where you we have a legitimate interest to promote the success of products and/or services you have expressed an interest in.

Every communication we send to you for marketing purposes will contain instructions on how to unsubscribe from receiving them.

In these circumstances, we are acting as a data controller.

Use of and to improve our website

When you visit our website, we may require to collect personal information about you relating to your use of the website and/or to provide you with a more effective user experience and/or to ensure the security of our website.

The details we collect may include, technical information including device identifier numbers (such as IMEI numbers and IP address), login information, browser type and version, time zone settings, plug-ins and operating systems as well as information about your visit including page response times, downloads and interaction methods.

You can ask us to stop using your personal information in this way by using the “do not track” functionality in your internet browser.

We may also share aggregated, anonymous data with third party providers including but not limited to analytics providers and search engine providers that assist us in the improvement and optimisation of our digital services.

For further information on how we use cookies on our website, please see here: SMS Cookie Policy

Under data protection law, we can only use your personal information if we have a legal basis to do so, for example:

• Where you have given your consent (e.g. in the case of marketing communications or in the case of analytics relating to our website)
• To comply with our legal and regulatory obligations (e.g. in the case of regulatory investigations or to fulfil our obligations under health and safety legislation);
• In connection with a contract with you or a third party (e.g. where you have purchased products or services from us); or
• For our legitimate interests or those of a third party (which is when we have a business or commercial reason to use your personal information, so long as this is not overridden by your own rights and interests) (e.g. where we require to require sums owed to us for our services via debt collection agencies.

Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing of your personal information prior to the withdrawal of consent.

Where we process your personal information on the basis of legitimate interests, we carry out a balancing test in accordance with our obligations under data protection law to ensure that our processing is necessary and is not outweighed by your privacy rights.