Effective date: 1st day of October 2018
- When do we collect personal information about you?
- What personal information do we use?
- How we use your personal information
- Our legal basis for processing personal data
- Do we share your personal information?
- Security and transfer of data
- How long do we keep your personal data for?
- Your rights and preferences
- Other websites
- How to contact us
Zeigo Ltd (“Us”, “We” or “Our”) is a UK registered company (registered company number 11255249) at registered address 25 Lavington St, London, England, SE1 0NZ
We are own a website where we connect large end users to suitable renewable energy generation assets, certificates or grid energy.
Our website is located at https://zeigo.energy (“the Website”).
We are committed to protecting your privacy and will only use the information that we collect about you lawfully. This policy is intended to give you an understanding of how and why we use the information you provide to us both online and otherwise.
If you have any questions please contact us using the contact details included at paragraph 12.
2. When do we collect personal information about you?
2.1 We may hold personal information relating to you from a number of sources and will collect personal information about you:
(a) When you give it to us directly
2.2 For example, personal information that you submit by contacting us or any personal information that you share with us when you communicate with us in person, by email, phone or post.
(b) When we obtain it indirectly
2.3 Your personal information may be shared with us by third parties, for example the broker you use. To the extent that we have not done so already, we will notify you when we receive personal information about you from them, and tell you how and why we intend to use that personal information.
(c) When it is publicly available
2.4 Your personal information may be available to us from external publicly available sources. This may include information available on Companies House, reputable media articles, publications and company websites and professional networking sites such as LinkedIn. Depending on your privacy settings for social media services, we may access information from those accounts or services.
(d) When you visit our website
3. What personal information do we use?
3.1 We may collect, store and otherwise process the following kinds of personal information depending on how you interact with us:
(a) your full name;
(b) postal address;
(c) telephone number(s);
(d) email address;
(e) records of your correspondence with us;
(f) information about your role in your organisation and your professional qualifications;
(g) your communication preferences;
(h) information you may enter onto the Website; and
(i) any other personal information which you choose to share with us.
We will never collect sensitive personal data (such as health information) without your explicit consent.
There is also information about your computer hardware and software that is automatically collected by the Website. This information can include: your IP address (the unique identifying number of a computer), the browser you use, for example Internet Explorer (IE), Firefox etc., domain names, access times and referring Website addresses. This information is used by us for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Website.
4. How we use your personal information
4.1 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:
(a) to provide and maintain our Website;
(b) to notify you about changes to our Website;
(c) to allow you to participate in interactive features of our Website when you choose to do so such as our Community page and Marketplace to interact with Developers;
(d) to provide customer support;
(e) to gather analysis or valuable information so that we can improve our Website;
(f) to monitor the usage of our Website;
(g) to detect, prevent and address technical issues;
(h) to provide you with news, and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
(i) to help identify market trends and provide you and developers with useful data to promote the use of renewable energy; and
(j) to match your requirements with suitable projects.
5. Our legal basis for processing personal data
We need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Four of these are relevant to the types of processing that we carry out. This includes information that is processed on the basis of:
(a) a person’s consent (for example to send you direct marketing by e-mail) – you always have the right to withdraw your consent;
(b) necessity for the performance of a contract with you;
(c) processing that is necessary for compliance with a legal obligation to which we are subject; and
(d) our legitimate interests (please see below for more information).
Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, as long as that interest is not overridden by the privacy rights of the individual whose data is being used. We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks e.g. when we receive external emails we will scan such emails for any threats. We will also rely on the legitimate interest ground to communicate with you in most instances.
If you would like to change our use of your personal data in this manner, please get in touch with us using the details in the “How to contact us” section below.
6. Do we share your personal information?
We may allow our staff, consultants and/or external providers acting on our behalf to access and use your information for the purposes for which you have provided to us (e.g. to deliver mailings, to analyse data and to process payments). We only provide them with the information they need to deliver the relevant service under contract, and we make sure your information is treated with the same level of care as if we were handling it directly.
We reserve the right to disclose your personal information to third parties:
(a) in the event that we buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller of such business or assets;
(b) if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
(c) with our professional advisors e.g. lawyers, where necessary to protect our interests;
(d) for auditing purposes e.g. finance audits where we employ chartered accountants;
(e) if we are under any legal or regulatory obligation to do so; and
(f) in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
If you have provided your contact details and have expressed an interest in connecting with other organisations in the clean energy sector, we may provide your contact information to relevant third parties. For example, if you are a developer we may put you in contact with prospective clients and contacts. The information we share will be limited to your contact details at the organisation (for example, name, email address and phone number).
7. Security and transfer of data
We aim to ensure that there are appropriate controls in place to protect your personal details.
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 our Website; 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.
As we sometimes use third parties to process personal information, it is possible that personal information we collect from you will be transferred to and stored in a location outside the UK or the European Economic Area (EEA).
We encourage you to review the privacy statements of websites you choose to link to from the Website so that you can understand how those sites collect, use and share your information. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services outside of the Website.
Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred, stored, and/or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. If you have any questions about the transfer of your personal information, please contact us using the details at paragraph 12.
8. How long do we keep your personal data for?
Unless still required in connection with the purpose for which it was collected and/or processed, we will generally remove your personal information from our records six years after the date that it was collected. However, before this date: (i) if your personal information is no longer required in connection with such purpose(s); (ii) we are no longer lawfully entitled to process it; or (iii) you validly exercise the rights of erasure under paragraph 9, we will remove it from our records.
9. Your rights and preferences
9.1 You have a number of rights under data protection legislation. These include:
(a) Right of access
You have the right know what information we hold about you and to ask, in writing, to see your records.
We will supply any information you ask for that we hold about you as soon as possible, but this may take up to 30 days. We will not charge you for this. You will be asked for proof of identity as we need to be sure we are only releasing your personal data to you.
This is called a data subject access and can be done by writing to us using the “How to contact us” details.
(b) Right to be informed
You have the right to be informed how your personal data will be used. This policy as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.
(c) Right to withdraw consent
Where we process your data on the basis of your consent (for example, to send you marketing e-mails) you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the “How to contact us” section below.
(d) Right to object
You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the “How to contact us” section below.
(e) Right to restrict processing
In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
(f) Right of erasure
In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials we will need to keep some limited information in order to ensure that you are not contacted in the future.
(g) Right of rectification
If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. To update your records please get in touch with us using the details in the “How to contact us” section below.
(h) Right to data portability
Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.
If you decide you do not want to receive any further emails from us, please tell us and we will remove you from our mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed at paragraph 12.
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.
If you would like to exercise any of these rights please get in touch with us using the details in the “How to contact us” section below.
10. Updating this privacy notice
11. How to contact us
If you have any questions about how we use your personal information and how we comply with our responsibilities, please contact us as follows:
Post: Zeigo Ltd, 25 Lavington St, London, England, SE1 0NZ