Content Renewables Limited is committed to ensuring the privacy and security of your personal data.
This Privacy Policy Notice explains what personal data are processed about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, as well as the options you have regarding your personal data and where to go for further information. And in addition to our terms and conditions of supply
In this Privacy Policy, when we refer to “personal data”, we mean information which could directly identify you (for example, your name) and information which could indirectly identify you, meaning that it could identify you when combined with other information which we hold about you (for example, your date of birth).
Content Renewables Limited (company number 13439062) is the data controller of your personal data (referred to in this Policy as “Content Renewables” or “we”).
If you have any questions about your personal data which are not answered by this Policy, please contact our Data Protection Officer: Data Protection Officer, Content Renewables, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
HOW WE COLLECT YOUR PERSONAL DATA
We’ll use your personal data for the purposes outlined below:
To fulfil our contractual agreement to provide you with our products and services:
▪ Where requested by you, to provide you with a quotation for any of our products and services.
▪ To deliver our products and services to you according to our contractual agreement.
▪ To contact you with important information about your account.
To comply with our legal obligations, and for the establishment, exercise or defence of legal claims:
▪ To comply with our regulatory requirements, for example those under OFGEM such as Warm Home Discount, Green Deal and ECO.
▪ To meet our data protection obligations to verify your identity, before we provide you with information relating to your account.
▪ To resolve any disputes relating to your service usage with us.
▪ For the detection and prevention of crime, including any investigations into potential fraudulent activity, such as energy theft.
▪ To ensure that your contact details are correct, so that we are able to comply with our requirements to update the Emergency Services database.
▪ To respond to requests for information from the police and government bodies, to support in criminal investigations.
▪ To offer a priority service for vulnerable customers, such as those with specific health or medical conditions.
▪ To comply with legal and regulatory obligations including health and safety, trade control, anti-money laundering and/or bribery and corruption laws.
▪ To defend against litigation or legal claims.
Where we have legitimate business interests:
▪ To respond to customer enquiries and complaints.
▪ To understand customer behaviour using modelling, analysis and profiling, so that we can provide you with products and services that are best suited to your requirements, including execution and analysis of market surveys.
▪ For management information (MI) reporting purposes including the use of analytics to help us continually improve our offering and operations to our customers.
▪ To assess the financial vulnerability of our customers, so that we can ensure you are on the best plan for your individual circumstances.
▪ Subject to your marketing preferences, to provide you with information about products and services that we think you’d benefit from, by post, telephone or by electronic means.
▪ To provide you with energy insights, based on your consumption data.
Where we have your consent:
▪ To provide you with information about products and services that we think you’d benefit from in accordance with your marketing preferences.
We’ll collect the following information from you when you request a quote or eligibility check:
▪ Your name
▪ Contact address
▪ Email address
▪ Telephone number
To be sure that we’re providing the best support to your home, we may ask you for and/or process the following information, so we can tailor additional help and support appropriately:
▪ Information about any eligible benefits
▪ Details of your home insulation measures
▪ Any other information that you provide us with as part of your application.
This personal data may be shared with Network Operators, for example energy distributors and transporters to enable them to prioritise your property’s supply should any issues occur for example a loss of power supply.
Should your circumstances change, we may also ask for the updated information
We will also obtain or request the following information if you contact us with an enquiry or complaint:
▪ Any information that you disclose to us as part of your enquiry or complaint.
▪ Necessary information to resolve your complaint, which could include:
▪ Bills from your previous supplier
▪ Legal documentation
▪ Tenancy agreements
If you enter one of our surveys or competitions, we will collect the following:
▪ Your contact details
▪ Any information that you disclose to us in your responses.
If you visit our website www.contentrenewables.co.uk :
▪ Your device and browser may disclose certain information (such as device type, operating system, browser type, IP address, MAC number, dates and times our website was accessed and other information) that may be Personal Data
COOKIES AND SIMILAR TECHNOLOGIES
Content Renewables uses cookies and similar technologies that collect and store information when you visit our website. This is to enable content to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings.
INFORMATION COLLECTED BY OTHER SOURCES
Your personal data will be passed onto us from price comparison websites, brokers and third-party sellers should you choose to interact with them to generate a quote or open up an account with us.
Tenants, landlords and letting agencies:
▪ If you move into a property that is on supply with us, your details may be provided to us by the previous tenant, your landlord or your letting agency. This could include your name, property address, email address and contact telephone number.
Publicly available sources:
▪ We may use publicly available sources such as the electoral register, Land Registry, phone directories or Companies House to verify the information we hold about you.
Other companies with an appropriate lawful basis for sharing your personal data:
▪ Where you have given your consent to another company for us to market our products and services to you
▪ Provide information relating to your personal finances to enable us to offer you tailored service.
▪ To enable us to check any information which may be missing from your account i.e. date of birth to enable us to identify you if you contact us.
Screening:
▪ In addition, in order to comply with legal and regulatory obligations, to protect Content’s assets and employees/contractors and specifically to ensure that Content can comply with trade control, anti-money laundering and/or
bribery and corruption laws and other regulatory requirements, we carry out screening (pre-contract and on a periodic basis post-contract) on owners, shareholders and directors of our Business Customers, Suppliers and Business Partners. This screening takes place against publicly available, or government issued sanctions lists and media sources.
▪ The screening does not involve profiling or automated decision making in relation to the counter-parties or potential counter-parties.
HOW WE USE YOUR PERSONAL DATA
We’ll use your personal data for the purposes outlined below:
To fulfil our contractual agreement to provide you with our products and services:
▪ Where requested by you, to provide you with a quotation for any of our products and services.
▪ To deliver our products and services to you according to our contractual agreement.
▪ To contact you with important information about your account.
To comply with our legal obligations, and for the establishment, exercise or defence of legal claims:
▪ To comply with our regulatory requirements, for example those under OFGEM such as Warm Home Discount, Green Deal and ECO.
▪ To meet our data protection obligations to verify your identity, before we provide you with information relating to your account.
▪ To resolve any disputes relating to your service usage with us.
▪ For the detection and prevention of crime, including any investigations into potential fraudulent activity, such as energy theft.
▪ To ensure that your contact details are correct, so that we are able to comply with our requirements to update the Emergency Services database.
▪ To respond to requests for information from the police and government bodies, to support in criminal investigations.
▪ To offer a priority service for vulnerable customers, such as those with specific health or medical conditions.
▪ To comply with legal and regulatory obligations including health and safety, trade control, anti-money laundering and/or bribery and corruption laws.
▪ To defend against litigation or legal claims.
Where we have legitimate business interests:
▪ To respond to customer enquiries and complaints.
▪ To understand customer behaviour using modelling, analysis and profiling, so that we can provide you with products and services that are best suited to your requirements, including execution and analysis of market surveys.
▪ For management information (MI) reporting purposes including the use of analytics to help us continually improve our offering and operations to our customers.
▪ To assess the financial vulnerability of our customers, so that we can ensure you are on the best plan for your individual circumstances.
▪ Subject to your marketing preferences, to provide you with information about products and services that we think you’d benefit from, by post, telephone or by electronic means.
▪ To provide you with energy insights, based on your consumption data.
Where we have your consent:
▪ To provide you with information about products and services that we think you’d benefit from in accordance with your marketing preferences.
COMMUNICATION AND MARKETING – YOUR CHOICES
We’ll never sell your data to third parties for marketing purposes. However, subject to your marketing preferences, we may send you recommendations about third party products and services that could be of interest to you.
This information could be sent to you via telephone, email, SMS, post, push notification.
You can opt out or update your marketing preferences at any time by contacting us:
Telephone: 03301749001 Email: contactus@contentrenewables.co.uk
Post: Customer Services, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
PROFILING FOR MARKETING:
We’d like you to receive personalised insights and offers about products and services that are most relevant to you, at the right time. In order to do this effectively, subject to your marketing preferences we will analyse your personal data to create a profile of you for marketing.
Your profile will be used to send you personalised communications we feel you’d benefit from, based on a variety of factors such as:
▪ General postcode and demographic data from publicly available sources
▪ Information you have provided us directly
▪ The impact of variables such as the time of day/weather on your energy usage
▪ The stage of your contract you are currently at
▪ The channels you use to interact with us
▪ Your eligibility for government schemes, where applicable
▪ Any other products and services you have purchased from us
▪ Customer insight information from external data sources such as credit reference agencies and Experian.
You can opt out of profiling at any time by opting out of all marketing. This can be done by contacting us at:
Telephone: 03301749001 Email: contactus@contentrenewables.co.uk
Post: Customer Services, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
WHO WILL WE SHARE YOUR PERSONAL DATA WITH?
Your personal data may also be shared with any company that is a member of our group of companies or third party energy insulation companies, where necessary for internal administrative purposes, corporate strategy, auditing and monitoring, sanctions screening and research and development. For more information on how your personal data will be used for sanctions screening, please see the ‘Information collected from other sources’ section of this Privacy Policy.
Your personal data may also be shared with our group companies for profiling purposes, such as to determine whether you have purchased any other products and services from us.
We may also share your personal data with our group companies where they provide products and services to us that help us to provide products and services to you as our customer, including:
OTHER THIRD PARTIES
Your personal data may also be shared with the following categories of third parties:
▪ Energy and business services infrastructure providers, so that we can provide you with access to our products and services.
▪ Installation service providers, to enable us to send out engineers to your property.
▪ Price comparison websites and brokers, should you use these third parties to generate a quote or register as a customer with us.
▪ Fraud protection and prevention services, such as the TRAS fraud prevention agency, to help us to identify any potential fraudulent activity and for the prevention and detection of money laundering.
▪ Printing and distribution services, so that we can send out mailings to you.
▪ Industry regulators, legal and tax services, to help us comply with our legal and regulatory obligations and to improve our services/operations.
▪ Distribution Network Operators and Gas Transporters to provide your contact details for use in the event of a loss of supply or any information to support an investigation.
▪ Dispute and complaints services, should we need to resolve a complaint with you.
▪ IT service providers, to enable us to manage and host our IT platforms.
▪ Third party telesales companies and sales agents, who may contact you on our behalf with offers of our products and services.
▪ Social media platforms and contact management tools, to enable us to respond to any communications with you via our social media and digital channels and provide you with advertising about our products and services which we think may benefit you.
▪ Marketing and advertising agencies, to help us develop our marketing communications so that they are relevant for you.
▪ Survey hosting providers, to enable us to send out surveys to you so that we can learn from your feedback and improve our customer service.
▪ Voucher and gift fulfilment companies, should you be entitled to receive an incentive from us.
▪ Referral marketing platforms, should you choose to participate in a referral scheme.
▪ Independent organisations and charities, such as Citizens Advice, should you choose to engage with us or raise a complaint through these channels.
▪ Landlords, letting agencies and property managers.
▪ Management consultants to help us improve the service we offer to you.
▪ Law enforcement agencies and other public authorities such as the police.
We will also disclose your personal data to third parties:
(a) Where it is in our legitimate interests to do so to run, grow and develop our business:
i. if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
ii. if Content Renewables Limited or substantially all of its assets are acquired by a third party, in which case personal data held by Content Renewables Limited will be one of the transferred assets.
iii. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.
(b) To enforce our contract with you, to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.
(c) To protect the rights, property or safety of Content Renewables Limited, our employees, customers, suppliers or other persons.
Any third parties with whom we share your personal data are limited (by law and by contract) in their ability to use your personal data for the specific purposes identified by us. We will always ensure that any third parties with whom we share your personal data are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws.
Save as expressly detailed above, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent. Where you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so. You can do so by:
Telephone: 03301749001 Email: contactus@contentrenewables.co.uk
Post: Customer Services, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
TRANSFERS OF YOUR PERSONAL DATA TO OTHER COUNTRIES
Where your personal data have been transferred to companies and/or to authorised third parties located outside of your country (including outside of the European Economic Area) we take organisational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Content Renewable group and for Content Renewables companies in the European Union, European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection as well as any additional local legal requirements. For more information, please contact us by:
Telephone: 03301749001 Email: contactus@contentrenewables.co.uk Post: Customer Services, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
SECURITY
Content Renewables Limited have implemented appropriate technical and organisational measures to protect the confidentiality of the personal data that you entrust us with against unauthorised, accidental or unlawful access, loss, alteration and disclosure. We update and test our physical, logical and procedural security controls on an ongoing basis. These include limiting access to your personal data to those who need it and training our employees about the importance of maintaining the privacy and security of your personal data.
Interacting with Content Renewables through social media
If you choose to interact with us through social media on a Content Renewables administered social media page such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in Content Renewables) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to us.
You can delete any information that you share on these sites at any time through your relevant social media platform’s account. We do not track your activity across the different social media sites that you use. Please contact us if you wish to make a request that you are unable to action yourself and which relates to a Content Renewables Social Media Page. For further information please see the section ‘Your rights in relation to your personal data’.
Additionally, and to the extent Content Renewables is jointly responsible with a social media platform of a Content Renewables Social Media Page, we will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Content Renewables Social Media Pages. For more information on how your personal data is processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
HOW LONG DO WE HOLD YOUR PERSONAL DATA FOR?
We’ll only store your personal data for as long as is necessary to fulfil the purposes outlined in this Privacy Policy or for as long as we reasonably consider necessary to establish, exercise or defend our legal rights. Your data will be retained in line with statutory and
regulatory requirements. The criteria used to determine these retention periods includes:
▪ To comply with the minimum regulatory retention requirements as set by OFGEM, OFCOM and the Department of Energy and Climate Change.
▪ To comply with the statutory retention periods for accounting records, as set by the Companies Act and HM Revenue & Customs (HMRC).
▪ To comply with the retention periods set by the TRAS Fraud Prevention Agency.
▪ Where our retention periods are not governed by legislation, our retention policy is based on commercial justifications, which have been set in accordance with the principle of retaining personal data for no longer than is necessary for the purposes for which it is processed. These include:
▪ To comply with our Supplier Licence Conditions.
▪ To enable us to provide you with our products and services.
▪ To allow us to resolve any disputes or complaints.
▪ For the detection and prevention of fraud.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
The following section sets out your rights in relation to your personal data.
If you would like to exercise any of your data subject rights, please contact us by:
Telephone: 03301749001 Email: contactus@contentrenewables.co.uk Post: Customer Services, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
We aim to keep our information as accurate as possible. You can request:
▪ access to your personal data;
▪ correction or deletion of the personal data (but only where it is no longer required for a legitimate business);
▪ that you no longer receive marketing communications;
▪ that the processing of your personal data is restricted; and/or that you receive personal data that you have provided to Content Renewables in a structured, digital form to be transmitted to another party, if this is technically feasible.
COMPLAINTS
If you would like to make a complaint, please contact our Data Protection Officer:
Data Protection Officer Content Renewables, Suite 4102 Charlotte House, Queens Dock Business Centre, Norfolk Street, Liverpool, Merseyside, England, L1 0BG.
If you are unsatisfied with the handling of your personal data by Content Renewables Limited, then you have the right to lodge a complaint to your local data protection authority The Information Commissioner’s Office (ICO) whose address is Wycliffe House, Water Ln, Wilmslow SK9 5AF, Great Britain or the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit autoriteitpersoonsgegevens.nl/en for more information.
CHANGES TO THE PRIVACY POLICY
This Privacy Policy does not form part of any customer’s contract with us and we may amend it from time to time. Any changes we make to our Privacy Policy in the future will be posted on our website and, where appropriate, notified to you by email.
This Privacy Notice was last updated in January 2023.
