TruEnergy Privacy Policy

Introduction
This Privacy Policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your PII in accordance with our website.
Most of the data we collect and hold about you is for the purpose of providing your energy. We also use data to make TruEnergy’s products and services better, and to help us advertise TruEnergy.
This Privacy Policy should help you work out what we collect your data for and how we protect it for you. If you have any questions about it, please email customercare@truenergy.co.uk.

Supply you with energy
We gather information about you and your home, so we can accurately supply your energy. For example, we need to know your address to supply the right property, and we need to know how much energy you use so we can send you accurate bills.
Where necessary, we share this with other organisations in the energy industry, like your old supplier, Ofgem and the organisations that maintain the national energy databases.

Make TruEnergy better
We collect data on how you use our website and other features. We track things like where you click on our site and what features you use. This lets us learn what is working well and what features we need to improve.
We sometimes share this data in an aggregated form with agencies or partners that are helping us. For example, we might tell a telecommunications partner how many phone calls we get a week.

Advertise TruEnergy
We use your data to help grow TruEnergy and spread renewable energy. If you are a member of TruEnergy, we share data with social media, search engine, and other advertising platforms so that we stop asking you to join TruEnergy, and instead show you content more relevant to you.
We also share aggregated data with agencies that help us with advertising. For example, we might share with an agency how many of our members live in Scotland.

Communicate with you
In addition to sending you key information about your account by email, from time to time we will also send you information about things we think will interest you. 
Where necessary, we share your data with organisations that send communications on our behalf. 

Information that we collect:
Information you provide us at sign-up

• Contact information: such as your name, address, email address, date of birth and telephone number.
• Vulnerability information: such as disabilities, age, or health conditions for you or a member of your household. This helps us provide suitable additional services.
• Financial information: such as your payment details and financial circumstances. We need your bank details if you want to pay by direct debit. If you have difficulty paying our bills, providing details of your circumstances helps us work with you to resolve this.

Information while we provide your services

• Information about your energy supply: such as your meter reference numbers and meter type. This ensures we link you with the right meter and keep industry databases accurate.
• Energy you use: such as details of your energy use and your supply start and end dates. If you have a smart meter we will take consumption data directly from your meter. We need details of your energy usage, so we can send you accurate bills.
• Energy you generate: details of energy you generate under the Feed in Tariff (FiT) scheme. We need this information, so we can accurately calculate the payments due to you.
• Customer service data: when you get in touch by phone, email or community posts we monitor, record and review those communications so we can provide the best possible service to you and all our members and so we can show evidence of transactions or events.
• Data about your interactions with us: such as information about how you communicate with us (by phone or email) and how you use our website or interact with our ads and content on other websites. 
• Technical data: such as IP addresses (including the general information in such address, such as city, county and postcode), login details and other information about your mobile devices, browser types and browser language.
• We do not use cookies for tracking purposes: You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies. If you turn cookies off, some of the features that make your site experience more efficient may not function properly that make your site experience more efficient and may not function properly.

Information provided by others

• Affiliates and partners: if you sign-up with TruEnergy through an affiliate or partner (such as a price comparison website), we are sent your personal information from that partner so we can enter into a contract with you.
• Energy industry partners: metering and debt information can come from other organisations involved in supplying your energy, such as your old supplier and meter operators.
• Landlords and estate agents: data such as your name and contact details may be provided to us by people moving in or out of a property you are occupying, or a landlord or estate agent. We may use this information to contact you in relation to the continuation of the energy supply to your property.
• Councils, postal services, and data brokers: information such as contact details, homemoving status and other details about your circumstances can be provided by councils, postal services and data brokers. We will always check that these organisations have your consent or are otherwise legally permitted to share this information.

How we use this information
It is important that you understand what we will do with the data that we hold about you, as well as the lawful reasons we are allowed to do this.
We may sometimes combine information that we collect from you with information we obtain about you from third parties and affiliates and information derived from any other subscription, product, or service we may provide.
We use the information we hold about you for the following purposes:
Performing our contract with you
We need to process information in order to supply your energy and the services you have asked for under our contract. For example, we may use your information (such as your contact information) to organise your switch to TruEnergy, to take monthly payments and organise meter repair jobs.
Fulfilling our legal and regulatory obligations
Many of the ways we manage your energy are based on requirements set out in our Licence and by Ofgem directions and Codes, such as how we may set out your annual statement and how we deal with disputes. We may also need to comply with court orders, and disclose information to law enforcement agencies.
Adding you to our Priority Services Register with your consent
If you have let us know that you (or a member of your household) need extra care or have any vulnerabilities, we will ask for your explicit consent before we add your details to our Priority Service Register. This helps us take steps to ensure your safety.
For our legitimate business interests
This means that using your information is necessary for us to build our business and provide our services to you. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. Our legitimate interests include:

• Maintaining and improving our services: for example, we may use your information that we obtain through your emails and calls to train our team. We may also use your information to ensure that our services are working as intended – for example, understanding which parts of the website are easiest to use. We may also contact you for suggestions on how we can improve the way we provide our services to you.
• Providing personalised services, including suggested payment amounts: for example, we may use information such as your account balance and expected annual energy use to make an automatic adjustment to your payment amount.
• Providing personalised advertising: we may let advertising platforms like Facebook and Google know that you are a member of TruEnergy by sharing your contact details with them. This means we can stop asking you to join TruEnergy once you are with us, and instead share information with you that we think you might be interested in.
• Communicating with you about our services: we may contact you about TruEnergy news, product updates and new products that we think you might be interested in. We may also contact you to provide you with offers, competitions, marketing materials and other promotional materials, both online and through other marketing channels, such as third party social networks.
• Measuring our performance and developing new services: for example, we use data for measurement to understand how our services are used. We also use aggregated data to understand our members and their energy usage better. This helps us develop offerings such as our Annual Impact Report.
• Helping to prevent and detect fraud or debt: we also need to be able to detect and prevent fraud and recover unpaid bills.

If you have questions about the lawful basis on which we collect and use your information, you can email our Data Protection Officer at customercare@truenergy.co.uk.

Sharing your information
When we share your information
We sometimes need to allow our service providers to process personal information we hold about you on our behalf for the reasons set out in this Privacy Policy or as otherwise required by law.
We make sure that these third parties will not use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law. This includes the following types of organisations:

• Trusted businesses or persons: who process your information for us for the purposes set out above, based on our instructions and as set out in our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with member support or payment processing.
• Energy industry partners: including other suppliers, network operators and energy market administrators.
• Marketing agencies, search engines and social media networks: to advertise TruEnergy and to gather feedback on TruEnergy such as through customer surveys.
• People you have authorised us to share data with: such as family members, energy brokers, solicitors and debt management companies, so we can fulfill your requirements.
• Market regulators: such as Ofgem and consumer protection organisations such as the Energy Ombudsman, where we are obliged to do so under regulations.
• Price comparison sites and other affiliates: to ensure that we can fulfill a contract you have requested.
• People you are referring to TruEnergy: if you refer a new member to us, we may share your first name and aggregated data about your energy use with the referred person.

When you share your own information
Sometimes you may share your information publicly, such as social media sites. Remember, when you share information publicly it may become accessible through search engines.
Sending your data outside the European Economic Area
Sometimes our agents and service providers are based outside the European Economic Area, so when working with them, we may pass your information outside of the European Economic Area to countries that do not have the same data protection standards as the UK.
If we do this, we will ensure that any information will be protected in line with this Privacy Policy. Some of the safeguards we rely on to share your information outside the European Economic Area include ensuring that the supplier has, if in the USA, certified to the Privacy Shield.

Your rights
If we collect or handle your personal data, you have rights as an individual which you can exercise in relation to the information we hold about you:

• To correct or update your personal information, you can call or email us on customercare@truenergy.co.uk.
• To delete your personal information, you can email us at customercare@truenergy.co.uk. We will delete any information that we no longer need to hold, but we will not always be required to do this. For example, we may need to hold your information to continue to provide your energy under our contract. If this is the case, we will explain why.
• To ask us to restrict processing of your personal information or transfer your personal information to a different organisation, you can email us at customercare@truenergy.co.uk.
• To confirm if we are using your personal information or get access to all your personal information that we hold, in an easy to understand, portable and secure format, you can email us at customercare@truenergy.co.uk with the subject line “Subject Access Request”.
• To object to the processing of your personal information, you can email us at customercare@truenergy.co.uk.
• To withdraw consent to process your data, you can email us at customercare@truenergy.co.uk at any time.
• To opt-out of marketing communications you can email us at customercare@truenergy.co.uk.

Once we receive a request from you, we will respond within at most 1 month, but usually a lot quicker. Before actioning these requests, we will need to positively identify you.
If you are unhappy with how we have handled or processed your personal information – or you want further information about your rights – you have the right to contact the Information Commissioner’s Office, the supervisory body that regulates handling of personal information in the UK.
Keeping your information secure
Whilst we cannot ensure or guarantee that unauthorised access to or unauthorised alteration, disclosure or loss of information will never occur, we work hard to prevent it. In particular:

• We use encryption to keep your data private while in transit.
• Your account information is protected for your privacy and security. 
• To help keep your account and your personal information secure you should not disclose your details to anyone. 
• We review our practices for collecting, processing and storing personal information, including physical security measures, to guard against unauthorised access to systems and backups to prevent the loss of information. We will continue to enhance our security procedures as new technology becomes available.
• We restrict access to personal information wherever possible to people who need to know that information to process it and who are subject to contractual confidentiality requirements.

Retaining and holding your information
We keep the personal information we collect for no longer than is necessary for the purposes for which we collected it.
The length of time depends on the purposes for which we use it, or otherwise to meet our legal obligations.
We will delete any information as soon as we no longer have a valid reason to hold it. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

About this Privacy Policy
When this Privacy Policy applies
For the purposes of this Privacy Policy, “we”, “us”, “our” and “TruEnergy” means TruEnergy Ltd and other companies in the same group. Unless otherwise stated, TruEnergy is the Data Controller for your personal data.
This Privacy Policy applies to how we use your information in relation to our products and services generally.
This Privacy Policy does not apply to other companies’ sites that you get to through our website or social media pages. Therefore, make sure you have read their privacy policy before putting your personal information on their site.
Changes to this Privacy Policy
We may change this Privacy Policy at any time. If we make any changes, we will post them on this page. If they are substantive changes, we will also have a more prominent notice letting you know. You can also email or write to us for a physical copy.
Your continued use of our services will mean that you accept and agree to any changes to the Privacy Policy.

Contact us
You can get in touch about anything in this Privacy Policy by emailing us at customercare@truenergy.co.uk.
Last updated: The Privacy Policy was last updated on 14th June 2018.