Privacy Policy

These were last updated on 1 April 2022 – Version 3.0

We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This privacy notice is to help you understand how we collect your personal data what we do with it.

When we refer to “we”, “us”, and “our”, we mean:

  • Igloo Works Limited (a company registered in England under registered number 12100615); and
  • Igloo Renewable Assets Limited (a company registered in England under registered number 12921597); and
  • Lightbulb ES Limited (a company registered in England under registered number 10074259);

all with their address at The White Building, 1-4 Cumberland Place, Southampton, SO15 2NP and the other members of the group of companies it is part of, and we are the data controller of the personal data collected about you.

By “you” or “your” we mean any individual, sole trader and/ or partnership that gets products or services from us, uses our website, or interacts with us in another way.

If you have any questions, comments, or concerns about this privacy notice, please contact our Data Protection Officer who’s details are section 16 below.

1. Scope of this Privacy Notice

This privacy notice sets out the way in which your information you provide to us, and information about you collected by us, is handled, stored and processed.

2. Where do we get your information from?

Your information may come to us from different sources:-

  • Directly from you: when you purchase products or services from us, submit information via our websites complete forms we provide to you, enter our competitions and promotions, make a claim, make a complaint, exercise your statutory rights, contact us by phone, email or communicate with us, our Website and apps: we collect information about how you use them and any smart devices you connect to them.
  • Other companies we work with: provide us with information to help us deliver our products and services to you, and to help us advertise to you our products and services. These include:-
    • Lead generation providers.
    • Market research and feedback providers.
    • Third party installers
    • Third party insulation companies
    • Third party EPC providers
    • Debt collection agencies and credit referencing agencies
  • Credit and Anti-fraud reference agencies: provide us with information about your transaction, claim history and credit history.
  • Third party data and insight providers: companies which provide us with relevant information about you and your property, to help us operate our business and deliver our services to you.
  • The government, ombudsman services, and regulators: for example, information about the complaints they receive, or to help us deliver services such as verifying eligibility for discount schemes and grant schemes.
  • Social media: information you submit to our social media accounts.
  • Other companies’ apps and products: provide us with information if you connect them to our products or services.
  • Public registers such as the Land Registry: provide us with information about your property.

3. What sort of information do we obtain?

We collect the following types of information:

  • Your contact details and the contact details of people associated with your account: name, email address, billing address, property address, phone number, any other relevant info we need in order to know that it’s you.
  • Your account data and the account data of other people associated with your account: unique account number, date of birth, title, whether you’re a homeowner or renting, , your energy consumption data, survey responses, Energy Performance Certificate (EPC) data, , conversations we have with you, including phone calls and emails, which might be monitored or recorded, household details and property type, complaints and/or incident details, appointment details, notes added to your account.
  • Financial data: information that allows us to understand your creditworthiness and financial position, including any discount schemes and or grants you may be benefitting from.
  • Transaction and payment information: credit/debit card details and bank account details you provide to make payment for the products and services you purchase from us.
  • Purchase and account history: records relating to the products and services which you have purchased or used from us.
  • Technical data via cookies (see our cookies section below):
  • Optimisation data: for some products and services, we might ask you to give us extra data about your home and lifestyle, to make sure you get the most out of whatever you’re using.
  • Marketing and communications data: your communication preferences; your preferences in receiving marketing from us, your preferences in receiving marketing from third parties.
  • Sensitive types of data: Data about your needs and the needs of other people in your household to understand if you or anyone in your household has any special requirements, disabilities, health and/or any financial vulnerability.
  • Exercising your rights: if you exercise any of your statutory rights under data protection law, we will keep a record of this and how we respond.

4. How we use your information

We use your information to operate, provide and improve the services we offer you, both through our website, our app, email, and on the telephone.

We may also aggregate information and generate statistics for the purposes of measuring the functionality and features of our services.

We have provided information below on the different reasons and purposes we collect your information and our lawful basis for processing this information.

Provision of Energy Related Services

Purpose To allow us to provide you with energy related services and tools to support the effective use of these services.

Lawful Basis Because of our contract with you.

Dealing with your enquiry or a complaint

Purpose To allow us to effectively deal with any enquiry or complaint you or others may have.

Lawful Basis Because we have a legitimate interest in effectively dealing with enquiries and complaints, whilst protecting the rights of individuals.

Improving services

Purpose Working with our partners and academic research institutions to make improvements to services. Supporting public interest research on UK energy consumption such as energy reduction, climate change and helping energy networks operate more efficiently and using the output from this research to improve our services to you and trying to help you reduce the amount of energy you use and your carbon emissions.

Lawful Basis Because we have a legitimate interest in improving our services and it is carried out in the interests of the public.

Providing promotional materials regarding our services

Purpose To provide those members of the public and customers who have requested information about us and our services to be kept up to date

Lawful Basis With your explicit consent for this information to be sent to you. This consent will be dated and will be compliant with data protection law consent requirements.

Dealing with rights of data subject requests

Purpose To allow us to respond to requests under data protection law for individuals to exercise their rights e.g. to access their own information, request erasure of information, object to processing etc.

Lawful Basis We are legally required under data protection law to respond to data subject requests.

Managing information breaches

Purpose To be able to assess any impact on individuals of an information breach involving information held on our systems or on third party systems.

Lawful Basis We are legally required under data protection law to respond to information breaches appropriately.

Legal Matters

PurposeT o deal with legal claims and ongoing litigation cases.

Lawful Basis Necessary to comply with a legal requirement or to establish, exercise or defend of legal claims.

Supplier Management

Purpose To ensure appropriate financial management of ongoing contracts with our suppliers.

Lawful Basis In order to manage the contract with that supplier.

Improving the use of our website and IT systems

Purpose To ensure appropriate system administration and troubleshooting of website and app issues, to track the pages you have visited in order to improve the quality of the site and to personalise the website experience. To keep track of and solve issues users are experiencing with our apps and other systems.

Lawful Basis Consent is sought for use of cookies when you access our website. Ensuring our systems are working effectively and user issues can be resolved is part of our legitimate interests in running the organisation effectively.

Staff Training and Development

Purpose To ensure staff are appropriately trained to deal with customers and their requirements.

Lawful Basis As part our legitimate interests in effectively training our staff to carry out their roles effectively.

5. Does Igloo Works Limited have to use my information?

We process your information to be able to provide you with the services you need or to liaise with our suppliers in relation to your services. Without your information we wouldn’t be able to do this, we use the minimum amount of information we need to do this.

Where you have previously asked to be kept informed of our services, you can ask us to stop sending you this information, and we will remove your name from our marketing lists. Please let us know if you would like to do this using the contact details in section 16 below or via the unsubscribe options on the communications you receive.

6. When we might disclose your information

We may disclose your information to any of our insurers, professional advisers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes set out in this privacy notice. We may share your information with third parties to perform services on your behalf and to help promote our business. Types of third parties who may have access to your information include:

  • Business process outsourcing providers who provide specific services into the business including third party IT system suppliers who may host your information on their systems and may need some level of access to resolve technical concerns and potentially other business support areas.
  • Organisations who support us in serving you advertisements and content online about our services that we think you might be interested in.
  • Academic research institutions and third parties who we carry out research with to improve our services and improve understanding generally of energy consumption in the UK (with your consent where this information is identifiable to you).
  • Any business that may buy our company or integrate our company into their business. In this situation, your details may be disclosed to our advisers and any prospective purchasers and their advisers and may be passed on to the new owners of the business.

We may disclose your information:

  • To the extent that we are required to do by law.
  • In connection with any ongoing or prospective legal proceedings.
  • In order to establish, exercise or defend our legal rights (including providing information to others for the purpose of fraud prevention and reducing credit risk).
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that information where, in our reasonable opinion, such an authority would be reasonably likely to order disclosure of that information.

We will never sell or share your information with other organisations for their direct marketing purposes without your explicit consent.

7. How long we keep your information for

Information that we process for any purpose will not be kept for longer than is necessary for that purpose. Different purposes will have different retention periods and we will retain your information:

  • To the extent that we arenrequired to do so by law.
  • If we believe that the information may be relevant to any ongoing or prospective legal proceedings.
  • In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
  • To support our ongoing business purposes (with due consideration for the rights and freedoms of individuals privacy).

If you would like further details of how your information is retained by us, please contact us directly using the contact details in section 16 below.

8. Your rights

You have a number of rights under data protection law including:

  • The right to be informed about the collection and use of your personal data e.g. via this privacy notice.
  • The right to access your personal data.
  • The right to have any inaccurate personal data rectified, or completed if it is incomplete.
  • The right to have your personal data erased in certain circumstances.
  • The right to request the restriction or suppression of your personal data in certain circumstances.
  • The right to data portabilitym- to obtain and reuse your personal data for your own purposes across different services.
  • The right to object to our use of your information in certain circumstances e.g. for marketing or profiling purposes.

If you would like to access your own information or exercise any of the rights detailed above, please contact us using the details in section 16 below. If any of your details change, you can contact us and we will make the necessary updates.

In the majority of cases, we will respond to your request within one month of receiving the necessary information required to deal with your request.

We may ask you to supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport plus an original of a utility bill (not one of ours) showing your current address and any additional information to help us to deal with your request effectively.

There may be some exemptions to dealing with your rights as specified in data protection law, but we will ensure you are fully informed of this within a month of receiving your request.

Full information on your rights under data protection law can be found from the following link:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Can I object to your use of my information?

You can withdraw your consent for use of your information for marketing by unsubscribing. On all communications provided by us we will provide you with details on how to withdraw your consent to the continued receipt of communications from us.

If you would like to object to the above or any other uses of your information please contact the Data Protection Officer using the contact details in section 16 below.

How do I raise a concern if my rights are not met?

If you have a concern that cannot be resolved through discussion with us, these can also be raised with the Information Commissioner’s Office. More information can be found from the following link:

https://ico.org.uk/concerns/

9. How do we use cookies and other information gathering technology?

We collect certain information automatically through the use of "cookies." A cookie is a small file of letters and numbers that we put on your device (smart phone, tablet, computer) if you agree when you access our app or website via the same device.

We use various types of cookies, including session cookies which improve your internet browsing experience (for example, by helping to load web pages more quickly) and analytical cookies. We use analytical cookies to enable us to recognise and count the number of visitors to our website and app and to see how visitors move around our website and app. This is used to help make our websites and apps easier to use.

Information collected

Our cookies collect information about your device behaviour such as usage and location data. We do not use cookies to collect or record information on your name, address or other contact details.

What are cookies used for?

The main purposes for which cookies are used is:

  • For technical purposes essential to effective operation of our application, and website particularly in relation to user experience.
  • To enable us to market to you, web banner advertisements and targeted updates.
  • To enable us to collect information about your device behaviours, including to monitor the success of campaigns and competitions.
  • To improve our product offering – by understanding our customers, we can ensure we offer you products and services that you want and that can try to save you as much energy as possible.
  • To improve the way our website and apps works, for example by ensuring that customers are finding what they are looking for easily.

We will never sell any of the information we collect about you to any third party.

How do I disable cookies?

You will be provided with the option to accept the use of cookies when you access our website and apps. If you do not accept the use of cookies then we will not be able to provide you with tailored content and offers to the same level as we can when the cookies are enabled, and some parts of our website and app may become inaccessible or not function properly.

10. Profiling

Data protection law includes certain provisions around how information can be used for:

  • Profiling – where information is processed to evaluate certain things about an individual.
  • Automated individual decision making – where a decision is made based on your information solely by automated means.

This includes ensuring that individuals are made aware of profiling and or decision making, how decisions are made based on this and the consequences of these decisions.

We do not carry out any automated individual decision making about individuals but in relation to profiling, where appropriate, we will use your information to create profiles based on you, your home and your energy consumption to evaluate your suitability for specific energy saving products and to tailor promotions to your circumstances and preferences.

We will also use your information to improve our services to help you use energy more efficiently. These will include the aggregation and analysis of energy data such as - your historic consumption, information you may have given us such as your location or social media details and publicly available information such as the Energy Performance Certificate for your property.

If you would like further information on how your information is used to develop profiles, please contact us using the contact details in section 16 below.

11. Transferring information outside the European Economic Area

We may transfer information that we collect from you to third party data processors or service providers located in countries that are outside of the EEA (the European Economic Area) in connection with the purposes for which we have collected it from you. If we transfer your information outside the EEA we will only do so where one of the following applies:

  • There is an adequacy decision by the European Commission which means that the recipient country is deemed to provide adequate protection for such personal data.
  • Where the transfer of information is to a member of our group of companies, and we have in place binding corporate rules with such member which safeguard the information.
  • Where we have in place standard model contractual clauses (which include certain safeguards to protection information) with the recipient which have been approved by the European Commission.
  • If such transfer is needed to enable us to perform our contractual obligations to you relating to products or services we have agreed to provide to you.

12. Security of your Information

We are committed to taking all reasonable steps to protect your information, including the use of appropriate technical and organisational controls to ensure your information is stored, accessed and shared appropriately. Our people are trained in the appropriate management of confidential information and our website and apps have been security tested to ensure the safe sharing of your information with us. All our procedures will be reviewed routinely and updated to ensure they continue to protect your information effectively in line with advances in technology and data protection law.

13. Third party sites and apps

Our website may contain links to other websites and apps operated by third parties. Please note that we cannot be and are not responsible for information that third parties may collect, store and use through their websites and apps. You should always read carefully the policy of each website and app you visit.

14. Different formats of this privacy notice

The information provided within this privacy notice can be made available in different formats including in printed form, and methods that meets the need of the visually and hearing impaired.

Should you require this information in a different format, please contact our Data Protection Officer using the contact details in section 16 below.

15. Changes to our privacy notice

This privacy notice will be reviewed regularly , should any new types of processing be identified or changes to data protection law mean changes are required. Any changes we may make to our privacy notice in the future will be posted on this page and, so please check from time to time to see if there are any changes.

This version of our privacy notice was updated on April 1st 2022 (version 3.0).

16. Contact Us

If you have any questions about our privacy notice, our use of information or if you wish to exercise your rights in respect of your information, please contact us by email or telephoning 0333 016 4500.

Our Data Protection Officer can be contacted directly by emailing DPO@igloo.energy or by writing to:

Data Protection Officer

Igloo Works Limited

1-4 Cumberland Place

Southampton

SO15 2NP