Privacy Policy

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 has been removed (anonymous data).

To provide our utility brokerage and management services, we may collect, use, store and transfer different kinds of personal and business data grouped as follows:

• Identity Data: includes first name, last name, job title, and company name.
• Contact Data: includes billing address, site addresses, email address, and telephone numbers.
• Utility Data: includes MPAN/MPRN numbers, existing supplier details, contract end dates, historical energy/water usage, billing history, and Letters of Authority (LOA) signed by you.
• Financial Data: includes bank account details and payment card details (only if strictly required for setting up direct debits with new suppliers).
• Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

3. How Is Your Personal Data Collected?

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

• Direct interactions: You may give us your Identity, Contact, and Utility Data by filling in forms, uploading bills, or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  • Request a utility quote;
  • Sign a Letter of Authority (LOA) allowing us to negotiate on your behalf;
  • Subscribe to our newsletters or publications;
• Automated technologies: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns using cookies and server logs.
• Third parties or publicly available sources: We may receive data about your business from public registers (such as Companies House) or industry databases (like ECOES or Xoserve) to verify meter details.

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:

• Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., obtaining quotes and setting up utility contracts).
• Legitimate Interests: 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.
• Legal Obligation: Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your data

5. Disclosures of Your Personal Data

To fulfill our role as a utility broker, we may have to share your personal data with the parties set out below for the purposes outlined in section 4:

• Utility Suppliers: Energy, water, waste, and telecom providers. We share your data (authorized by a Letter of Authority) to obtain quotes, negotiate rates, and facilitate the switching process.
• Service Providers: IT and system administration providers who host our CRM, website, and secure document storage.
• Professional Advisers: Including lawyers, bankers, auditors, and insurers based in the UK.
• Regulators: HM Revenue & Customs, Ofgem, Ofwat, Ofcom, and other authorities based in the UK who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

6. Data Security & Retention

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Access to your personal data is limited to those employees, agents, and suppliers who have a strict business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

By law, we have to keep basic information about our clients (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being clients for tax and regulatory purposes.

7. Your Legal Rights

Under the UK GDPR, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data where there is no good reason for us continuing to process it.
• Object to processing of your personal data where we are relying on a legitimate interest.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer using the details below.

8. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer (DPO) in the following ways:

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 (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.