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Privacy Notice
Voltaea Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, clients, prospective clients, and partners, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us Voltaea Ltd.
Company Limited by Shares, registered in England & Wales under company number 12012326. Head of Data Protection Department: Naim Latif (Managing Director) Registered address: 20-22 Wenlock Road, London, England, N1 7GU Postal address: 20-22 Wenlock Road, London, England, N1 7GU Email address: data.protection@voltaea.com Telephone number: 0330 124 9988.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. This Privacy Notice also applies to your use of Our Website. Our Website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies and notices of any such websites before providing any data to them. This Privacy Notice also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. For the purposes of this Privacy Notice we do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that if you wish to exercise your individual rights as far as they relate to your product/service provider that you contact them directly via the appropriate avenue as outlined in their privacy notice; if at any point you are confused as to who to speak to, please do not hesitate to write to us, and we will do our utmost to point you in the right direction (data.protection@voltaea.com).
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Helpline number: 0303 123 1113).
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
Depending upon your use of Our Website, and/or your interactions with ourselves and our team, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children, or data relating to criminal convictions and/or offences.
Please note we record and monitor communications with you by telephone for the purposes of quality assurance, our mutual protection, staff training, improving our customer service, fraud detection, supplier compliance, and to ensure adherence to industry standards.
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
With your permission or where permitted by law, we will also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out (you may opt-out at any time either verbally or in writing via the details given in Part 11). We will not share your personal data with third parties for marketing purposes.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is reasonably necessary in light of the reason(s) for which it was first collected. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In some instances the retention period will be for as long as the applicable legal requirements stipulate, for example, by law, we have to keep basic information about our customers (including contact, identity, financial and transactional data) for six years after they cease being customers for tax purposes. However, in the absence of such legal requirements we will determine the length of retention based on a multitude of factors, namely; the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, whether we believe that we are still under a contractual duty of care to you or your business, and/or whether under a duty to fulfil a product warranty.
Our retention guidelines recognise that our industry sector clients often require experienced support on a long-term basis, often dictated by the contract length of their supply agreement(s), and in some cases beyond, particularly clients with large property portfolios and metering needs will be regularly needing our services and/or advice on a frequent basis as more sites, meters and thus contracts are added to their portfolio.
Users of Our Website can visit the site without revealing their identity or providing information about themselves, and we do not collect cookie data from visitors during this process. We only collect data from users of Our Website when they voluntarily submit their personal information to us. When this sort of information is collected we reserve the right to do one of two things. We may decide not to retain the information you have sent if we feel that we would be an organisation who would be unable to provide you with services. In this case your data would be immediately deleted. If we choose to retain your information we will do so in light of the considerations listed above, and will only use your data for the purpose of supporting you as a business and in the pursuit of our legitimate interests as outlined in Part 6.
We may anonymise your personal information (so that it can no-longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our Privacy Notice and our above data retention guidelines are periodically reviewed in light of changes within the law and in the interest of keeping our customers, clients, prospective clients, and partners data up to date, accurate and secure.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK or European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
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limiting access to your personal data to those employees, agents, contractors, and other third parties (including our third party partner suppliers) with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
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procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
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storing personal data within a double-encrypted storage file, and kept secure in a fire-proof, waterproof safety cabinet to ensure data integrity and to prevent any potential data breach.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
If we are arranging supply contracts with our Partner Suppliers, and liaising with them to resolve issues you have specifically asked us to resolve. This includes tendering for prices, negotiating on your behalf, and discussing arrangements to facilitate any site-works you have asked us to manage on your behalf. Whether this has been done in the form of a letter of authority, via verbal communication, email and/or post.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Head of Data Protection Department): Email address: data.protection@voltaea.com Telephone number: 0330 124 9988. Postal Address: 20-22 Wenlock Road, London, England, N1 7GU
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available via our website at www.voltaea.com. This Privacy Notice was last updated on 08/07/2019
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