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Introduction
Welcome to the HomeFuels Direct’sprivacy notice.
Certas energy UK Limited trading as HomeFuels Direct (“HomeFuels Direct”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you what personal data we collect from you and why, 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.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how HomeFuels Direct collects and processes your personal data through your use of this website or otherwise, including any data you may provide through this website when you create an online account 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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Controller
HomeFuels Direct is the controller and is responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice). The Company is owned by Certas Energy UK Limited (“Certas Energy”) and your personal data will be shared with Certas Energy as set out in this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Data Protection, Certas Energy UK Limited, 1st Floor, Allday House, Warrington Road, Birchwood, Cheshire WA3 6GR, emailing us at marketing@certasenergy.co.uk or phoning your local Certas Energy contact centre who will assist with the handling of your request.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on [26 October 2021].
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 the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- 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 and other relevant personal information e.g. date of birth.
- 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 (encrypted), email 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, email address, 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 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.
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.
- 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;
- request marketing to be sent to you; or
- request customer service and support.
- enter a competition, promotion or survey; or
- 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- (a) analytics providers such as Google Analytics based outside the EU; and
- (b) IT and software service providers such as TR10 based in the United Kingdom.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.
- from publicly available sources (e.g. the electoral roll)
- 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 internal record keeping and account management purposes (e.g. verifying your identity and fulfilling orders you place)
- providing you with the product or service you have requested from us
- monitoring, recording and storing telephone or email communications for the purpose of internal training, audit and compliance checking, to improve the quality of our customer service and in order to meet any legal and regulatory requirements
- improving our products and services
- contacting you by email, SMS, phone or mail for the purpose of account administration and/or processing and fulfilling orders and/or taking payment for such orders
- customising our website according to your interests
- contacting you on the grounds of us having a legitimate interest to do so to periodically send promotional mails or contact you by telephone about new products, special offers or other information which we think you may find interesting using the contact details which you have provided and for market research purposes
- where you give us your consent to do so, we may
- periodically send promotional emails or SMS messages about new products, special offers or other information which we think you may find interesting using the contact details which you have provided
In order to utilise your personal information, as set out about, we may allow third parties to process your personal information on our behalf. This is likely to be the case where, for example we:
- pass information to Certas Energy to deliver your order
- pass information to GPUK LLP trading as Global Payments (third party card processor) to process your payment.
Where we share personal information for these purposes, we put in place controls to ensure that your personal information is only used for the purpose for which we’re sharing it (e.g. to deliver your fuel to you). Where we want to allow third parties to process or control your personal information for reasons other than those set out above, we will inform you of this and, if necessary, seek your consent to share such information with them.
Where we have asked for your consent to use your personal information for a particular purpose, this consent may be withdrawn by you at any time. Similarly, where we are using your personal information to fulfil a legitimate interest of ours, you may have a right to object to your personal information being used for a particular purpose (e.g. for direct marketing). Please see the section entitled ‘Controlling your personal information’ below.
We may also invite you to leave a review on the Trust Pilot website. To invite you to leave a review, your email address will be shared with them. Should you not wish to leave a review, you can choose not to respond to that invitation. Trust Pilot retain your email address only for the purpose of sending this invite and for no other purpose.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 may only process your personal information where we have a lawful basis for processing it. What this lawful basis is will depend on the type of personal information you provide, and where we want to process personal information for a specific purpose not identified in this Privacy Policy we will notify you of this at that time.
Our lawful bases for processing your personal information are as follows:
Processing
|
Lawful Basis
|
Internal record keeping
|
Contract
|
Internal training/audit/compliance
|
Contract
|
Improving products and services
|
Legitimate Interests
|
Account Administration
|
Contract
|
Customising our website
|
Legitimate interests
|
Direct marketing – current customers*, mail and telephone
|
Legitimate Interests
|
Direct marketing electronic marketing
|
Consent
|
Direct marketing – non-current customers, mail and telephone
|
Legitimate Interest
|
Market research
|
Legitimate Interests
|
Preventing fraud and money laundering and verifying identity
|
Legitimate Interests
|
Trust Pilot
|
Legitimate Interests
|
In certain circumstances, we may be required to process your personal information in order to comply with a lawful obligation on us. This may be the case, for example, where a statutory or regulatory body requests such information in accordance with their legal powers. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. We also have a legitimate interest and, on occasion, a legal obligation to disclose personal information to regulatory bodies in certain circumstances, including where we have information about potential criminal acts or security threats, and may disclose information to authorities on this basis.
*If you proactively contact us to enquire about becoming a customer, we will treat you as a current customer for the purpose of potentially directly marketing to you on the grounds set out above.
Controlling your personal information
You may choose to restrict or control the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website or elsewhere, ensure that you do not tick any box requesting permission to use your personal information for specific purposes (e.g. marketing) or, in the case of ‘opt-out’ consents relating to electronic communications, ensure that you un-tick the relevant box
- if you have previously agreed to us using your personal information for direct marketing or other specific purposes and wish to change your mind
- if you believe that we are holding personal information which is incorrect, out of date or incomplete and wish for that to be corrected
- if you wish for your personal information to be erased from our systems
- if you wish for us to transfer your personal information to a third party (e.g. another service provider), we may provide you with your personal information which held by us for you to pass to that third party (or, in certain circumstances, we may be able to transfer that personal data to such third party directly if you wish for us to do so)
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 goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, 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 company for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or 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, product/service experience or other transactions.
Third Party Links and Cookies
Links to other websites Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website (s). Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
- Cookies
How we use cookies
Cookies are alphanumeric identifiers which enable our systems to recognise your browser in order that we can provide you with easy use of the various services available on the website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. The table below explains the cookies we use and why.
Cookie Name
|
Cookie ID
|
Cookie Duration
|
Additional info
|
Has Javascritp
|
has_js
|
A cookie that determines whether your browser has JavaScript enabled. Required by the content management system this site has been built with.
|
This cookie is strictly necessary for the website to operate.
|
Google Analyitics
|
_utma
_utmb
_utmc
_utmz
|
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This cookie is essential for the website to operate efficiently.
|
Click here for an overview of privacy at Google
|
Please refer to our full cookie policy available here for more details click here If you wish to learn more about cookies go to www.aboutcookies.org.
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.
- Data security
The security of your information is very important to us. As part of our commitment to keeping your data safe, our technical experts maintain physical, electronic and managerial procedures to keep safe the information we collect online. 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. These people will only be allowed access to your data for the purposes identified within this Privacy Policy, processing it on our behalf or for IT security and maintenance.
Where a third party is processing your data on our behalf, we will take steps to ensure that such third party gives us commitments that it will process your data in line with EU law. If a third party processing your data on our behalf is located in a non-EU country that does not have data protection laws equivalent to those in the EU, we will always take appropriate additional steps to ensure that your personal information is kept safe and secure by those processing your data on our behalf. This will generally involve ensuring that such third party agrees to sign up to a formal legal agreement committing such party to comply with standards equivalent to those that would apply where that party to be located within the EU. Whenever fraud prevention agencies transfer your personal data outside of the EU they impose contractual obligations on the recipients of that fata to protect your personal data to the standard required in the European Economic Area. This may also require the recipient to subscribe to “international frameworks” intended to enable secure data sharing.
Sometimes, you might wish to disclose sensitive information to us, for example if you need a priority delivery because you are receiving medical treatment. We will only use sensitive data for the specific reason you disclosed it to us and we will take extra care to keep it secure. From time to time, we will check with you that we may continue to use that sensitive data for the specified purpose. Similarly should you sign up to our Cold Weather Priority scheme, you will be asked to provide a specific consent to us holding sensitive information for the purpose of this scheme.
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.
- Data retention
How long will you use my personal data for?
The time period for which we keep information varies according to what we use the information for. Unless there is a specific legal requirement for us to keep information, we will keep your information for as long as it is relevant and useful for the purpose for which it was collected.
Where we are using your personal information to send you marketing information we will generally retain that information for marketing purposes for two years from the point of your last order as we understand that you even if you do not buy from us on every occasion, frequently we see repeat purchases from customers in this time period. We will retain your account information for seven years in line with relevant tax and contract requirements. In the case of commercial customers, we may retain personal information relating to such individuals within such customers for a longer period of time depending on the order and contracting cycles of such customers (e.g. if a customer commonly enters into five year deals, we would retain such information for a short period beyond the time when we would expect such agreement to be renewed).
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Where you have given consent to us holding data for a particular purpose, that consent may be withdrawn by you at any time. You may withdraw your consent by contacting us by any method that you wish to communicate with us, including e-mail or telephone. Our usual contact details are set out on the first page of this Privacy Policy.
You are entitled to request that we erase your personal information at any time, for example where you cease to be an active customer of ours. Whilst we will generally seek to comply with your request, there will be circumstances where we are entitled to retain such personal information (e.g. in respect of legal claims or to ensure that any activity on your account (e.g. monies owing) may be resolved).
- Your legal rights
Your rights
You have the right to:
- know that information is being processed
- access information that is being processed
- rectification of information being processed
- erasure of information held on you (commonly known as the right to be forgotten)
- restrict processing
- be notified about what information has been rectified, erased and restricted
- portability (that is, to request your data be handed over to someone else)
- object to the processing of your information
It is important to note that this is not an absolute right to review all the information that is held about you, as there are various exceptions to this right. These include:
- (a) where personal data is kept for the purpose of preventing, detecting or investigating offences and related matters; and
- (b) where the data is given by another person in confidence.
You may request that we cease to contact you for direct marketing purposes at any point. We will comply with any such request.
You are entitled at any point to see the personal information that we hold about you. This is called a Subject Access Request. If you want to make a Subject Access Request, or if you want to remove a consent, request that we cease contacting you for direct marketing purposes or request erasure or transfer of your personal information, you may do so at any time by writing to us at Data Protection, Certas Energy UK Limited, 1st Floor, Allday House, Warrington Road, Birchwood, Cheshire WA3 6GR, emailing us at marketing@certasenergy.co.uk or phoning your local Certas Energy contact centre.
We will not sell, distribute or lease your personal information to third parties for their control unless we have your permission, need to do so in order to fulfil a contractual obligation to you or are required by law to do so. Where we do seek your permission, we will name the relevant third party at the time we seek such permission from you and any such permission shall be limited to that third party. Please note that we may provide information for processing to certain third parties as outlined above.
If you believe that any information we are holding on you is incorrect, out of date or incomplete, please write, email or call us as soon as possible, using the details set out above. We will promptly correct any information found to be incorrect. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.
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.
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 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.
- 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Courier providers acting as processors based in the United Kingdom who provide delivery services of goods.
- 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.
- Professional advisers acting as processors and joint controllers including lawyers, bankers, auditors, accountants, insurers and pension advisors who provide their professional services.
- Service providers acting as processors based in the United Kingdom who provide IT and website system administration services.
- Web hosts service providers acting as processors based in the United Kingdom who provide website hosting services
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: (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 it 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 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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Introduction
Welcome to the HomeFuels Direct’sprivacy notice.
Certas energy UK Limited trading as HomeFuels Direct (“HomeFuels Direct”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you what personal data we collect from you and why, 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.
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how HomeFuels Direct collects and processes your personal data through your use of this website or otherwise, including any data you may provide through this website when you create an online account 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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Controller
HomeFuels Direct is the controller and is responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice). The Company is owned by Certas Energy UK Limited (“Certas Energy”) and your personal data will be shared with Certas Energy as set out in this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Data Protection, Certas Energy UK Limited, 1st Floor, Allday House, Warrington Road, Birchwood, Cheshire WA3 6GR, emailing us at This email address is being protected from spambots. You need JavaScript enabled to view it. or phoning your local Certas Energy contact centre who will assist with the handling of your request.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on [26 October 2021].
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 the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- 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 and other relevant personal information e.g. date of birth.
- 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 (encrypted), email 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, email address, 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 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.
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.
- 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;
- request marketing to be sent to you; or
- request customer service and support.
- enter a competition, promotion or survey; or
- 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- (a) analytics providers such as Google Analytics based outside the EU; and
- (b) IT and software service providers such as TR10 based in the United Kingdom.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.
- from publicly available sources (e.g. the electoral roll)
- 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 internal record keeping and account management purposes (e.g. verifying your identity and fulfilling orders you place)
- providing you with the product or service you have requested from us
- monitoring, recording and storing telephone or email communications for the purpose of internal training, audit and compliance checking, to improve the quality of our customer service and in order to meet any legal and regulatory requirements
- improving our products and services
- contacting you by email, SMS, phone or mail for the purpose of account administration and/or processing and fulfilling orders and/or taking payment for such orders
- customising our website according to your interests
- contacting you on the grounds of us having a legitimate interest to do so to periodically send promotional mails or contact you by telephone about new products, special offers or other information which we think you may find interesting using the contact details which you have provided and for market research purposes
- where you give us your consent to do so, we may
- periodically send promotional emails or SMS messages about new products, special offers or other information which we think you may find interesting using the contact details which you have provided
In order to utilise your personal information, as set out about, we may allow third parties to process your personal information on our behalf. This is likely to be the case where, for example we:
- pass information to Certas Energy to deliver your order
- pass information to GPUK LLP trading as Global Payments (third party card processor) to process your payment.
Where we share personal information for these purposes, we put in place controls to ensure that your personal information is only used for the purpose for which we’re sharing it (e.g. to deliver your fuel to you). Where we want to allow third parties to process or control your personal information for reasons other than those set out above, we will inform you of this and, if necessary, seek your consent to share such information with them.
Where we have asked for your consent to use your personal information for a particular purpose, this consent may be withdrawn by you at any time. Similarly, where we are using your personal information to fulfil a legitimate interest of ours, you may have a right to object to your personal information being used for a particular purpose (e.g. for direct marketing). Please see the section entitled ‘Controlling your personal information’ below.
We may also invite you to leave a review on the Trust Pilot website. To invite you to leave a review, your email address will be shared with them. Should you not wish to leave a review, you can choose not to respond to that invitation. Trust Pilot retain your email address only for the purpose of sending this invite and for no other purpose.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 may only process your personal information where we have a lawful basis for processing it. What this lawful basis is will depend on the type of personal information you provide, and where we want to process personal information for a specific purpose not identified in this Privacy Policy we will notify you of this at that time.
Our lawful bases for processing your personal information are as follows:
Processing
|
Lawful Basis
|
Internal record keeping
|
Contract
|
Internal training/audit/compliance
|
Contract
|
Improving products and services
|
Legitimate Interests
|
Account Administration
|
Contract
|
Customising our website
|
Legitimate interests
|
Direct marketing – current customers*, mail and telephone
|
Legitimate Interests
|
Direct marketing electronic marketing
|
Consent
|
Direct marketing – non-current customers, mail and telephone
|
Legitimate Interest
|
Market research
|
Legitimate Interests
|
Preventing fraud and money laundering and verifying identity
|
Legitimate Interests
|
Trust Pilot
|
Legitimate Interests
|
In certain circumstances, we may be required to process your personal information in order to comply with a lawful obligation on us. This may be the case, for example, where a statutory or regulatory body requests such information in accordance with their legal powers. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. We also have a legitimate interest and, on occasion, a legal obligation to disclose personal information to regulatory bodies in certain circumstances, including where we have information about potential criminal acts or security threats, and may disclose information to authorities on this basis.
*If you proactively contact us to enquire about becoming a customer, we will treat you as a current customer for the purpose of potentially directly marketing to you on the grounds set out above.
Controlling your personal information
You may choose to restrict or control the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website or elsewhere, ensure that you do not tick any box requesting permission to use your personal information for specific purposes (e.g. marketing) or, in the case of ‘opt-out’ consents relating to electronic communications, ensure that you un-tick the relevant box
- if you have previously agreed to us using your personal information for direct marketing or other specific purposes and wish to change your mind
- if you believe that we are holding personal information which is incorrect, out of date or incomplete and wish for that to be corrected
- if you wish for your personal information to be erased from our systems
- if you wish for us to transfer your personal information to a third party (e.g. another service provider), we may provide you with your personal information which held by us for you to pass to that third party (or, in certain circumstances, we may be able to transfer that personal data to such third party directly if you wish for us to do so)
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 goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, 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 company for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or 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, product/service experience or other transactions.
Third Party Links and Cookies
Links to other websites Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website (s). Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
- Cookies
How we use cookies
Cookies are alphanumeric identifiers which enable our systems to recognise your browser in order that we can provide you with easy use of the various services available on the website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. The table below explains the cookies we use and why.
Cookie Name
|
Cookie ID
|
Cookie Duration
|
Additional info
|
Has Javascritp
|
has_js
|
A cookie that determines whether your browser has JavaScript enabled. Required by the content management system this site has been built with.
|
This cookie is strictly necessary for the website to operate.
|
Google Analyitics
|
_utma
_utmb
_utmc
_utmz
|
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This cookie is essential for the website to operate efficiently.
|
Click here for an overview of privacy at Google
|
Please refer to our full cookie policy available here for more details click here If you wish to learn more about cookies go to www.aboutcookies.org.
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.
- Data security
The security of your information is very important to us. As part of our commitment to keeping your data safe, our technical experts maintain physical, electronic and managerial procedures to keep safe the information we collect online. 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. These people will only be allowed access to your data for the purposes identified within this Privacy Policy, processing it on our behalf or for IT security and maintenance.
Where a third party is processing your data on our behalf, we will take steps to ensure that such third party gives us commitments that it will process your data in line with EU law. If a third party processing your data on our behalf is located in a non-EU country that does not have data protection laws equivalent to those in the EU, we will always take appropriate additional steps to ensure that your personal information is kept safe and secure by those processing your data on our behalf. This will generally involve ensuring that such third party agrees to sign up to a formal legal agreement committing such party to comply with standards equivalent to those that would apply where that party to be located within the EU. Whenever fraud prevention agencies transfer your personal data outside of the EU they impose contractual obligations on the recipients of that fata to protect your personal data to the standard required in the European Economic Area. This may also require the recipient to subscribe to “international frameworks” intended to enable secure data sharing.
Sometimes, you might wish to disclose sensitive information to us, for example if you need a priority delivery because you are receiving medical treatment. We will only use sensitive data for the specific reason you disclosed it to us and we will take extra care to keep it secure. From time to time, we will check with you that we may continue to use that sensitive data for the specified purpose. Similarly should you sign up to our Cold Weather Priority scheme, you will be asked to provide a specific consent to us holding sensitive information for the purpose of this scheme.
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.
- Data retention
How long will you use my personal data for?
The time period for which we keep information varies according to what we use the information for. Unless there is a specific legal requirement for us to keep information, we will keep your information for as long as it is relevant and useful for the purpose for which it was collected.
Where we are using your personal information to send you marketing information we will generally retain that information for marketing purposes for two years from the point of your last order as we understand that you even if you do not buy from us on every occasion, frequently we see repeat purchases from customers in this time period. We will retain your account information for seven years in line with relevant tax and contract requirements. In the case of commercial customers, we may retain personal information relating to such individuals within such customers for a longer period of time depending on the order and contracting cycles of such customers (e.g. if a customer commonly enters into five year deals, we would retain such information for a short period beyond the time when we would expect such agreement to be renewed).
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Where you have given consent to us holding data for a particular purpose, that consent may be withdrawn by you at any time. You may withdraw your consent by contacting us by any method that you wish to communicate with us, including e-mail or telephone. Our usual contact details are set out on the first page of this Privacy Policy.
You are entitled to request that we erase your personal information at any time, for example where you cease to be an active customer of ours. Whilst we will generally seek to comply with your request, there will be circumstances where we are entitled to retain such personal information (e.g. in respect of legal claims or to ensure that any activity on your account (e.g. monies owing) may be resolved).
- Your legal rights
Your rights
You have the right to:
- know that information is being processed
- access information that is being processed
- rectification of information being processed
- erasure of information held on you (commonly known as the right to be forgotten)
- restrict processing
- be notified about what information has been rectified, erased and restricted
- portability (that is, to request your data be handed over to someone else)
- object to the processing of your information
It is important to note that this is not an absolute right to review all the information that is held about you, as there are various exceptions to this right. These include:
- (a) where personal data is kept for the purpose of preventing, detecting or investigating offences and related matters; and
- (b) where the data is given by another person in confidence.
You may request that we cease to contact you for direct marketing purposes at any point. We will comply with any such request.
You are entitled at any point to see the personal information that we hold about you. This is called a Subject Access Request. If you want to make a Subject Access Request, or if you want to remove a consent, request that we cease contacting you for direct marketing purposes or request erasure or transfer of your personal information, you may do so at any time by writing to us at Data Protection, Certas Energy UK Limited, 1st Floor, Allday House, Warrington Road, Birchwood, Cheshire WA3 6GR, emailing us at This email address is being protected from spambots. You need JavaScript enabled to view it. or phoning your local Certas Energy contact centre.
We will not sell, distribute or lease your personal information to third parties for their control unless we have your permission, need to do so in order to fulfil a contractual obligation to you or are required by law to do so. Where we do seek your permission, we will name the relevant third party at the time we seek such permission from you and any such permission shall be limited to that third party. Please note that we may provide information for processing to certain third parties as outlined above.
If you believe that any information we are holding on you is incorrect, out of date or incomplete, please write, email or call us as soon as possible, using the details set out above. We will promptly correct any information found to be incorrect. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.
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.
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 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.
- 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Courier providers acting as processors based in the United Kingdom who provide delivery services of goods.
- 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.
- Professional advisers acting as processors and joint controllers including lawyers, bankers, auditors, accountants, insurers and pension advisors who provide their professional services.
- Service providers acting as processors based in the United Kingdom who provide IT and website system administration services.
- Web hosts service providers acting as processors based in the United Kingdom who provide website hosting services
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: (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 it 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 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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