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PRIVACY POLICY




INTRODUCTION

Welcome to the Watt Utilities Ltd’s (“WATT”) privacy policy. WATT respects your
privacy and is committed to protecting your personal data. This privacy policy
will inform you as to how we look after your personal data when you visit our
website (regardless of where you visit it from) and tell you about your privacy
rights and how the law protects you.



1. IMPORTANT INFORMATION AND WHO WE ARE


PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how WATT collects and
processes your personal data through your use of this website, including any
data you may provide through this website when you sign up to our newsletter or
purchase a product or service. This website is not intended for children and we
do not knowingly collect data relating to children. It is important that you
read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why we
are using your data. This privacy policy supplements other notices and privacy
policies and is not intended to override them.


CONTROLLER

WATT is the controller and responsible for your personal data (collectively
referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy). We have
appointed a data protection officer (DPO) who is responsible for overseeing
questions in relation to this privacy policy. If you have any questions about
this privacy policy, including any requests to exercise, please contact the DPO
using the details set out below.


CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices,
please contact our DPO in the following ways:

Full name: Peter Hunter

Email address: Peter@watt.co.uk

Postal address: St Ann’s House, 5th Floor, St Ann’s Square, Manchester, M2 7LP

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

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review.

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.


THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every
website you visit.



2. 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 as 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 card details.
 * Transaction Data includes details about payments to and from you and other
   details of products and 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.
 * Profile Data includes your username and password, purchases or orders made by
   you, your interests, preferences, feedback and survey responses.
 * 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 could be derived from your
personal data but is not considered personal data in law as this data will 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 policy.

We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data). Nor
do we collect any information about criminal convictions and offences.


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 goods or services). In this case, we may have
to cancel a product or service you have with us but we will notify you if this
is the case at the time.



3. 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, Contact and Financial
   Data by filling in forms or by corresponding with us by post, phone, email or
   otherwise. This includes personal data you provide when you:
   * apply for our products or services;
   * create an account on our website;
   * subscribe to our service or publications;
   * request marketing to be sent to you;
   * enter a competition, promotion or survey; or
   * give us feedback or contact us.

 * Automated technologies or interactions. As you interact with our website, we
   will 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. We may also receive Technical Data about
   you if you visit other websites employing our cookies.
 * Third parties or publicly available sources. We will receive personal data
   about you from various third parties and public sources as set out below.
 * Technical Data from the following parties:
   * analytics providers;
   * advertising networks; and
   * search information providers.

 * Contact, Financial and Transaction Data from providers of technical, payment
   and delivery services.
 * Identity and Contact Data from data brokers or aggregators.
 * Identity and Contact Data from publicly available sources.




4. 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 obligation.


Generally, we do not rely on consent as a legal basis for processing your
personal data although we will get your consent before sending third party
direct marketing communications to you via email or text message. You have the
right to withdraw consent to marketing at any time by contacting us.


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan
to use your personal data, and which of the legal bases we rely on to do so. We
have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please
contact us if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set out in the
table below.

Purpose/ActivityType of dataLawful basis for processing including basis of
legitimate interestTo register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business)

To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision
of administration and IT services, network security, to prevent fraud and in the
context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy)To use data analytics to improve our website,
products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy)To make suggestions and
recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and
grow our business)


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.


COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly.


MARKETING

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.


PROMOTIONAL OFFERS 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 products, 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 you
have not opted out of receiving that marketing.


THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with
any third party for marketing purposes.


OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any
time by contacting us at any time. Where you opt out of receiving these
marketing messages, this will not apply to personal data provided to us as a
result of a product/service purchase, warranty registration, product/service
experience or other transactions.



5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes
set out in the table above.

   

 * External Third Parties as set out in the Glossary.
 * Third parties to whom we may choose to sell, transfer or merge parts of our
   business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. If a change happens to our business, then the
   new owners may use your personal data in the same way as set out in this
   privacy policy.

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 service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.




6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK.



7. 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 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.



8. DATA RETENTION


HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, regulatory, tax, accounting or reporting requirements. We
may retain your personal data for a longer period in the event of a complaint or
if we reasonably believe there is a prospect of litigation in respect to our
relationship with you. 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,
regulatory, tax, accounting or other requirements. Details of retention periods
for different aspects of your personal data are [available in our retention
policy which you can request from us by contacting us.



9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data.
 * Request access to your personal data.
 * Request correction of your personal data.
 * Request erasure of your personal data.
 * Object to processing of your personal data.
 * Request restriction of processing your personal data.
 * Request transfer of your personal data.
 * Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.


NO FEE USUALLY REQUIRED

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 could refuse to
comply with your request in these circumstances.


WHAT WE MAY NEED FROM YOU

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.


TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it
could 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.



10. GLOSSARY


LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance any
potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities
by contacting us.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.




THIRD PARTIES


EXTERNAL THIRD PARTIES

 * Service providers acting as processors who provide IT and system
   administration services.
 * Professional advisers acting as processors or joint controllers including
   lawyers, bankers, auditors and insurers who provide consultancy, banking,
   legal, insurance and accounting services.
 * HM Revenue & Customs, regulators and other authorities acting as processors
   or joint controllers based in the United Kingdom who require reporting of
   processing activities in certain circumstances.




YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data 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 that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.

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 continuing 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 (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time
of your request.

Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You also have
the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms.

Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios:

 * If you want us to establish the data’s accuracy.
 * Where our use of the data is unlawful but you do not want us to erase it.
 * Where you need us to hold the data even if we no longer require it as you
   need it to establish, exercise or defend legal claims.
 * 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 to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, 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 products or services to you. We will advise
you if this is the case at the time you withdraw your consent.


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ABOUT US

 * ABOUT US
 * CAREERS
 * NEWS
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 * ABOUT US
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 * HOW WE GET PAID


MORE INFO

 * COMPLAINTS PROCEDURE
 * PRIVACY POLICY
 * TERMS & CONDITIONS
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 * LETTER OF AUTHORITY

 * COMPLAINTS PROCEDURE
 * PRIVACY POLICY
 * TERMS & CONDITIONS
 * TPI CODE OF CONDUCT
 * GLOSSARY OF TERMS
 * LETTER OF AUTHORITY


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