We are committed to providing our customers with excellent customer service. We recognise that customers value their data and privacy, and so we treat our customer data with great care. This page explains out how and/or when we collect, use and share your personal information that you, or others, provide to us.
If you have any questions, or any requests to exercise your legal rights, please do contact our Data Protection Officer via firstname.lastname@example.org
We only collect and process data about you where we have a reason for doing so and only where that reason is permitted under data protection law. This section sets out how we collect and use your data.
It’s important that you keep your personal information with us up to date, so please let us know if anything changes.
When you purchase products or services from us, we will use your personal information to complete your purchase. The details we collect from you may include your name, address, date of birth, email address, phone number, MPAN/MPRN meter details and payment details such as credit or debit card information or direct debit details.
We need to process your personal information in this way to enter and perform the contract for the product or service you have asked us to provide. This may include sending you information about your account, such as statements, payment and meter reading reminders and occasional updates about important changes, such as updates to your Demand Flexibility Service reward mechanism.
When you phone, message or email us with general queries, we may process your personal information (your name, address, contact details and other personal information you’ve given us) in order to provide the customer services you have asked us to, for example providing more information about our reward mechanism for Demand Flexibility.
We rely on your consent to handle your personal information in this way. If you do not provide us with the data we request from you for customer services purposes, we may not be able to fully answer your queries.
We may log and record the interactions you have with us, such as phone calls to help us better service your requests.
This section applies if you have opted in to receive marketing communications from us or have previously expressed an interest in our products and services and have not opted out. We will process your personal information (your name, address, contact details, MPAN and other personal information you’ve given us) to provide you with marketing communications in line with any preferences you have told us about. Where you have opted to receive marketing communications, we rely on your consent to contact you for marketing purposes. If you have not opted in and we send you marketing emails, we do this because of our legitimate interest to promote the success of the products and services you have expressed an interest in. Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them, or you can contact us anytime at email@example.com
We never share your information with any third parties for their direct marketing purposes.
We may sometimes provide personalised advertising via third party platforms. For example, we’ll hash your data (so no one can view it) and reference it against Facebook’s platform. If you have a profile with Facebook, we’ll ask them to exclude you from irrelevant adverts, such as “join VpowerU” adverts, and send you more relevant adverts instead. All of this is done without Facebook revealing your identity to us and vice-versa. We do this on the basis of legitimate interest to ensure that you receive more tailored and relevant information about our products and services.
We may use your personal information to provide you with a more effective user experience, such as by displaying services we think you will be interested in. Using your information in this way means that your experience of our website and apps will be more tailored to you, and the content you see on our website and apps may differ from someone else.
When you visit our website, we will automatically collect the following information:
We may also collect information on your location on our websites and apps, such as your location data when accessing the website or apps in line with the location settings on your phone or internet browser. This can be disabled or amended via the relevant IOS/Android platforms or in your internet browser settings.
We will need to collect half hourly consumption information from the smart meter for payment and settlement purposes, in line with the consents we receive from you about this. We need to collect information from your smart meter so we can accurately pay you for any demand flexibility response.
We will need to request half hourly data for the purpose of demonstrating your demand flexibility response and for us to be able to deliver this product to you. As we are not your energy supplier, we may make this request using an “other user” licence (as defined by Smart Energy Code Administrator and Secretariat).
We may also analyse information we collect from smart meters in order to develop new products and services and to tailor these to your needs. We do this because of our legitimate interest to develop new products and services for the energy market.
We are always looking for ways to make demand flexibility better, for both our customers and for the planet. We may sometimes process your data where we have a legitimate interest for doing so, for example:
Where we do process your personal data, we rely on legitimate interests to process your data in this way, we always carry out a “balancing” test in line with the ICO’s guidance to ensure that our processing is necessary and is not outweighed by your rights to privacy.
As well as the information you provide us with directly, we may also receive information from some third parties.
We work with various affiliates and partners, such as telesales agencies and door-to-door sales agencies, and if you sign up to our services through one of our affiliates or partners, they may send us your personal information.
We may also share your information for the following reasons.
We will transfer your personal information to a third party as follows:
We process your personal information in this way because we have a legitimate interest to ensure our business can be continued by the buyer.
In some circumstances we may need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation, or to allow us to comply with any Ofgem obligations.
Occasionally people may share information which indicates that they, or a member of their household, are in imminent danger or at serious risk, and in line with guidance from the Information Commissioner, in such circumstances we may refer the situation to relevant authorities or sources of assistance. In such cases we will consider first and foremost the interests of the person at risk.
What are cookies, web beacons and similar technologies
These technologies are essentially small data files placed on your computer, tablet, mobile phone or other device (“collectively, a “device”) that allows us to record information when you visit or interact with our websites, service, applications, messaging, and other tools. Though often these technologies are generically referred to as “Cookies,” each functions slightly differently, and is better explained below:
Cookies: Cookies are small (often encrypted) text files placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:
Web beacons: A web beacon (also called “tracking pixels” or “image tags”) is a small file (most often a transparent, 1x1 GIF file) that is loaded on our web pages. These pixels may work in concert with cookies to collect information about your visit, your web browser/device, browsing activity, or onsite behavior and provide that information to service providers. Pixels are most commonly used to collect anonymous traffic metrics (page visits, button clicks, order completion) used to analyse site performance.
Scripts: A script is a small piece of website code placed on our websites to power customer service tools like live chat, allow for the delivery of video tutorials in our help section, and allow us to provide interactive experiences to visitors. They are also used to collect data that we use for website analytics, or to provide data on the effectiveness of our advertising.
Similar technologies: Technologies that store information in your browser or device utilizing local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers. In some instances, these technologies may not be fully managed by your browser and may require management directly through your installed applications or device. We do not use these technologies for storing information to target advertising to you on or off our sites.
What technologies do we use and why
Our cookies, web beacons and similar technologies serve various purposes, but generally they (1) are necessary or essential to the functioning of our sites, services, applications, tools or messaging, (2) help us improve the performance of or provide you extra functionality of the same, (3) help us to serve relevant and targeted advertisements, or (4) allow us to offer support tools that you utilize to interact with our care guides:
Strictly Necessary or Essential: "Strictly necessary" or “essential” cookies, web beacons and similar technologies let you move around the website and use essential features like secure areas and shopping baskets. Without these technologies, services you have asked for cannot be provided. Please note that these technologies do not gather any information about you that could be used for marketing or remembering where you've been on the internet. Accepting these technologies is a condition of using our sites, services, applications, tools or messaging, so if you utilize tools that might prevent these from loading, we can't guarantee your use or how the security therein will perform during your visit.
Performance: Performance technologies may include first or third-party cookies, web beacons/pixels, and scripts placed in order to gather information about how you use our website (pages you visit, if you experience any errors, load times). These cookies do not collect any information that could identify you and are only used to help us improve how our website works, understand the interests of our users, and measure how effective our content is by providing anonymous statistics and data regarding how our website is used.
Advertising: Advertising technology may include first or third-party cookies, web beacons/pixels, and scripts placed in order to gather information on the effectiveness of our marketing efforts, deliver personalized content, or to generate data that allows for the delivery of advertising relevant to your specific interests on our sites, as well as third-party websites. We also utilize 3rd party service providers to assist us in delivering on the same functions, which means that our authorized service providers may also place cookies, web beacons and similar technologies on your device via our services (first and third party cookies). They may also collect information that helps them identify your device, such as IP address, or other unique or device identifiers.
Support: Support technologies may include first or third-party cookies, web beacons / pixels, and scripts placed in order to provide tools for you to interact with our customer support teams. This technology allows us to provide chat services, gather customer feedback, and other tools used to support our visitors. Data collected for these purposes is never used for marketing or advertising purposes.
How to manage, control and delete these technologies
Internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the 'Help' option in your internet browser for more details.
If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings.
More information about cookies
We are based within the UK, however some of the third parties and agents that we work with may be based outside of the European Economic Area (EEA), so their processing of your personal information may involve a transfer of data outside of the EEA.
Whenever we transfer your personal information outside of the EEA, we will always ensure it is protected by making sure we have safeguards in place. This might mean only transferring your personal information to a country that has been deemed by the European Commission to provide an adequate level of protection, or by using specific contractual protections. You can contact us at firstname.lastname@example.org for details of how we protect specific transfers of your data.
All information that you provide us with is stored on our secure servers, or those of our third parties’ data storage providers.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or administrative requirements.
To determine the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information, the applicable legal requirements and whether we can achieve those purposes through other means.
You have various rights under the data protection laws, which you can exercise by contacting us. The easiest way to do this is by email to email@example.com.
You have the right to object to us handling your personal information where we are handling your personal information based on our legitimate interests. If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why we should continue to use your personal information.
You can also ask us to stop handling your personal information for marketing purposes at any time.
You have the right to access your personal information which we are handling, and you are entitled to receive confirmation and details about whether your personal information is being processed by us.
You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to ask us to complete personal information which you think is incomplete.
You can restrict our processing of your personal information where:
Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle any legal claims.
This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us. You have the right to receive your personal information in a structured, standard machine-readable format, and the right to ask us to send your information to another organisation or to give it to you.
You have the right to require us to erase your personal information in the following circumstances:
You have the right to lodge a complaint with the Information Commissioner's Office, the supervisory authority for data protection issues in the United Kingdom.
Our website and apps may contain links to third party websites. If you click on a link to any of these websites, you will leave our website or app and this may allow third parties to collect or share your data. We have no control over the contents of those third party websites and so will not accept any responsibility or liability for any materials on there. We encourage you to check their privacy policies before you submit any personal information to these websites.
We would always rather you speak to us first if you have any questions about our handling of your personal data, so we can resolve any problems as quickly as possible. However, if you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the Information Commissioner’s Office, the UK’s independent authority on data privacy at www.ico.org.uk.