Energy Marketing and Trading and Your Personal Data: Business Customers

For our business energy services and connection and metering services such as smart meters, the data controller is Tiga Limited.

These are collectively referred to as the “Services”.

This document is our privacy notice for the Services.

It explains your statutory rights and how we collect and use your personal data.

It describes the processing activities that are carried out by Energy Marketing and Trading in relation to the Services, the purposes for which these activities are performed and the legal basis that Niccolo relies upon for these processing activities.

This notice applies to personal data we hold about individuals (such as company directors, or contacts on business accounts), including sole traders and partners.

It does not apply to information which we hold about companies and other legal organisations.

We may update this privacy notice from time to time to ensure it is always up to date and accurate.

Any changes we may make to our privacy notice will be posted on this page, and we will communicate any significant changes to you.

You can contact Niccolo’s data protection officer by writing to The Data Protection Officer, Energy Marketing and Trading, Hudson House, 8 Albany Street, Edinburgh, EH26 8QR.

You can also contact our data protection officer at privacy@energymarketingandtrading.com

1. Personal data we collect

We collect the following types of personal data from all customers:

• Your contact details and the contact details of people associated with your business account: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your business account or order.
• Audio and video recordings and contemporaneous notes.
• Responses to surveys: we keep records of any studies to which you and your business respond.
• Records of your discussions with our customer support teams, including call recordings, webchat and emails: when you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our support team or contact us via webchat or through social media sites such as Twitter or Facebook.
• How you use mobile applications and websites: we use technology such as cookies (subject to your cookie preferences) when you use our applications or websites, as well as our pages and profiles on social media sites, and we collect information about the pages you look at and how you use them.
• Location information: your smartphone or computer’s IP address may tell us an approximate location when you connect to our websites, but this will be no more precise than the city, state or country you are using your device in.
• Device and machine information: information about the computer hardware and software on your computers and smartphones that are used to connect or communicate with us.
• 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.
• Advertising and direct marketing preferences and responses: information about how you respond or interact with, any direct marketing or advertising communications directed to you, including any requests for these communications to stop.

We collect the following types of personal data from sole traders and partners in a partnership:

• Anti-fraud information: where you purchase insurance products and services from us, we will carry out anti-fraud checks.
• Business account information: information about your account with Energy Marketing and Trading including your login details for our websites and mobile applications, unique account number, unique customer identification, contract details, job details , property type, premises details, previous supplier, proposed new supplier, meter and gas point numbers, meter details, energy consumption, tariff details, marketing preferences, complaints details, incident details, and dispatch appointment details.
• Loyalty programme: information about your loyalty programme, including which rewards you choose.
• Transaction and payment information: credit/debit card details and bank account details you provide to make payment for the products and services you and your business purchase from us.
• Purchase and account history: records relating to the products and services which you and your business have purchased or used from other companies in the Niccolo group or us.
• Financial information: information that allows us to understand your creditworthiness and financial position.
• Lifestyle and demographic insight information: how you use our services.
• Vulnerability information: information that allows us to understand whether you are a vulnerable person including health, disabilities and other information which could indicate that you, your family members, tenants or where there is shared supply between your premises and residential premises require extra care.

You are not required to provide to us any of the personal data described above. However, if you do not do so, you may not be able to purchase our products and services or the functionality of our products may be reduced.

• What we use your personal data for and why

Where we process your personal data because of our contract. We process these items of your personal data to enter or fulfil the contract between us, including:

Where we process your personal data because we’re legally obliged to

We process these items of your personal data because we have a legal obligation to, including:

Where we process your personal data because we have a legitimate interest to

We process these items of your personal data because we have a legitimate interest to do so. We process the following categories of personal data, including:

Where we process your personal data because you have allowed us to

We process these items of your personal data when you have provided your consent to the processing. You may revoke your consent at any point

Sources we collect your personal data from

We will collect personal data from several sources.

These include:

• Directly from you: when you set up an account with us, purchase products or services from us, submit information via our websites or apps, 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, and also from our energy generation and export meters, and other devices we provide.

• Our website and mobile applications: we collect information about how you use them and any smart devices you connect to them.

• Our smart devices such as smart meters and other devices we provide: we collect information about how you use them.

• Other companies we work with: provide us with information to help us deliver and match our products and services to you.

These include:

– Companies in the same group of companies as us: who may provide relevant information about the products and services bought from them.

– Meter installation booking companies

– Debt collection agencies

– Service and metering engineers

– Lead generation providers and brokers

– Other companies’ apps and products: provide us with information if you connect them to our products or services

– Network operators and distributors: to connect your meter to the energy network.

• Credit and anti-fraud reference agencies: provide us with information about your transaction and claim history and credit history.

• Client relationship management agencies: we will check the information we hold about you against information other companies hold about you to see it is accurate and up to date. If any conflict arises, the other company will provide us with changes that need to be made to your personal information.

• Network operators and distributors: to connect your meter to the energy network.

• Third party data providers: companies to which you give contact information, where you permit for them to pass it on to us for updating information we hold about you.

• The government, ombudsman services, and regulators: provide us with information about the complaints they receive and help us to deliver services.

• Housing associations: some housing associations provide us with tenants’ data, to enable us to make contact about their energy supply.

• Social media: information you submit to our social media accounts.

• Our business customers: provide us with information about their customers.

• Your previous energy provider: we may ask your previous energy provider for information about meter readings, equipment, and payments.

• Other companies’ apps and products: if you permit them to provide us with information when you connect them to your connected devices and smart home products.

• Tracing activities: where you do not have an energy supply contract with us but move into a site, where we are supplying either gas, electricity, or both to that site, we will use third parties such as Google, Land Registry to try and identify you so that we can contact you about the energy supply being consumed by you.

• Public registers: such as the Land Registry and Companies House.

• Private registers: such as Zoopla that provide us with information about your property.

Whom we share your personal data with

We share personal data with the following categories of third parties. We never sell your data to a third party for their marketing use.

Direct marketing

Email, SMS, post and telephone marketing:

From time to time, we may contact you by email, SMS, phone or post with information about our products and services we believe you may be interested in. When you call Niccolo, we may also provide you with information about products and services we think you may be interested in. If you have not consented to receive direct marketing communications, we will only send these communications to you when permitted to do so by law, but in all circumstances we will respect your marketing preferences which you set when you first create your account with us (or you first deal with us), or which you update from time to time. You can let us know at any time that you do not wish to receive marketing messages by sending an email to us at privacy@energymarketingandtrading.com You can also unsubscribe from our marketing by clicking on the unsubscribe link in any email marketing messages or by replying STOP to the number indicated on any marketing text messages we may send to you, or by calling the Customer Care Team on 0131 610 1368.

 Direct marketing and advertising on websites and mobile applications

You can find out more about cookies and how to manage their use by reading our cookie policy, which is available at: https://www.energymarketingandtraing.com/cookies-policy/. The details here provide a high level overview of how and where we capture and/or use personal data on our own and third party websites and mobile applications.

Energy Marketing and Trading websites and mobile applications

When you visit any of our websites or download any of our mobile applications, you will always be provided with access to the site or application’s privacy notice and cookie policy. We aim to ensure that our websites and mobile applications are always working optimally for those who use them. When you visit our websites, and you are an anonymous visitor, we will use cookies and similar technologies – in accordance with your cookie preferences – to track anonymous details such as response times, the pages you view and the functionality you use.

No individual is uniquely identifiable from this data, and it is used purely to enable us to review and improve these services constantly. Any adverts you may see while using the website anonymously will be generic in nature, i.e. it will not use any personal data to ‘personalise’ the advert to you.

If you chose to complete an online application, enquiry or another form then the form will set out explicitly how the data you provide will be used. If you are logged in, or we can see that you were previously logged in, we will use cookies and similar technologies – in accordance with your cookie preferences – to track your use of the site or application. In this instance, some data may be recorded to your record to enable us to provide the best ongoing service to you.

Transferring your data internationally

Energy Marketing and Trading is a modern organisation, and in common with other organisations, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where our customers and we are located. This includes countries outside the European Economic Area (“EEA”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully.

How long we keep personal data for

We will keep your data for as long as is necessary to achieve the processing purposes.

Your rights in relation to your personal data

You may have the following rights in relation to your data:

• the right to be informed about the personal data we collect, how your personal data is being used, and from whom we collect your personal data when we obtain it from other sources;

• the right to access the personal data we hold about you;

• the right to request the correction of inaccurate personal data we hold about you;

• the right to request the blocking or deletion of your personal data in some circumstances;

• the right to request that we port elements of your data either to you or another service provider;

• the right to object to us processing your personal data (1) where we have a legitimate interest to do so, as listed in section 2, but your rights override ours based on your particular situation (which you will need to explain to us), (2) where we are processing it for direct marketing, or (3) because we are using automated means to make decisions that have a legal or similarly significant effect; and

• the right to withdraw your consent to those processing activities which we carry out on the basis of consent, listed in section 2.

You only have the benefits of some of the above rights in limited circumstances, which depend on the legal reason why we collected your personal data.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us using the details below.

Getting in touch If you have any privacy-related questions or comments, please contact Niccolo’s data protection officer by writing to The Data Protection Officer, Energy Marketing and Trading, Hudson House, 8 Albany Street, Edinburgh, EH1 3QB.

You can also contact our data protection officer at privacy@Energy Marketing and Trading.com

If you are unhappy with the way we are using your personal data, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator.

We are here to help and encourage you to contact us to resolve your complaint first.