Lowering bills, cutting carbon

Privacy – Cleanswitch.energy

Last updated: 10th April, 2019

Clean Switch is a campaign owned and run by Brakkn Ltd. In the remainder of this policy, references to ‘we’, ‘us’ or ‘our’ refer to Brakkn Ltd.

We believe you have a fundamental right to privacy and we aim to do everything we can to protect your security. This privacy policy describes how we will treat, handle and protect your personal information as you interact with us online and offline. It explains how we collect, use, disclose and transfer the information that you provide to us on our websites or mobile applications and when you respond to our online and digital communications.

Please read the policy in full to make sure you understand how your personal information will be treated. It may change periodically, so please check back from time to time.

By visiting our site and providing us with your personal data, you acknowledge and accept this privacy policy. You can find out more about the Clean Switch and the Terms of Use governing our site at www.cleanswitch.energy/termsofuse.

We welcome your comments about this policy. If you have any questions about how we use your personal data, please do not hesitate to contact us at:

Email: my.data@cleanswitch.energy
Telephone: +44 (0)800 249 4770

The bases upon which we process your data
We process your data at different times based upon one of two legal principles. There is more information about the lawful bases organisations may use for processing data on the Information Commissioner’s Office website in the UK or the Data Protection Commission’s website in the Republic of Ireland.

1. Legitimate interest
This occurs when the processing is necessary for our legitimate interests or the legitimate interests of a third party, and providing your own individual rights and freedoms do not override those interests. Examples of our legitimate interests include:

  • Communicating with you about clean energy in order to help you switch to a new supplier;
  • Making sure that our marketing to you is tailored to your interests;
  • Generating a clean energy quote for you, and if you decide to proceed, initiating your switch to a new supplier;
  • Maintaining accurate user records (and where you have been introduced to us by a partner, helping that partner do the same);
  • Understanding our impact and improving our services; and
  • Fraud prevention.

What this means in practice is that we process your data based on legitimate interests when:

  • It is necessary for us to process your data in order to deliver our services to you. For example, this includes providing you with information you may need in order to feel confident switching to a clean energy provider; and
  • You would reasonably expect us to process your data in this way. Examples of this include emailing you with additional information about switching to renewable electricity after you have entered your details on our site in order to get a clean energy quote, or if you signed up with us on the recommendation of one of our partners, passing your details back to that partner so that they can continue to communicate with you about switching to clean energy; or
  • Your interests and our interests are aligned. For example, if you have entered your details on our site in order to get a clean energy quote, we judge that us communicating with you in order to help you complete your switch is in both of our interests. Similarly, if you sign up with us through a partner, we may pass your details back to that partner to allow them to remove you from any follow-up communication aimed at people who haven’t yet responded to their communications about switching. This avoids you receiving unnecessary communications from them.

You have the right to object to this processing. If you wish to do so please email us at my.data@cleanswitch.energy. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

Consent and legitimate interests
Under the Privacy and Electronics Communications Regulations (PECR), you must have given consent for us to communicate with you by telephone or email even where we use legitimate interests as our lawful basis for processing your data. This is distinct from when we use consent as the lawful basis for processing your data (see below). When you provide us with your contact details during the process of generating a clean energy quote, you agree to us getting in touch using those details in order to help you switch to clean energy.

2. Consent
There may be some cases in which we judge that we need your consent as the legal basis for processing your data. In such cases, we will ensure that we ask for your consent in a way that is:

  • prominent and separate to our terms and conditions;
  • clear about why we want the data and what we’re going to do with it; and
  • clear about who will be relying on your consent in order to process your data.

Where we use consent as the lawful basis for processing your data, you may withdraw your consent at any time. If you have any questions or comments about how we process your data, please email my.data@cleanswitch.energy.

What we collect
We obtain information about you in a range of ways:

Information you give us
We collect your name, postal address, email address, phone number and demographic information (such as your gender and occupation) as well as other information you directly give us on our site. In addition, we may also collect personal information from you when you correspond with us (for example, when you send us e-mail communications or letters, or by telephone).

Information we get from others
We may get information about you from other sources including Fundraising Innovation Limited trading as EnergyHelpLine (who previously provided our price comparison functionality in Great Britain and share data with us on the status of switch applications submitted in Great Britain during that time), MyUtilityGenius Ltd (who now provide our price comparison functionality in Great Britain), Google and Facebook. We may add this to information we get from this site.

Information automatically collected
We automatically log information about you and your computer. For example, when visiting our site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site.

Our site (like most platforms) uses cookies and other similar technology such as ‘web beacons’. To learn more about how we use them, please see our cookies policy

Pixel tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our site to track the actions of users on our site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the site at an aggregate level, so that we can manage our content and promote the site more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

IP addresses
We may collect information about your computer or mobile device, including where available your IP address, operating system, log in times and browser type. We use this information to better understand how visitors use our site and for internal reporting purposes. We may anonymise and share this information with advertisers, sponsors and/or other businesses.

How we use your data
We may use your personal data for the purposes shown below. The lawful basis for processing your data is indicated in italics in each case – for more on what is meant by these terms, see the section above on ‘the basis upon which we process your data’. Where we rely on consent as the lawful basis for processing your data and have not yet secured this consent from you, we will not process your data in that way.

We may use your data to:

  • operate, maintain, and improve our sites, products and services. This may include:
    • sharing your data with MyUtilityGenius Limited and with clean energy suppliers for the purposes of generating clean energy quotes and facilitating your switch – legitimate interests;
    • receiving data from MyUtilityGenius Limited and from clean energy suppliers about your switch application if you choose to switch through us; and
    • contacting you by telephone, where you have provided us with your telephone number, in order to get feedback and assist you or your organisation in switching to renewable electricity tariffs – legitimate interests;
  • process and deliver competition entries and rewards – legitimate interests;
  • respond to comments and questions and provide customer service – legitimate interests;
  • send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages – legitimate interests;
  • communicate with you about promotions, upcoming events, and other news about products and services offered by us and our selected partners where these have a clear connection to low carbon purchasing choices – consent;
  • to link or combine user information with other personal data, including to identify other people who may also be interested in our products and services – legitimate interests;
  • to allow a partner that may have referred you to us to communicate with you more effectively – legitimate interests or consent, depending on how the data are used;
  • to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity – legitimate interests; and
  • to provide and deliver additional products and services at your request – consent.

Limiting access to your personal data
Our overarching principle is that we will restrict access to your data to the minimum number of people and organisations required to provide our service and comply with the law. To be clear, we will never share personal information about you with other people or organisations except where we have to do so to provide our services or to comply with the law. Specifically, we may share your data:

  • With those who need it to do work for us in order to provide our services to you or market our services to other users, or whose services we use in managing and maintaining our data records.
  • During the sale or transfer of all or substantially all of our business or assets. This includes through a merger, financing, acquisition, or bankruptcy transaction or proceeding. In these events we will take steps to ensure that the purchasing or contracting organisation(s) carry the same obligations and responsibilities in terms of holding and processing of personal data as are set out in this policy.
  • For legal, protection, and safety purposes:
    • to comply with laws or any regulatory obligation;
    • to respond to lawful requests and legal processes;
    • to protect the rights and property of Brakkn Ltd, our agents, customers and others. This includes enforcing our agreements, policies and Terms of Use.
    • in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

Sending personal data outside the European Economic Area
We sometimes work with suppliers who store data outside of the European Economic Area (EEA). Where we do so, we ensure that they are accredited under schemes that offer additional protections, such as the US Privacy Shield. For more information on this, please see the UK Information Commissioner’s Officer guidance, here: https://ico.org.uk/media/for-organisations/documents/2014413/data-transfers-to-the-us-and-privacy-shield.pdf or the Republic of Ireland Data Protection Commission’s guidance here: https://www.dataprotection.ie/en/organisations/know-your-obligations/eu-us-privacy-shield

If you sign up though one of our partners
We sometimes help partner organisations to promote clean energy to their stakeholders, including, but not restricted to, their employees, customers, members, supporters, viewers, readers and listeners. In those cases, users are directed to a dedicated co-branded landing page on our website. If you sign up through one of these dedicated landing pages, we may share your information with the organisation that referred you to help them measure impact and to allow them to communicate with you about Clean Switch.

Should we identify a need to share your data outside of the circumstances outlined above, we will secure your consent to this in advance of sharing your data in this way.

Protecting your information
We want you to feel confident about using the Clean Switch site, and we are committed to protecting the personal information we collect. We limit access to personal information about you to employees who reasonably need access to it in order to do their jobs. We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction.

Retention period
We will retain your personal data for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

How to edit, delete or access your personal data
You have the right to ask for a copy of any personal information that we hold about you in our records, to correct any inaccuracies and to update any out of date information. You can also ask us not to send you direct marketing communications. If you wish to exercise any of these rights, or wish to object to our use of your personal information, please email: my.data@cleanswitch.energy or write to the address listed below.

Changes to this policy
From time to time we may change this Policy. If we make any changes, we will change the Last Updated date above. If you do not agree to these changes, please do not continue to use our site. If material changes are made to this Policy, we will notify you by email or by placing a prominent notice on the site.

Your rights under the Data Protection Act
Brakkn is a UK-registered company and the collection and use of personal information on this site is in accordance with the UK Data Protection Act. Please visit the Information Commissioner’s Office for further information about this Act at: ico.org.uk.

If you have any questions relating to this policy, please address them to:
Jon Fletcher
Clean Switch, Brakkn Ltd
14a Commercial Road
United Kingdom

Tel: +44 (0)800 249 4770

Email: my.data@cleanswitch.energy.

If you are not satisfied with our response to your concern, you may wish to contact the Information Commissioner’s Office.