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FIDELITY ENERGY LIMITED (we/us/our) is committed to protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes.
Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you (set out below or in our agreement with you) or in the way you ask us to, and we will give it back to you at any time.
1.1 This policy, together with any terms and conditions or other documents we provide to you at any time during our relationship with you, sets out how we will process your personal data.
1.2 This policy will apply to our contract with you. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act 2018 (Act) and/or the UK GDPR (having the meaning given in section 3(10) (as supplemented by section 205(4)) of the Act, as applicable.
1.3 By visiting our website at www.fidelity-energy.co.uk/privacy-policy (our Website), or by providing your personal data to us, you understand, accept and consent to the practices described in this policy.
1.4 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
1.5 For more information relating to your rights under this policy, please see section 9.
1.6 If you have any queries relating to this policy, please contact us at partners@fidelity-energy.co.uk in the first instance.
2.1 For the purposes of the Act, the data controller (or data processor from time to time) will be FIDELITY ENERGY LIMITED, a company registered in England & Wales (number 09258334) with our registered office at 90 Bartholomew Street, Newbury, Berkshire RG14 5EE.
2.2 We are registered with the ICO to process your personal data and our registration number is ZA200079.
2.3 Your personal data will be held and stored by us in our internal management information systems on servers located in the UK. All personal data is processed by UK based staff who are regulated by our internal staff data protection and information security policies. All staff receive appropriate data protection training as part of their induction process with us.
3.1 We do not ordinarily rely on your consent to process your personal data. We process your personal data primarily to perform our contract with, and provide our services to, you. We consider the personal data we obtain is reasonable and necessary for these purposes. However, we review this intermittently and remove any inaccurate or obsolete data in accordance with our internal data retention policy.
3.2 By using our Website and/or our services, you expressly consent to:
3.2.1 the transfers of your personal data to those specifically listed third parties in this policy, for the reasons specified; and
3.3 Where you consent to marketing from us, we confirm that we only market our services directly and do not engage any third parties to do this on our behalf.
3.4 You may exercise your rights under section 9 at any time, which includes withdrawing your consent to our processing of your personal data (where we rely on your consent to process such data). However, where this withdrawal prevents us from performing our contract with you, we may not be able to provide our services to you.
4.1 We will only collect your name, business email address, address (business or personal) phone number and date of birth. This is to allow us to create your account in our internal system to monitor the progress of your order, and to contact you in relation to it.
4.2 Where you are a current, potential or former employee, worker or other member of our staff, we may collect additional categories of your personal data for the purposes of providing you with the necessary benefits under our contract with you. In those circumstances, a separate privacy notice applies and a copy is available on request.
4.3 If your personal data changes, or becomes inaccurate at any time, you must let us know to avoid any errors or delays in our services.
5.1 When you provide it to us
Your personal data is primarily provided to us when you complete our new partner form or provide us with a letter of authority to act on your behalf in relation to providing our services.
When you correspond with us by phone or e-mail as part of our business with you, any of your personal data contained in that correspondence will be retained by us.
5.2 When we collect it from you
When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings.
We also monitor your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.
5.3 When we receive it from others.
So that we can provide our services to you, and can verify your identity and your ability to continue to make payments to us, we will use recognised third party credit rating/reference agencies to carry out credit checks on you. Any information in that credit report that allows us to identify a natural person will be retained by us for the purposes of providing our services. We may also receive personal data from our referral partners who are contracted to refer new customers to us.
6.1 Your personal data is primarily required to enable us to supply you with the relevant services and support you have requested from us, and to contact you in relation to any enquiries or requests you raise with us.
6.2 We also use your personal data to send you information about us, our services, energy market insights, events and any recent market updates that are similar to those you have already purchased or enquired about. Where required by law, we will only do this where you have given us permission to do so, and you can opt out at any time by using the opt-out mechanism provided in the communication or by contacting us using the details in section 1. Where you opt out, we will no longer send you marketing until you ask us to, and we will not prompt you to do so. Your marketing preferences will not affect service or contractual communications which we need to send you.
6.3 Technical information we collect about your visit to our Website is used to enable us to:
personalise and improve its functionality and security (to keep it safe and secure)
administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes; and
ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary.
6.4 Once collected, your personal data will be retained by us for as long as is necessary for us to provide you with the relevant services, to market our services to you (where requested) and to enable us to improve our Website. After this point, the data will be securely deleted and we will not contact you unless you ask us to.
6.5 We may use your personal data, including your contact details and relevant account or business relationship information, to communicate with you (and your authorised representatives) in connection with the provision, administration and management of our products, services and contractual relationships. These communications may relate to your accounts, contracts, renewals, billing, service updates, regulatory requirements and other matters associated with the delivery and management of our services.
6.6 Depending on the purpose of the communication and applicable legal requirements, we may contact you by telephone, email, SMS, MMS, WhatsApp, voicemail, post, customer portals or other appropriate digital messaging and communication channels. Where a particular channel requires your specific consent (for example WhatsApp), we will ask for that consent separately and record it before contacting you through that channel.
6.7 We process your personal data in accordance with applicable data protection legislation, relying on an appropriate lawful basis, which may include contractual necessity, legal obligation, our legitimate interests or your consent, depending on the circumstances. Marketing communications are managed separately from service communications and are sent only where permitted under applicable data protection and electronic marketing legislation, including where any necessary consent or other permission has been obtained.
7.1 All personal data we host is stored in accordance with our internal Information Security & Data Protection Policy, on which all staff are trained. All locally held data is encrypted using AES 256-bit encryption, and all hardware is protected using endpoint security tools.
7.2 We do not host data on any physical servers at any of our premises. All personal data we process is stored on Cloud-based servers hosted by the following providers:
Salesforce.com, Inc., a company incorporated in the USA (Delaware) and/or salesforce.com EMEA Limited, a company incorporated in England and Wales (Salesforce) and their affiliated companies and appointed sub-processors. We use Salesforce as our customer relationship management (CRM) system to hold customer and prospect records and to send and manage email communications with you. Salesforce impose binding corporate rules in relation to the processing of personal data within its group of companies and more information is available at http://trust.salesforce.com; and
Microsoft Azure, a Cloud-hosting solution provided by Microsoft Corporation (Microsoft). Our Microsoft Azure environment is hosted in Microsoft’s UK data centre regions, so personal data stored there remains within the United Kingdom. Where Microsoft or its sub-processors need to access personal data from outside the UK, for example for support purposes, Microsoft relies on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. More information is available at https://www.microsoft.com/en-gb/trust-center.
All personal data contained on internal or external communications is stored on Microsoft’s Office365® OneDrive.
7.3 Access to the personal data we store within our systems is restricted to personnel who have received appropriate data protection training, and those members of staff with appropriate seniority (account managers, members of our senior team, and members of our operations teams).
7.4 Access to all of our databases is by two-factor authentication software. All passwords are held securely and any access to back-end servers requires this as well as user-based authentication. Staff have access only for the purposes of performing their roles.
8.1 The very nature of our services requires us to pass your personal data to third party energy and utility providers to enable them to assess your usage needs and provide you with an accurate quote going forward. As there are many providers in the United Kingdom, it is not practical to list all of these in this policy, but where a quote is provided we will notify you as to which company is processing your personal data on our behalf. Where we have received your personal data from a referral partner, we will also make that personal data available to any successor of that referral partner where the successor is taking over the obligations of the original referral partner under their contract with us.
8.2 Where you have told us that you would like to receive services from Etainabl Limited (“Etainabl”), we will share your name, contact details, usage data and meter details (including serial numbers, MPRN, MPANs, meter addresses and billing data) with Etainabl so that they can provide the requested services to you going forward.
8.3 Any websites which are linked from the Website are outside of our control and not covered by this policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.
9.1 In relation to all of your personal data, you have the following rights (in addition to any rights you may have under the Act or UK GDPR) to ask us:
9.1.1 not to process your personal data for marketing purposes;
9.1.2 to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
9.1.3 to amend any inaccurate data we hold about you;
9.1.4 to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time);
9.1.5 to only process your personal data in limited circumstances, for limited purposes
9.1.6 to obtain a copy of your personal data on request;
9.1.7 to stop processing your personal data in instances where we are relying on legitimate interests as a legal ground for processing;
9.1.8 to stop processing your personal data for a period if the personal data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing personal data; and
9.1.9 to transfer your personal data to another party.
9.2 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).
9.3 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
9.4 Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
10.1 Our carefully selected service providers may process personal information about you on our behalf. Our current processors are the cloud hosting providers described in section 7.2, the credit reference agencies described in section 5.3 and, where you have requested their services, Etainabl Limited as described in section 8.2. We do not currently appoint any third-party marketing agencies to process your personal data. If we appoint additional processors who will process your personal data, we will update this policy.
