We are a “data controller” as defined in the Data Protection Act 1998 (Act) and are registered as a with the UK Information Commissioner’s Office (ICO) under number ZA103743. You can view a copy of our current registration by entering our registration number into the ICO’s Register of data controllers.
Please read this Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By authorising us or our authorised installers to install a Product in your household and/or by using our Applications, you are accepting and consenting to the practices described in this Policy.
Our commitment to privacy
We take your privacy very seriously and strive to apply the same standards towards the collection and processing of your personal data as we would expect to be taken with our own personal data. As such, we promise not to use your personal data for commercial gain or for any other purpose which is not set out in this Policy, unless we have obtained your express and informed consent to us doing so.
We will always be transparent with you about the data that we collect and how we intend to process it. As required by the Act, we will also take all reasonable technical and other security measures to keep your personal data safe and to protect your Product from unauthorised access.
The data that we collect from you
When you purchase one of our Products and use our Applications, we will collect the following information about you, your household, your energy consumption and the network and devices that you use to access our Applications:
Data collected about you
- The full name(s) of the householder(s)
- The postal address, including postcode, of the householder(s)
- The email address(es) of the householder(s)
Data collected about your household
- Type of property
- Number of bedrooms
- Number of occupants
- Typical daytime occupancy
- Distance from substation
- Major household appliances (using a checklist)
- Any non-optimised appliances
- Other installed energy-saving measures (for example, loft insulation)
Data collected about your energy consumption (which is collected remotely)
- Load voltage (voltage consumed by the electrical circuit in your household)
- Instantaneous power (the power used by your household at a specific point in time)
- Unit temperature (temperature of the Product when it is switched on)
- Power factor (measures how efficiently the load voltage is converted into useful output)
- Unit status (current mode of the Product)
- Last event (last recorded technical event by the Product)
[Unlike “smart meters” we do not collect any data about your total energy consumption, for example, the data that you would give to your utilities provider so that they can calculate your energy bill.]
Data collected about your network and devices
- Name of your household wireless network (know as the Service Set Identified or SSiD) and your household wireless network password (used to connect to the Internet)
- Internet Protocol (IP) address of the device used to access the Applications (Which is used to connect your device to the Internet)
- Technical information about the device used to access the Applications (including operating system and platform, browser type and version and browser plug-in types and versions)
- Information about your use of our Applications (including the date and time of each use, sections of the Application used and the duration of use and interaction information such as scrolling, clicks and mouse-overs)
How we use the data that we collect from you
- We use the data that we collect from you for the following purposes:
- Carrying out our obligations arising from any contract between you and us and to provide you with the information, products and services that you request from us
- Providing you with information about other products and services that we offer and that are similar to those that you have already purchased or enquired about
- Notifying you about product safety issues and changes to our services
- Developing a historical view of your energy consumption and energy savings, which will be presented to you via the Applications and/or sent to you by email
- Aggregating and anonymising technical data for specific geographical areas, home types or occupancy levels for research purposes (for example, we may be interested to know the average supply voltage in a certain location or the average energy saving using our Products in 4-bedroom householders)
- Aggregating and anonymised technical data for the purpose of producing reports for and/or commissioning reports by academia, Distribution Network Operators (DNOs) or utility companies
- Communicating data to and from the Product via your household wireless network (other than your password) to our servers and downloading firmware updates
- Enabling you to participate in interactive features of our Applications
- Administering our Products and Applications including troubleshooting, data analysis and testing,
- Internet research, statistical and survey purposes
- Developing and improving our Products and Applications
Disclosure of your personal data
Except for in the circumstances listed below, we will not share your personal data with any third parties unless we have obtained your express and informed consent to us doing so.
- We may disclose your personal data to our authorised third party installers and service engineers to install or service the Products. We ensure that all our authorised third party installers have entered into binding agreements to keep your personal data confidential.
- We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries at any time, as defined in section 1159 of the UK Companies Act 2006.
- We may disclose your personal data in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Bristol BlueGreen Limited, or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of sale and other agreements; or to protect the rights, property, or safety of our company, customers or other third parties.
Where your personal data are stored
Whilst our data centres are situated in the UK, we cannot guarantee that the data we collect from you will not be transferred to, and stored at, a destination outside the European Economic Area (EEA) as part of our data centres’ backup and disaster recovery protocols. By agreeing to this Policy, you acknowledge and agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
All information you provide to us is stored on our secure servers. Any payment transactions will be processed by third parties which we are satisfied as having appropriate encryption protocols in place. Where we have given you (or where you have chosen) a password which enables you to access our Applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or from our Products or Applications; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long your personal data are stored
We will store your personal data for as long as your remain our customer. We will consider you to remain our customer until the later of:
- You notifying us that you no longer live at the household in which the Product was installed
- Expiration of our Limited Product Warranty
- The Applications not being accessed by you for a period of five years from the date of last access
You have the right to ask us not to process your personal data for marketing purposes. We will obtain your consent if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
For independent advice about your rights and choices relating to your personal data, contact the ICO at www.ico.org.uk or via the ICO Helpline on 0303 123 1113.
Changes to this Policy
We may change this Policy from to time and will notify you by email (to the email address(es) provided by you at the time of purchase or otherwise notified to us) of any changes affecting you.
Questions or comments
Please address any questions, comments and request regarding our data processing practices to email@example.com.
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