SM4U Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.sm4u.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1) Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
2) Information About Us
Our Site is owned and operated by SM4U Ltd, a Limited Company registered in England under company number 10486766.
Registered address: SM4U Ltd, 1 Heather Court, Shaw Wood Business Park, Shaw Wood Way, Doncaster, DN2 5YL
|Postal Address:||As above|
|Data Protection Manager:||Fiona Lindley|
|Telephone number:||01302 802050|
3) What Does This Policy Cover?
4) What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5) What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6) What Data Do We Collect?
We collect your data directly and this data may include:
- Your name, address, and in some cases your date of birth (so we can check you are eligible for the scheme and contact you regarding your installation);
- Proof of identity (which may be collected to evidence a supporting component or for eligibility evidence);
- Copies of documents showing proof of benefits and income supplied to you by the Department for Work and Pensions and HMRC (this will be limited to information showing you are eligible for the scheme);
- Your phone number and email address (so you can be contacted as necessary for the Purpose outlined in this notice);
- Optional: the financial amount you have contributed towards the cost of the installation (to help the Department for Business, Energy and Industrial Strategy develop future schemes).
- IP address, Web browser type and version, Operating system, a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
7) How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.
Your personal data may be used for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by email.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services.
You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and
Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies.
Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
8) How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Retention for measures with a twenty-five-year guarantee (including wall insulation): we may retain your personal data for up to twenty-five years, or as needed to match the lifetime of the guarantees provided
- Retention for all other measures: we may retain your personal data for up to seven years after the scheme ends, in line with HM Revenue & Customs record management.
- The Department for Business, Energy and Industrial Strategy, will hold some information, including your address, but not your name or other personal information, for up to 25 years for statistical purposes.
9) How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows. Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Encryption of your personal data.
10) Do You Share My Personal Data?
We will share your personal data with:
- if necessary the Department for Work and Pensions will profile your data in order to provide a YES/NO response via the Energy Saving Trust1 to verify whether or not you receive the relevant benefits to be eligible for the scheme;
- The Office of Gas and Electricity Markets (Ofgem)2 will:
- use and share your information in order to fulfil its statutory duties; if requested, share your information with the installer of the measure in order to verify whether it has been notified to Ofgem;
- if necessary, share your information with auditors contracted to ensure the integrity of the scheme.
- when required, disclose your personal information to the Secretary of State of the Department of Business, Energy and Industrial Strategy. They may use some of the data for research and statistical purposes and may, for these purposes, link the data with other data sources they hold.
- The obligated energy supplier3 (who will make a contribution towards the cost of the measure; and will process data as necessary to comply with a legal obligation4 and in accordance with their own privacy policies);
- Relevant companies supporting the installation:
- the installer (who installs the measure);
- the installer’s certification body (who monitor a sample of installations to ensure they meet the correct standards);
11) How Can I Control My Personal Data?
- In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12) Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13) How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for measuring web traffic, length of time users spend on Our Site. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law. Before Cookies are placed on your computer or device, you will be shown a popup requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.The following first-party Cookies may be placed on your computer or device:
|cookie_notice_accepted||Cookie to store user consent for cookies||Yes|
|viewed_cookie_policy||Cookie to say if cookie consent viewed||Yes|
|wordpress-test_cookie||Used by WordPress to check cookies functioning||Yes|
|__cfduid||Used by Zopim Chat service to provide help desk support||Yes|
|__cfduid||Used by True Quote service (freegeoip.net)||Yes|
|tq_cookies||Used by True Quote service to display focused deals based on customer property specification||Yes|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15) How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:For the attention of Fiona Lindley:
Email address: firstname.lastname@example.org
Postal Address: SM4U Ltd, 1 Heather Court, Shaw Wood Business Park, Shaw Wood Way, Doncaster, DN2 5YL.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.