We shall always ensure all personal data is collected in a fair and lawful manner and used only for specified purposes. We will always make sure that any personal data collected and held is relevant to the product or service provided. We will never hold personal data any longer than is necessary for the purpose and we will dispose of it appropriately when it is no longer required.
If you have any questions or concerns about this Policy, please email our data security team at firstname.lastname@example.org.
Your personal information
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).
Collecting your information
We will collect personal information about you during our sign-up process, when you get in touch with us, use our website or just as part of providing our services to you.
We may also be provided with your personal information by other parties.
- Comparison websites or energy switching companies – this is so that we can provide our service to you.
- Energy industry partners – this includes Energy Supply Data and Vulnerability Data so that we can supply your energy safely and accurately, these partners may include your previous supplier(s) and metering agents.
- Landlords and estate agents - Contact Data may be provided to us by occupiers moving in or out of a property, 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 - Contact Data, moving-home status and other details provided by councils, postal services and data brokers.
- Referral scheme - Contact Data may be provided to us by people referring you to So Energy as part of our Refer a Friend scheme.
Categories of information
We have set out below different categories of data that we may process and include some of the reasons why we need this information.
- Contact Data – this includes your name, date of birth or age range, address, email address and telephone number. We need this to verify your identity and to enter into a contract with you.
- Financial Data - your bank details and payment details in order to pay for the services rendered.
- Energy Supply Data - your energy usage, technical information on your meter(s), supply history and smart meter data that lets us know that it is safe and operating and recording correctly.
- Technical Data – this includes internet protocol (IP) 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 account log in username and password, your interests, preferences, feedback and survey responses.
- Data about your communications or interactions with us - such as information about how you communicate with us (by phone, emails, or chat) and how you use our website and App or interact with our ads and content on other websites. More information can be found in our Cookie section further down.
- Marketing and Communications Data - includes your preferences in receiving marketing content from us and our third parties and your communication preference.
- Vulnerability Data - such as information relating to your health, disability or financial circumstances. This information helps us to provide you with appropriate services to keep you safe and to determine eligibility for a Priority Services Register (PSR).
- Customer service data - when you get in touch by phone, email, chat or on social media we monitor, record and review those communications so we can provide the best possible service to you and all our customers and so we can show evidence of transactions or events.
Apart from when required to (Vulnerability Data referred to above), we do not collect any Special Categories of Personal Data about you (this also includes details about your race, 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.
How we'll use your information
We’ll only use your personal information where necessary and allowed to by law. Generally, this will be under one or more of the following circumstances:
- To provide our services. We need to process your information to supply your energy and the services you’ve asked for. For example, we may use your information to arrange your switch over to us, manage payments towards your energy and maintaining your meter(s). We also use your personal information to add you to the Priority Service Register if necessary.
- To help us improve or develop our website, services and products. We will aggregate data, in order to improve our operations and ensure we are providing you with the best service possible. All aggregated data is anonymised and doesn’t reveal your identity.
- To fulfil our legal and regulatory obligations. We are governed under Gas and Electricity Supply Licence conditions and by Ofgem directions and Codes. We may need to comply with court orders and disclose information to law enforcement agencies if required.
- To help us prevent and monitor any debt, fraud and loss that may occur.
- To make sure that our employees are trained properly as well as meeting our regulatory and legal responsibilities. Through this, we may monitor and record your calls, emails or webchat to do so.
- If consent has been provided, we will get in touch with you about incentives schemes, products and services that we or our partners are offering.
- To administer and protect our business, website and app (including monitoring and recording troubleshooting, data analysis, testing, system maintenance, support and reporting.
- To maintain and improve 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 or whether service emails are correctly delivered. We may also contact you for suggestions on how we can improve the way we provide our services to you.
- To provide personalised advertising: we may let advertising platforms like Facebook and Google know that you are a customer of So Energy by sharing your contact details with them. This means we can stop asking you to switch So Energy once you're with us, and instead share information with you that we think you might be interested in.
- To communicate with you about our services: we may contact you about product updates on our website and app, and through other marketing channels, such as third party social networks, like Facebook.
Some of these above-mentioned purposes are 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.
Getting in touch with you
We’ll always contact you by the method we’ve agreed with you when you signed up to us.
Smart MeterTaking your smart meter readings with your consent
If you use a smart meter and we are able to operate this remotely, we'll normally collect readings from your smart meter once a day. You can decide whether we take a reading for the entire 24-hour period or for each half-hour period. We won't take more than one reading a day unless you have given us your consent. If you'd prefer us to only take one reading a month, you can email us at email@example.com.Analysing your smart meter readings to offer you new products and services with your consent
If you use a smart meter and we are able to operate this remotely, we could use your smart meter readings to understand how you use your energy. For example, we could learn how to buy energy for lower prices and be able to build and offer you new products and services. We will only use your smart meter readings to do this if you have given us your consent. You can email us at firstname.lastname@example.org at any time to withdraw this consent.If you have any questions or concerns about how we use your personal information, please email our data security team at email@example.com.
We sometimes need to allow our service providers to process your personal information on our behalf for the reasons set out in this Policy or as otherwise required by law.
If you decide you want to change your marketing preference, you can change your preference in your So Energy online account or you can just send an email to firstname.lastname@example.org and we’ll update your preferences for you.
Disclosing your information
We may also transfer your personal data to third parties for the purposes set out in How We’ll Use Your Information.
- To give you the product or services you've requested. We may have to give information to one of your family members, household, anyone acting on your behalf or other people who have an interest (like landlords or letting agents).
- To help find and prevent debt, fraud or loss.
- We'll have to disclose your details if any unpaid debt is transferred to another organisation.
- For legal or regulatory purposes such as our regulator, Ofgem, or for consumer protection organisations such as the Energy Ombudsman.
- Service providers who provide engineering services, industry data collection and aggregation, call-centre, IT and system administration services.
- Marketing agencies to provide you with information about our products and services or other products and services which may be of interest to you (provided you’ve given your consent) and to help manage any reward or loyalty schemes.
- If you're leaving us as an energy customer, we'll pass on your information on to your new suppliers. This may include any special assistance requirements and information about you as an energy customer.
- If we are asked to provide information to the police or law enforcement agencies we will require them to provide a warrant, unless we feel that it is in the best interests of our customers or the public to provide the information without a warrant.
We make sure that these third parties won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law.
Sending your data outside the European Economic Area
Occasionally, we may need to pass your information to our agents and service providers, this may involve people or organisations outside of the European Economic Area (EEA). The laws of some of the jurisdictions in which these people or organisations are located may not be as robust as those of the UK.
How we protect your information
We follow strict security procedures to protect personal information. This includes following certain guidelines (for example, checking your identity when you phone us).
We recommend that you do not disclose your account login details to anyone. Please always remember to log out of your account when you have finished accessing your online account.
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.
We use encryption to keep your data private while in transit.
We regularly review our practices for collecting, processing and storing personal information, including physical security measures, to guard against unauthorised access to systems and backups.
Retaining your information
We will only keep your 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 used it, or otherwise to meet or 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.
A 'Cookie' is a piece of information stored on your computer that records how you've used a website. Don't worry they're completely anonymous and we don't store any personal information.
We may use 'cookies' to monitor how people use our website. Cookies help us to understand how our customers and visitors use our website, so we can make improvements to its design, layout and functionality. Short-term cookies are also able to recognise your computer and remember non-personal information each time you use the site, so you can just pick up where you left off each time.
We use programs such as Google Analytics to help us find out:
- how many people visit our websites;
- which pages are most popular;
- how long people spend in each area;
- what information they’re searching for.
These insights help us understand how to improve our websites.
- browser types;
- operating systems;
- referring sites that sent you to us
- the dates and times of a visit.
We also use third party analytics services like Hotjar, which is similar to Google Analytics.
It allows us to:
- see where people click on a webpage
- follow mouse patterns
- track non-sensitive text that people might type into the site.
We use Facebook Pixel and Google Analytic Advertising to track the performance of our advertising campaigns and allow us to tailor the advertising you might be interested in.
Every email we send to our customers contains small gif files, also known as tracking pixels. These are tiny graphic files that contain unique identifiers that enable us to recognise when our marketing subscribers have opened an email or clicked certain links. This allows us to record each subscriber's email address, IP address, device ID, date, and time associated with each open and click for a campaign. We use this data to create reports about how an email campaign performed and to amend future campaigns based on subscriber interactions.
If you don't want us to use your cookies, you can change the settings of your browser preventing it from accepting cookies, or to notify you when a website tries to put a cookie on your computer. See www.aboutcookies.org for more information on deleting or blocking cookies.
Please bear in mind, if you do disable this function, you might not be able to use some of the products or services on our website.
You can also opt out from these third parties’ targeting through the following sources:
- Google Analytics Advertising Features – visit https://www.google.com/settings/ads and adjust your personal settings as per their instructions;
- Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
- Hotjar: https://www.hotjar.com/legal/compliance/opt-out
You have various rights in relation to your personal information.
- Request access to your personal information - you can request a copy of the personal information we hold on you.
- Request correction of your personal information - if any personal information we hold on you is incorrect, you can request to have it corrected. You can update personal information that we have on you via your online account.
- Request erasure of your personal information - you can ask us to delete your personal information in certain circumstances. If we are not able to do this we will explain why we cannot.
- Object to processing or restrict processing of your personal information - you may object to our processing of your personal data in certain circumstances.
- Request the transfer of your personal information - to provide you, or a third party you have chosen, with your personal information.
- Withdraw consent to processing of your data - where we’re relying on consent to process your personal information.
About this Policy
For the purposes of this Policy, “we”, “us”, "our" and “So Energy” means So Energy Trading Ltd. Unless otherwise stated, So Energy Trading is the Data Controller for your personal data.
Changes to this Policy
Last updated: 1 July 2019