1. INTRODUCTION

• Home Energy is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of our customers and users of our products that communicate (online or offline) with us, over the phone, through our websites and social media platforms.
• We have therefore developed this privacy notice to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

2. WHO ARE WE?

• Home Energy Ltd is a company registered in England and Wales (company number 10364306). Home Energy provides energy supply services to UK customers.
• The data controller is Home Energy.
• You may contact our Data Protection Officer at:
  Data Protection Officer
  Granville Hall,
  Granville Road,
  Leicester
  England
  LE1 7RU
• Or email us at hello@homeenergy.com

3. WHEN DO WE COLLECT YOUR PERSONAL DATA?

• We may collect your personal data in the following circumstances:
• • When we create or administer an account for you.
  • When you contact us by any means including by phone, in writing, by email or online channels including social media.
  • When you register and use any of our online services.
  • From your meter, including SMART meters.
  • When you have given a third party permission to share with us the information they hold about you.
  • When you visit our websites such as cookies, online forms.
  • When you enter competitions.
• We also collect data from publicly available sources such as the electoral role and land registry where the information is made public as a matter of law.

4. WHAT PERSONAL DATA DO WE COLLECT AND USE?

• Your contact details and the contact details of people associated with your account:
  This information allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account.
• Account information and details of other people linked to your account:
  Information about your account with Home Energy including Home Energy login details for our websites, age, date of birth, unique account number, contract details, household details, property type, nominees, executors, or people with power of attorney and their details, or someone else to set up to pay your bill, premises details, previous supplier, proposed new supplier, meter and gas point numbers, meter details, energy use and consumption pattern, tariff details, complaints details, incident details, dispatch appointment details and notes added to your account.
• Vulnerability information:
  Information that allows us to understand whether you are in a vulnerable situation, including health and disability information.
• Contemporaneous Notes:
  Records of site visits by third parties including meter readers and debt recovery agents.
• Financial Information:
  Information that allows us to understand your creditworthiness and financial position.
• Transaction and payment information:
  Credit / debit card details and bank account details you provide to make payment for the product and services you purchase from us.
• Account History:
  Records of your previous account if you have used our service previously.
• Responses to competitions:
  Your entries to competitions that we run.
• Records of your discussions with our customer service team, including call recordings, messages from social media and emails:
  When you share comments and opinions with us, ask questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our customer service team, or contact us through social media such as through Twitter or on Facebook.
• How you use our website:
  We use technology such as cookies (subject to your cookie preferences) when you use our website, we collect information about the pages you look up and how you use them.
• Exercising your rights:
  If you exercise any of your statutory rights under data protection law, we will keep a record of this and how we respond.
• Sensitive or special category personal data:
  Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these along with biometric and genetic data are all called sensitive or special category personal data. The special categories of personal data we process are:
• Smart meter consumption data – in some circumstances of high frequency collection, smart meter consumption data may amount to special category data.
• When we ask for special category data, we will make it clear to you which data is needed for the particular service and ensure we process the data lawfully.
• You are not required to provide us any of the personal data described above, however, if you do not do so, you may not be able to purchase our products and services or the functionality of our services may be reduced.

5. WHY DO WE NEED TO COLLECT AND USE YOUR PERSONAL DATA / THE LEGAL BASIS FOR USING YOUR DATA

• We process these items of your personal data to enter or fulfil the contract between us, including:

• Reason or purpose	Personal data used
  Provide our services to you and maintain your account (including quality assurance purposes and handling any complaints you might make).	All personal information we collect as listed in section 4.
  Take payment for our products and services and debt collection.	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Financial information. Transaction and payment information. Delivery information. Purchase and account history. Location information.
  Perform credit checks.	Your contact details and the contact details of people associated with your account. Financial information. Account information and details of other people linked to your account. Transaction and payment information.
  To deliver service communications (such as bills) and tailing those communications to your circumstances.	Your contact details and the contact details of people associated with your account. Transaction and payment information.
  Answer your complaints or questions.	The personal data which is necessary for us to deal with your complaint, which will depend on the nature of your complaint and your contact preferences. Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Transaction and payment information. Purchase and account history.
  Showing your energy consumption.	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account.
  Providing industry flows to ensure you are charged the right amount for your energy supply.	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account.

• We process these items of your personal data because we have a legal obligation to, including:

• Reason or purpose	Personal data used
  Investigating misuse of your account, crime and fraud.	The personal data which is necessary for us to investigate the issue, which will depend on the nature of the problem. At a minimum, this will include your name and contact information and information about your account and transaction history.
  Attending emergency situations (including gas leaks).	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Vulnerability information.
  Raising awareness of smart meters.	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account.
  Comply with OFGEM obligations.	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Transaction and payment information. Anti-fraud information. Vulnerability information. Account history. Records of your discussions with our customer service team.
  Understand the information we hold to ensure compliance with data protection legislation.	All personal information we collect as listed in Section 4.
  Internal and statutory audits.	All personal information we collect as listed in Section 4.
  Look after customers who have a vulnerability. (e.g. if you are on the Priority Services Register)	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Vulnerability information.

• Where we process your personal data because you have allowed us to.

• Reason or purpose	Personal data used
  Collecting data from your smart meter more frequently.	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Energy consumption.
  Direct marketing	Your contact details and the contact details of people associated with your account. Account information and details of other people linked to your account. Financial information. Purchase and account history. Transaction and payment information. How you use websites. Advertising and Direct Marketing preferences and responses. Products and services that we have determined may be of interest to you.

• Where we process your personal data so you cannot be identified any more.
• We may anonymise and aggregate any of the personal data we hold (so that it does not identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services.

6. ABOUT YOUR CONSENT

• Where we need your consent to process your data, we will clearly ask for it and will tell you why we are processing your data. When we collect special category data, we will always tell you why and how the information will be used.
• Unless required to by law, we will not pass your special category data to a third party without your explicit consent. If you withdraw your consent, we will stop processing your data for the purpose for which you gave consent. This does not mean that we will no longer process your data – we may still process your data if we have another purpose with a different legal basis.
• You are entitled to object to direct marketing (even though we may not need your consent to contact you with promotional material in the first place).

7. WHO DO WE SHARE YOUR PERSONAL DATA WITH

• We share personal data with the following categories of third parties. We never sell your data to a third party for their own marketing use.

• Who	Examples
  Debt collection agencies, solicitors to recover debt, Courts, High Court Enforcement Officers.	To recover debt.
  Industry partners.	To comply with Ofgem Smart meter installation requirements which can include companies who will install the smart meter.
  Other energy companies, network companies and industry bodies.	Other energy companies and industry bodies, including National Grid and Xoserve as part of industry initiatives, or to help make it easier for you to switch suppliers.
  Regulators.	To ensure we meet licence conditions and current regulation: Information Commissioner’s Office (ICO) Office of Gas and Electricity Markets (Ofgem) Agents and auditors appointed by Ofgem
  Ombudsman services.	If you raise a dispute or complaint and are eligible for review by an ombudsman service, like the Energy Ombudsman Service, we may share information such as your contact details, meter readings, equipment, and payments.
  Trial partners.	Companies we work with to test our new products and services.
  Your Housing Association, Landlords, Councils and Letting Agencies.
  Network operators and distributors.	National Grid
  Companies that help us run our business, support our IT infrastructure and to further understand our customers.	Price Comparison Websites – To deliver energy tariffs for your comparison. Energy Ombudsman Service – To provide response on your complaints and questions.

8. WHERE YOUR PERSONAL DATA MAY BE PROCESSED

• It may be necessary to transfer your personal information to other companies or to Service Providers that are located outside and/or use facilities located outside the European Economic Area (EEA). This may happen where our servers or such companies/facilities are based in countries outside of the EEA or where you use our services and products while visiting countries outside of the EEA. The data protection and other laws of countries outside the EEA may not be as protective of your information as those in the UK or the European Union – in these instances we will take steps to ensure that your privacy rights are respected and your personal information adequately protected as required by applicable law. If you wish for more information about how your data may be processed outside the EEA, please contact our Data Protection Officer.

9. HOW LONG WILL WE KEEP YOUR PERSONAL DATA

• Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.

10. INFORMATION SECURITY

• Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. The form of security that we use is Secure Sockets Layer (SSL). This is a method of hiding the information that a web browser and a web server send to each other. An SSL-enhanced browser uses encryption to scramble the data you send to a website into an unintelligible string of seemingly random characters. This is the industry standard for encrypting digital communications between any two points across a network.
• Despite the encryption described above, your communications may route through a number of countries before being delivered – this is the nature of the internet – and Home Energy is therefore unable to guarantee the security of any information you transmit to or via our website.
• We do, however, have appropriate policies, rules and security measures in place to protect the personal information that we have under our control.

11. OUR WEBSITE

• The website may involve use of a mechanism called “cookies”. A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a website’s computers and stored on your computer’s hard drive, if your browser settings permit it.
• When you use our website Home Energy may set and access cookies on your computer as described below. If you do not agree to this use of cookies you can adjust your browser settings to reject all cookies (each browser is different, so check the “Help” menu of your browser to learn how to do this). Alternatively, you can choose not to use our website.
• Please note that if you choose to continue with use of our website without taking any further action in relation to cookies, we will consider that you agree to the use of cookies as described below.
  Home Energy does not use cookies to target advertising or to share information with social networking sites or other services.
• In addition, Home Energy uses Google Analytics to help analyse how users use our sites. This analytical tool uses a cookie set by Google to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the Google analytics cookie about your use of the Websites is transmitted to Google, and used to evaluate and compile statistical reports about this use for Home Energy.
• Home Energy will not (and will not allow any third party to) use the statistical analytics tool to track or collect any personally identifiable information about users of our sites, and will not associate any data gathered by means of the Google statistical tool with any personally identifying information.

12. WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA

• You may have the following rights in relation to your personal data:
• • the right to be informed about the personal data we collect, how your personal data is being used, and from whom we collect your personal data when we obtain it from other sources;
  • the right to access the personal data we hold about you;
  • the right to request the correction of inaccurate personal data we hold about you;
  • the right to request the blocking or deletion of your personal data in some circumstances;
  • the right to request that we port elements of your data either to you or another service provider;
  • the right to object to us processing your personal data (where we do so only because you have consented, or because we are using automated means to make decisions that affect you); and
  • the right to withdraw your consent.
• You only have the benefits of some of the above rights in limited circumstances, which depend on the legal reason why we collected your personal data.
• To exercise any of the above rights, or if you have any questions relating to your rights, please contact us using the details below.

13. DIRECT MARKETING

• Home Energy does not use direct marketing to sell its core services.

14. YOUR RESPONSIBILITIES

• You need to tell us when you are no longer liable to pay for our services. This could be, for example, because you have moved house, or it could be due to a change to the individuals who are jointly liable with you. If you do not tell us, it could result in incorrect data being processed, shared and used by debt recovery agencies, which in turn, may affect how other organisations view your creditworthiness.

15. GETTING IN TOUCH

• If you have any privacy-related questions or comments, please contact Home Energy ‘s data protection officer by writing to:
• Home Energy Ltd
  Granville Hall
  Granville Road
  Leicester
  England
  LE1 7RU
• You can also contact our data protection officer at hello@homeenergy.com.
• If you are unhappy with the way we are using your personal data you can also complain to the UK Information Commissioner’s Office or your local data protection regulator.
• We are here to help and encourage you to contact us to resolve your complaint first.