Privacy Policy – SAS ENERGY

 

Introduction

Welcome to SAS ENERGY’s privacy notice

SAS ENERGY respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data.

  • IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Notice

This privacy notice aims to give you information on how SAS ENERGY collects and processes your personal data.

Our services are not intended for children and we do not knowingly collect data relating to children.

This privacy notice replaces past privacy notices and can be updated at any time, with a new updated policy published on this website.

Controller

SAS ENERGY is the controller and responsible for your personal data and this website

This privacy notice is issued on behalf SAS ENERGY so when we mention ‘we’ ‘us’ or ‘our’ in this privacy notice we are referring to SAS ENERGY, who is responsible for processing your data.

We have appointed a Data Protection Officer who is responsible for overseeing questions relating to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Data Protection Officer

Full name of legal entity: Solar Advanced Systems Ltd trading as SAS ENERGY

Name: Nicholas Porter, Managing Director and Data Protection Officer

Email address: SASENERGYGDPR@sas-energy.co.uk

Postal Address: Unit 9, Edenbridge Trading Estate, Hever Road, Edenbridge, Kent, TN8 5EA.

Telephone Number: 01732 866731

You have the right to make a compliant at any time to the Information Commissioners Office (ICO), The UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

This version was last updated in May 2018, and the historic hard copy version could be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links

This website may include links to third party websites, plug ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  • THE DATA WE COLLECT ABOUT YOU

Personal data or 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)

We may collect, use or store and transfer different kinds of personal data about you which we have grouped together as follows:-

  1. Identity Data – includes first name, last name, username or similar identifier, title, marital status.
  2. Contact Data –includes billing address, delivery address, email address and telephone numbers
  3. Financial Data – includes bank account and payment card details
  4. Transaction Data – includes internet protocol (IP) address, your login data, browser type and version, time zone and location, browser plug in types and versions, operating system and platform and other technology on the devices you use to access this website.
  5. Profile Data – includes your use name and password, purchases and orders made by you, your interests, preferences, feedback and survey responses.
  6. Usage Data – Includes information about how you use our website, products and services
  7. Marketing and communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also may share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but it is not considered personal data in law as this does not directly or indirectly reveal your identity. For example we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

We do not collect Special Categories of Personal Data about you. This includes details about your race or ethnicity, 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 offenses.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you ( i.e. to provide you with goods or services). We may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  • HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions – you may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    • Apply for our products or services
    • Create an account with us
    • Subscribe to our services
    • Request marketing to be sent to you
    • Enter a competition, promotion or survey
    • send us your feedback
  • Automated technologies or interactions – as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy on our website for further details.
  • Third Parties or publically available sources. We may receive personal data about you from various third parties that include those below:
    • Analytics providers such as Google
    • Search information providers such as Google and other search engines
    • Financial or transactional data companies – Cambridge Mercantile Corp (UK), TransferWise Ltd and Firma Foreign Exchange Corporation (UK) Ltd
    • Bad debtors – Thomas Higgins Ltd.
    • Publications from industry events or information from websites
    • Companies House, Dun & Bradstreet,
    • Plus other publically available sources
  • HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:-

  • Where we need to perform a contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data but you have the right to withdraw consent to us contacting you about specific topics at any time. Please send us an email to optout@sas-energy.co.uk.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

  • To register you as a new customer
  • Types of data – Identity and Contact
  • Lawful Basis = performance of a contract with you
  • To process and deliver your contract:-

This includes managing payments, fees and charges and collecting and recovering money owed.

  • Types of data – Identity and Contact
  • Lawful Basis = performance of a contract with you and necessary for our legitimate interests
  • To manage our relationship with you

Notifying you about changes to our terms or privacy policy or asking you to leave a review or take a survey

  • Types of data – Identity, Contact, Profile and Marketing and Communication
  • Lawful Basis = performance of a contract with you, necessary to comply with a legal obligation or necessary for our legitimate interests to keep records updated and to know how customers use and view our products and services
  • To administer and protect our business and website

By troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

  • Types of data – Identity, Contact and Technical
  • Lawful Basis = necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
  • To deliver relevant website content and marketing communication

We wish to deliver relevant information and to measure or understand the effectiveness of these communications.

  • Types of data – Identity, Contact, Profile, Usage, Marketing Communications, and Technical
  • Lawful Basis = necessary for our legitimate interests to study how customers use our products/services, to develop them, grow our business and to inform our marketing.
  • To use data analytics to improve

We wish to improve our website, product/services, customer relationships and experiences.

  • Types of data –Technical and Usage
  • Lawful Basis = necessary for our legitimate interests to offer customers different products and services, to keep our website updated and relevant and to develop our business and its marketing
  •  To make suggestions and recommendations that may be of interest
    • Types of data –Identity, Contact, Technical, Profile and Usage
    • Lawful Basis = necessary for our legitimate interests to develop our products and services and grow our business.

MARKETING 

    • We may use your Identity, Contact, Technical, Profile and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
    • You can ask us to stop sending you marketing messages by certain mediums (email, text or postal) at any time, by logging into the SAS ENERGY website’s CONTACT US page, clicking on the opt out email address and filling in your details, stating whether you wish to state a medium preference to receive marketing communications or to opt out of all messages. You can also opt out by clicking on the link in the email signature of any SAS ENERGY email. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
  • OPTING OUT
    • You will receive marketing communications from us if you have requested information or purchased goods or services from us; or if you work for a company or organisation that could benefit from our services. In each case you have not opted out of receiving that marketing.

COOKIES

  • You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse all or some browser cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please contact us.

CHANGE OF PURPOSE

  •  We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to know more then do contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  • DISCLOSURE OF YOUR PERSONAL DATA

We may have to share your personal data with parties such as:- ‘the Cloud’, our local printers to print and personalise address labels and letters, and professional bodies e.g.International Standard Organisation (I.S.O.) and Contractors Health & Safety Assessment Scheme (C.H.A.S). We may have to share your data with third parties to whom we may choose to sell, transfer or merge parts of our business or assets with. Alternatively we may seek to acquire or merge with other businesses. If a change happens with our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

  • INTERNATIONAL TRANSFERS

We will not transfer your personal data outside the European Economic Area.

  • DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents and third parties who have a business need to know. They are all subject to a duty of confidentiality.

  • DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data – see Request Erasure below.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  • YOUR LEGAL RIGHTS

You have a right to:

Request Access – known as a data subject access request (DSAR or SAR). This enables you to receive a copy of your personal data we hold about you and to check that we are lawfully processing it.

Request correction – of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure – of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below). Note we may not always be able to comply with your request of erasure for specific legal reasons, which will be stated, if applicable, at the time of your request.

Object to processing – of your personal data where we are relying on legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which would override your rights and freedoms.

Request restriction of processing – of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer – of your personal data to you or to a third party. We will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time – where we are relying on consent to process your personal data. However this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

If you wish to exercise any of the rights set out above, please contact us on the email address: SASENERGYGDPR@sas-energy.co.uk

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

  • LAWFUL BASIS
  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you ( both positive and negative) and your rights before we process your personal data for our legitimate interest. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted by law.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with legal or regulatory obligation that we are subject to.

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