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PRIVACY POLICY



This is the privacy notice for eEnergy PLC.



eEnergy PLC respects your privacy and is committed to protecting your personal
data.






IMPORTANT INFORMATION AND WHO WE ARE




PURPOSE OF THIS PRIVACY NOTICE



This privacy notice will inform you as to how we look after your personal data
when you visit our website (regardless of where you visit it from), use our
services, or register to attend our events. We are committed to protecting your
personal data and this privacy notice will explain how we look after it, what
rights you have, as well as how the law protects you.



eEnergy PLC is the controller and responsible for this privacy notice.



We have appointed a data protection officer (DPO) who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise your
legal rights, please contact the DPO using the details set out below.



This privacy notice should be read together with any other privacy notice or
fair processing notice we may provide on specific occasions when we are
collecting or otherwise processing personal data about you so that you know how
and why we are using it. This privacy notice supplements those other notices and
is not intended to override them.




CONTACT DETAILS



Our full details are:



Full name of legal entity: eEnergy PLC



Data Protection Officer’s email address: melina@elightgroup.com



Postal address: 1-3 The Green, Malahide, Co. Dublin, K36 FV22, Ireland.




CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES




THIS VERSION WAS LAST UPDATED ON 13TH DECEMBER 2018.



It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.




HOW THIS PRIVACY NOTICE OPERATES WITH OUR OTHER PRIVACY NOTICES



It is important that you read this privacy notice together with any other
privacy notices that we may provide on specific occasions when we are collecting
or otherwise processing personal data about you so that you know how and why we
are using it. This privacy statement supplements those other notices and is not
intended to override them.




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).




WE MAY COLLECT, USE, STORE AND TRANSFER DIFFERENT KINDS OF PERSONAL DATA ABOUT
YOU WHICH WE HAVE GROUPED TOGETHER FOLLOWS:



 * Identity Data includes first name, maiden name, last name, username or
   similar identifier, marital status, title, date of birth and gender
 * Contact Data includes billing address, delivery address, email address and
   telephone numbers
 * Financial Data includes bank account and payment method details
 * Transaction Data includes details about payments to and from you and other
   details of services you have purchased from us
 * Technical Data includes internet protocol (IP) address, your login data,
   browser type and version, time zone setting and location, browser plug-in
   types and versions, operating system and platform and other technology on the
   devices you use to access this website, together with CCTV and other visual
   or audio recordings, including photographs
 * Profile Data includes your interests, attendance at our events, preferences,
   feedback and survey responses – which may include Special Categories of
   Personal Data
 * Usage Data includes information about how you use our website, products and
   services
 * Marketing and Communications Data includes your preferences in receiving
   marketing from us and our third parties and your communication preferences



We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy notice.




IF YOU FAIL TO PROVIDE PERSONAL DATA



Where we need to collect personal data by law, or under the terms of a contract
we have with you and you fail to provide that data when requested, we may not be
able to perform the contract we have or are trying to enter into with you (for
example, to provide you with services). In this case, we may have to cancel a
service you have with us but we will notify you if this is the case at the time.




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 and Contact by filling in
   forms or by corresponding with us by post, phone, email or otherwise. This
   includes personal data you provide when you:
 * make enquiries of, and/or seek to procure our, services
 * contact us via one of the communication means set out on our website
 * enter into an agreement with us for the provision of, or receipt of, services
 * request marketing and other promotional material to be sent to you
 * enter a survey
 * give us some feedback.
 * Automated technologies or interactions. As you interact with our website, we
   may automatically collect Technical Data about your equipment, browsing
   actions and patterns. We collect this personal data by using cookies, server
   logs and other similar technologies.
 * Third parties or publicly available sources. We may receive personal data
   about you from various third parties and public sources.



 1. 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:



 * Where we need to perform the contract we are about to enter into or have
   entered into with you
 * 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
 * Where we need to comply with a legal or regulatory obligation
 * Where you have consented to its use




PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA




WE MAY USE YOUR PERSONAL DATA TO:



 * Carry out our obligations arising from any agreements entered into between
   our clients and us (which will usually be used for the provision of our
   services)
 * Carry out our obligations arising from any agreements between our clients and
   us (which will usually be for the provision of our services, where you may be
   a sub-contractor, supplier or customer of our client
 * Provide you with information related to our services and our events and
   activities that you request from us or which we feel may interest you,
   providing you have consented to be contacted for such purposes
 * Seek your thoughts on the services we provide
 * To process and consider your job application, where we use our legitimate
   interests to process your personal data for assessing your job application
   and to keep you updated throughout the application process




MARKETING INFORMATION FROM US



We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which services and offers may be relevant for you (we call
this marketing).



You will receive marketing communications from us if you have requested
information from us or purchased services from us and, in each case, you have
not opted out of receiving that marketing. This is in line with our legitimate
interest.




THIRD-PARTY MARKETING



We will get your express opt-in consent before we share your personal data with
any company outside of eEnergy PLC for marketing purposes.




OPTING OUT



We try to always include an opt out option of any marketing messages. Where this
is not possible, you can ask us to stop sending you marketing messages at any
time by contacting us



Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a service purchase, service
experience or other transactions.




COOKIES



For more information about the cookies we use, please see our cookies policy




CHANGE OF PURPOSE



We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.



If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.



Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted
by law.

Where a data controller has an online presence, the WP29 recommends that the
controller provides a privacy
notice which is layered. The data subject should have a clear overview of the
information available to them and
on finding detailed information within the layers of the notice. The Guidelines
provide that the first layer should
always contain information on the processing which has the most impact on the
data subject and processing
which could surprise the data subject.

Third Party Processors

Our carefully selected partners and service providers may process personal
information about you on our behalf
as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity
on our behalf, such activity may
result in the compliant processing of personal information. Our appointed data
processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact
Sopro and view their privacy
policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877
their Data Protection Officer can be
emailed at: dpo@sopro.io.”




DISCLOSURES OF YOUR PERSONAL DATA



We may have to share your personal data with other organisations from time to
time, but we will maintain responsibility for what they do with your data and
how it is processed. 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 providers to use your personal data for their own purposes and
we only permit them to access your personal data for specified purposes and in
accordance with our instructions – for example, service providers who process
data for us, including those providing IT and system administration services and
hosting.




INTERNATIONAL TRANSFERS



Generally, we process your personal data within the EEA. If we need to transfer
your personal data out of the EEA, we will ensure a similar degree of protection
is afforded to it as if it were being processed within the EEA. By way of
example:



 * we will transfer your personal data to countries that have been deemed to
   provide an adequate level of protection for personal data by the European
   Commission
 * where we use certain service providers, we may use specific contracts
   approved by the European Commission which give personal data the same
   protection as it has in Europe
 * where we use providers based in the US, we may transfer data to them if they
   are part of the Privacy Shield which requires them to provide similar
   protection to personal data shared between Europe and the US




DATA SECURITY



We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.



We have also put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where we are
legally required to do so.




DATA RETENTION




HOW LONG WILL YOU USE MY PERSONAL DATA FOR?



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



To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.



In some circumstances, we may anonymise your personal data (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.




YOUR LEGAL RIGHTS



Under certain circumstances, you have rights under data protection laws in
relation to your personal data. Please click on the links below to find out more
about these rights:



 * Request access to your personal data (also known as a “subject access
   request”). This enables you to receive a copy of the personal data we hold
   about you and to check that we are lawfully processing it
 * Request correction of the personal data we hold about you. This allows you to
   have any incomplete or inaccurate data we hold about you corrected
 * Request erasure of your personal data. This enables you to ask us to delete
   or remove personal data where there is no good reason for us to continue to
   process it. You also have the right to ask us to delete or remove your
   personal data where you have successfully exercised your right to object to
   processing, where we may have processed your information unlawfully, or where
   we are required to erase your personal data to comply with the law. Note,
   however, that we may not always be able to comply with your request for
   erasure for specific legal reasons which, if applicable, we will notify you
 * Object to processing of your personal data where we are relying on our
   legitimate interests (or those of a third party) and there is something about
   your particular situation which makes you want to object to our processing on
   this ground as you feel it impacts on your fundamental rights and freedoms.
   In some cases, we may demonstrate that we have compelling legitimate grounds
   to process your information which override your rights and freedoms. You also
   have the right to object where we are processing your personal data for
   direct marketing purposes
 * Request restriction of processing of your personal data. This enables you to
   ask us to suspend the processing of your personal data in any of the
   following scenarios: (a) if you want us to establish the data’s accuracy; (b)
   where our use of the data is unlawful but you do not want us to erase it; (c)
   where you need us to hold the data even if we no longer require it as you
   need to establish, exercise or defend legal claims; or (d) you have objected
   to our use of your data but we need to verify whether we have overriding
   legitimate grounds to use it
 * Request the transfer of your personal data to you or a third party. We will
   provide to you, or a third party you have chosen, your personal data in a
   structured, commonly-used and machine-readable format. Note that this right
   only applies to automated information which you initially provided consent
   for us to use or where we used the information to perform a contract with you
 * Withdraw consent at any time where we are relying on consent to process your
   personal data. However, this will not affect the lawfulness of any processing
   carried out before you withdraw your consent. If you withdraw your consent,
   we may not be able to provide certain services to you. We will notify you if
   this is the case




IF YOU WANT TO EXERCISE ANY OF THE RIGHTS SET OUT ABOVE, PLEASE CONTACT US




SHOULD YOU WISH TO ACCESS YOUR DATA, PLEASE NOTE THE FOLLOWING:



 * you will not have to pay a fee to access your personal data (or to exercise
   any of the other rights). However, we may charge a reasonable fee if your
   request is clearly unfounded, repetitive or excessive. Alternatively, we may
   refuse to comply with your request in these circumstances
 * we may need to request specific information from you to help us confirm your
   identity and ensure your right to access your personal data (or to exercise
   any of your other rights). This is a security measure to ensure that personal
   data is not disclosed to any person who has no right to receive it. We may
   also contact you to ask you for further information in relation to your
   request to speed up our response
 * we try to respond to all legitimate requests within one month. Occasionally
   it may take us longer than a month if your request is particularly complex or
   you have made a number of requests. In this case, we will notify you and keep
   you updated



You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority 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.




CONTACT

Registered office address
Salisbury House,
London Wall, London,
England,
EC2M 5PS


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