Last Updated: [tbc]

1. Introduction

SmartPay Energy Ltd (company number 10971782) (“we”, “us” or “our” in this Privacy Notice) is a gas and electricity supplier licensed under the Gas Act 1986 and the Electricity Act 1989. Our registered address is at 10th Floor (North West), One Canada Square, London, E14 5AB.

We are the data controller for your personal data. Our Information Commission’s registration number is ZB650211.

Should you have any queries relating to this notice, please contact our Data Protection Manager using the address at the start of this privacy policy, or email us at datacontroller@smartpay.energy.

2. Data we collect

We collect your name, business name, business e-mail, business address and your current contract end date when you submit an online form to register your interest in obtaining a quote for our services once we launch. We use this information to notify you as soon as our business launches and our quote tool becomes live and for your convenience to pre-populate your details in our quote tool.

3. How we use your data and the lawful basis

By law, we are required to explain what information we collect from you and how and why we use your personal information (the “processing activity”). We are also required to have a “lawful basis” on which to process your personal information.

We process your personal data based on our legitimate interests, specifically our legitimate interest in providing you with a quote for our services. Because you have actively provided your details to request a quote for our services, we will contact you once we launch our quote tool. You can opt out of this notification at any time by contacting us directly at datacontroller@smartpay.energy or clicking the “unsubscribe” link in our future email.

4. Who we share your personal data with

Your personal data may be shared with:

• Organisations who provide us with IT and system administration services.
• Organisations who distribute the notice to you.

5. Data security

We have policies, rules and technical and organisational measures in place to protect your personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage.

We will hold your details for 6 months after the launch of our quote tool, or until you choose to opt out.

We will ensure, where personal data are no longer required, that records are destroyed we will ensure that they are disposed of safely and permanently.

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

6. International transfers of Personal Data

Your personal data may be shared with organisations based outside of the UK. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.

If we transfer personal data outside of the UK, we may rely on a decision from the Secretary of State determining that the recipient country provides an adequate level of protection. Alternatively, we rely on appropriate safeguards in respect of transfers of personal data to a country outside of the UK, for example, by agreeing standard contractual clauses adopted by the Information Commission.

7. Your rights

Data protection laws provide you, as an individual, rights to:

• access – you can request access to your personal information (a data subject access request), so you can check what data we hold about you and are using it in accordance with the law.
• rectification – you can ask us to correct personal information that we hold about you.
• erasure – you can ask us to delete your personal data where there is no good reason for us to hold this data. You can also ask us to delete or remove your personal information where you have exercised your right to object to processing.
• restriction of processing – you can ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• data portability – you can ask for a copy of the data we hold about you, in an accessible format and the right to transfer it, or to require us to transfer it directly, to another controller.
• object to processing – you can object to the processing of your personal information and there is something about your particular situation which makes you want to object to processing on this ground.
• not to be subject to automated decisions – You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
• withdraw consent – you have the right to withdraw your consent where we are relying on it to use your personal data; and
• objection to marketing – you have the right to withdraw your consent to receive digital marketing material.

No fee is required to claim any of these rights. However, we may charge a reasonable fee or refuse to comply if your request for access is considered to be unfounded or excessive. If you wish to exercise any of your rights, please contact us using the details set out below.

8. Complaints, requests exercise your rights and our contact details

If you have any queries or concerns regarding our processing of your personal data, would like to exercise any of your rights or would otherwise like to make a complaint, please contact our Data Protection Manager in the first instance at datacontroller@smartpay.energy. We will acknowledge receipt of your complaint within 30 days and will investigate and respond to it without undue delay.

You also have the right to make a complaint to the Information Commission if you are dissatisfied with our handling of your personal data or our response to your complaint. You can lodge a complaint at www.ico.org.uk/make-a-complaint/.

However, please contact us in the first instance if you have any issue that you wish to discuss.