Easy2switch UK Ltd (our registered office address is Unit 1b Breach Farm Egdon Lane Egdon Worcester WR7 4QW (Company number: 05469909)) (“we”, “us”, “our”) is committed to protecting and respecting your privacy. We are registered with the Information Commissioner’s Office (“ICO”) with registration number ZA268242.
This policy (together with our terms and conditions of service) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. When you provide your personal data to us, you are deemed to have read this privacy policy and to have accepted the terms set out herein.
We are the controller and responsible for your personal data.
We trade under the names Easy2switch UK Ltd
Alternatively you can email us at info@easy2switchuk.com.
Questions, comments and requests regarding this privacy notice are welcomed by using the contact details above.
Please note that you have the right to make a complaint at any time to the 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.
We keep our privacy notice under regular review to ensure that it properly reflects our use of your personal data. We will notify you of any changes we may make to our privacy notice in the future.
This privacy notice was last reviewed and updated on 15 May 2018.
It is important that the personal information we hold about you is accurate and current. Please let us know if any personal information which we hold about you needs to be corrected or updated at any time.
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 use different methods to collect personal data about you, and there are different ways that we might do so. This privacy notice tells you what to expect when we collect personal data on:
(a) visitors to our website, www.easy2switchuk.com;
(b) anyone who interacts with us or contacts us through social media;
(c) anyone who contacts us by phone, or when we contact you by phone;
(d) anyone who uses our services;
(e) you when you are transferred by one of our third party partners to our website, or one of our third party partners provides us with your personal data; and
(f) third party marketing partners.
This privacy notice also explains the types of personal information we collect from you, and the lawful basis we rely on under data protection legislation to use your personal data. Under data protection legislation, we are only permitted to use your personal data if we have a lawful basis for doing so as set out in the data protection legislation. Where we rely on our legitimate interests (or those of a third party) as the lawful basis for processing, we have done so on the basis that our legitimate interests (or those of a third party) do not override your interests and fundamental rights. This is called the “balancing test” and you have the right to ask us for information on the test that has been undertaken, by using the contact details above.
Should you apply for a position with us we will retain your information in accordance with our data retention, deletion and security policies. Should you be unsuccessful in securing a position we will retain your information for 6 months in order to assess suitability for upcoming vacancies and as a record of application for the role. If you are successful the information you have provided will form part of your Employee Record and we will retain this for the duration of your employment and for 6 years after your employment ceases.
We will collect details of your visits to our website, including traffic data, location data, weblogs and other communication data and the resources you access on our website. We may also collect information about your computer and your visits to and use of our site, including, where available, your device’s IP address, geographical location, operating system, referral source, browser type, length of visit and number of page views. We will collect this information for the purposes of system administration, optimising the use of our site and reporting aggregate information to third party suppliers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
In particular, we use an analytics service provider for website traffic analysis and reporting and to track information such as which browser, screen resolution and IP address you are using to access our website, in addition to tracking your movements around our website. We are currently using Google Analytics for this purpose.
Our site contains links to and from the websites of our third party partner networks, suppliers and affiliates. If you follow a link to any of these websites, please note that these websites collect personal data for their own purposes and have their own privacy notices. We do not accept any responsibility or liability for these third parties or their data activities on such websites. Please check their privacy notices before you submit any personal data to these websites.
Any information you provide to us via social media (including messaging, “liking” or “following” and other communications) is controlled by the relevant social media network.
Our website contains links to our social media pages. We currently use Facebook and Twitter.
Our website provides you with different ways to contact us. You may choose to call us, or submit a query to us or request a call-back from us. All communications are handled, reviewed and responded to internally by us.
As part of communicating with us, you will submit personal data about yourself which includes your name, email address, telephone number and any other additional information you choose to provide to us. We will use your personal data for our legitimate interests (or those of a third party) where it is necessary for any of the following:
We will retain records of our correspondence with you, for a period of 7 years from the date of last correspondence.
Please note that we record all telephone calls from our call centre, either when we contact you or you contact us. It is in our legitimate interests to record these calls to:
We will retain copies of call recordings for a period of 7 years from the date of your call.
Our website provides price comparison services for energy suppliers. We will collect personal data from you when you complete a form on our website in order to access our price comparison services or when you contact us by post, telephone or email.
The table below sets out the categories of personal data we collect from you, the purposes for which we use your personal data and the lawful basis we rely upon for processing your personal data:
| Category of personal data | Purpose | Lawful basis of processing |
|---|---|---|
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To provide you with our price comparison services. | It is in our legitimate interests to use this information to be able to deliver our service and to provide you with a realistic indication of prices available to you. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To carry out our obligations arising from any contracts entered into between you and us. | Contractual necessity, as this information is needed by us to perform our obligations under the contract. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To notify you about any changes to our services. | Contractual necessity, as this information is needed by us to perform our obligations under the contract. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To ensure that content from our website is presented in the most effective manner for you and your device. | It is in our legitimate interests to study how customers use our products/services, to develop them and to grow our business. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To enable us to effectively administer, develop, support and improve our website and improve your browsing experience by personalising our website. | It is in our legitimate interests to study how customers use our products/services, to develop them and to grow our business. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To collate statistical information about customers and carry out market research. | It is in our legitimate interests to tailor our service, grow our business and to inform our marketing strategy. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To enable us to provide customer services in relation to our services and to deal with enquiries and complaints made by or in relation to our customers and/or products supplied to our customers. | It is in our legitimate interests to provide you with our services, investigate and resolve your enquiry or complaint. |
| Any other personal data you provide us with. | ||
| Title, first name, surname, email, business address, telephone number, mobile number, and address. Any other personal data you provide us with. | To allow you to participate in interactive features of our service, where you choose to do so. | Consent – you will be provided with a clear choice to participate in these features and you will have the right to withdraw consent at any time in accordance with section [3.7]. |
| Any other personal data you provide us with. |
In the course of using our services, whether you choose to switch energy suppliers or not, we will retain your personal data for a period of seven years from:
(a) the date you provide us with your personal data and/or express an interest in our services, or subscribe to our services; or
(b) the date your contract with us ends, whichever is the later.
We work with a number of third party partners to provide you with price comparison services. When you access our services through our third party partners, we will collect personal data about you in the following circumstances:
Please note that we will be the controller of your personal data from the stage we are provided with your personal data (either directly from you or one of our third party partners, whichever is the earlier). You should refer to this privacy notice for details on how we will use and treat your personal data. Please refer to sections 3.1 and 3.4 for further information on how we will use your personal data when we are providing you with our services.
From time to time, we will obtain personal data from Market Location, a member of the 118 Group. This includes your name, email address, telephone number and business address. In these circumstances, we will take reasonable steps to ensure that such third party has collected your personal data fairly and lawfully and, if applicable, has obtained all appropriate consents required from you to allow us to market to you. Market Location is one of the most experienced business database providers in the UK. They take the protection of your personal data and compliance with data protection legislation seriously. If you would like to find out more about Market Location’s use of personal data, their own privacy notice can be found at: https://marketlocation.com/privacy-fair-processing/.
If we have obtained your personal data from the 118 Group or any other third party source, we will inform you of where we collected your personal data within a reasonable period of time of having obtained your personal data and provide you with a copy of this privacy notice.
We rely on our legitimate interests as a lawful basis for processing your personal data, to offer and promote our products and services to you.
If you are a customer, or have made an enquiry, we will have given you a clear opportunity to object or opt-out of receiving marketing communications at the time of collecting your personal data. If you have not opted out of receiving the marketing communication, we will contact you by email or telephone in our legitimate interests to promote our products and services that are relevant to your purchase or enquiry. We will also provide you with the option to unsubscribe or object to continuing receiving marketing with each communication. You have the right to object to receiving these communications at any time by contacting us on the details above.
If you are not a customer but are interested in our products and services, we will provide you with a clear choice to consent to receiving marketing promotional material, updates, reminders and communications by giving you an opt-in to receiving such communications. If you have provided your consent we will collect your contact details (name, postal address and email address) to provide you with such communications.
You have the right to withdraw your consent at any time. For full details on how to withdraw consent please see above.
We use a third party, Pure 360, to manage our newsletter subscriptions.
If you ever decide you no longer wish to receive our marketing communications, you can opt out at any time by unsubscribing from the mailing list, using the link provided in the marketing communications email, or by using the contact details above. If you do unsubscribe, please note that we will still keep your email in a separate secure list so that we can make sure that you do not receive our marketing communications again in the future.
We will need some of your personal data as a contractual necessity in order to provide you with our services or contact you and follow up with you in respect of any query or complaint you have submitted on our website. For example, we need to know your personal contact details in order to identify you and contact you.
Where information is needed for these purposes, if you do not provide it we will not be able to provide you with our services, or contact you and follow up with you in respect of the query or complaint you have submitted on our website. We explain this is the case at the point where we collect this information from you.
We use third parties to provide services to us from time to time. We will share data with them where it is in our legitimate interests for our business administrative needs. A list of third parties that we use and how they process personal data is set out in the table below. Please note that these third parties are located within the European Economic Area.
| Third party | What data? | Why do we share this data? | How long is this data kept by this third party? |
|---|---|---|---|
| Energy suppliers (gas and electricity) | Title, first name, surname, email address, home number, mobile number and address. | We share this data for a number of reasons, including: To enable you to switch energy suppliers To whom disclosure is necessary to enable us and/or a supplier to determine if you are eligible to subscribe to our services and/or the supplier's services; and To whom disclosure is necessary to enable us to provide you with any service to which you have subscribed (including for the purposes of contract fulfilment, processing payments, credit referencing, designing, maintaining and administering the site). | These third parties will be acting as controllers of your personal data. You will be notified of which energy supplier your personal data has been provided to at the relevant time. Please refer to their own privacy notice for information about how your personal data is used and retention periods. |
| Cloud hosting companies | Title, first name, surname, email address, home number, mobile number, business postcode (if this is also your home address) and any other personal data you provide to us. | Hosting of our servers and all of our customer data. | We are responsible for deleting your personal data from our cloud servers in accordance with sections 3.3 and 3.4 above. |
| Telecommunications Service | Title, first name, surname, email address, home number, mobile number, business postcode (if this is also your home address) and any other personal data you provide to us. | To provide our main call system and to record our calls. | 7 years for call recordings |
| Data processing, hosting and related activities | Title, first name, surname, email address, home number, mobile number, business postcode (if this is also your home address). | To provide marketing services. | Please see section 3.7 above. |
| Electronic Waste Recycling Organisation | Title, first name, surname, email address, home number, mobile number, business postcode (if this is also your home address) and any other personal data you provide to us. | To securely recycle IT hardware. | All data is securely erased from the hardware. |
We will not usually disclose your personal data other than as already explained in sections 3 and 5 above. However, there may be circumstances where we need to share personal data other than as anticipated in sections 3 and 5 above. These include:
(a) where we are legally required to disclose the information. This includes sharing the personal data with tax authorities and law enforcement agencies for the purposes of the prevention and detection of crime;
(b) where we need to disclose the personal data for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
(c) disclosure is required to protect our interests, or someone else’s interests (for example, to prevent fraud or credit risk reduction);
(d) disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance);
(e) it is to a third party for the purposes of providing administrative or processing services on our behalf. If such disclosure is required we will take steps to ensure that the third party protects the personal data in the same way that we do and notify you of any changes to this privacy notice; and
(f) to any prospective purchaser of our business assets or organisation.
We know that you provide your personal data in good faith and expect it to be looked after. This is why we take the security of your personal data seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal data. This includes:
(a) locating all personal data that we control on servers located in the United Kingdom;
(b) ensuring strict access controls to your personal data on a need to know basis and monitoring such access to customer personal data;
(c) encryption of the personal data on our website and all electronic transactions using SSL technology; and
(d) where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential, together with any login details and/or user details. We ask you not to share your password, login or user details with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and prior to us receiving it. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access including those measures set out above.
You have rights in respect of your personal data and this section explains a bit more about those rights that are applicable to how we use your personal data, and the circumstances in which you are able to exercise these rights. If you would like more information about any of your rights, please contact us on the details set out above.
We want you to fully understand and be comfortable with how we use your personal data. You can contact us at any time to ask whether we process any personal data about you. If we do hold or use your personal data in any way, you have the right to access that personal data. All we ask is that:
(a) you make your request to access in writing to the contact details above;
(b) you verify your identity; and
(c) you are fair and reasonable with how often you make this kind of request (please note if you are unreasonable in the number and frequency of requests you make, we may charge an administrative fee for processing any further requests. We will notify you of this prior to incurring such an administrative fee).
Please allow us up to one month from receipt of your request (or verification of your identity, whichever is the later) in order to provide you with our response.
We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal data. We have tried to be as clear and as open as we can and will continue to update this privacy notice as our use of personal data develops. However, if you have any questions regarding our use of your personal information, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details above.
You also have some additional rights that you may exercise as set out here. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses above and provide verification of your identity.
(a) You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address).
(b) You have the right to request that we erase your personal data. Please be aware that we can only comply with such a request if
(c) You have the right to request that we restrict or refrain from processing your personal data:
(d) You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into a contract (contractual necessity). If you exercise this right, we will transfer a copy of the information that you have provided to us at your request.
(e) You have the right to object to our use of your personal data: