Data Protection and Privacy Policy

Data Protection and Privacy Policy

WE RESPECT YOUR PRIVACY

At SolarSmart Energy Limited, we’re committed to ensuring that your privacy is respected and protected. This privacy notice applies to SolarSmart Energy Limited (SolarSmart), a company registered in Ireland with company number 681720, the data controller. By “you” or “your” we mean any individual, sole trader and/or partnership that receives services from us, uses our website or otherwise interacts with SolarSmart.

In the course of its role as data controller, SolarSmart engages a number of Data Processors to process personal data on its behalf. These data processors include: Constant Contact (marketing campaigns and CRM), OpenSolar (solar modelling software), SunBase (business management software) and Microsoft (Email).

When we refer to “third parties” or “Data Processors” we mean any of those Data Processors listed above as well as any newly contracted third parties in line with this policy.

Please read this notice carefully as it provides important information about how we handle your personal information and the steps you can take to control it. If you have any questions, comments or concerns about any aspect of this notice, please contact us using the details set out in section 11. This privacy notice is divided into the following sections:

1. What information do we collect and how do we do it?
2. How do we use your personal information?
3. How do we use your sensitive personal information?
4. What information do we receive from third party sources?
5. Legal bases for processing
6. Who do we share your personal data with?
7. How is your personal information transferred outside of the EEA?
8. How long do we hold your personal information?
9. How will we change this privacy notice?
10. What choices and rights do you have in relation to your personal information?
11. How can you contact

 

What information do we collect and how do we do it?

We, or third parties on our behalf, collect your personal information when you use our website, communicate with us by phone, letter, email, social media or in person, receive our products and/or services, or request to join schemes which you are eligible for. We may collect the following personal information and we refer to this as “personal information” throughout this notice:

• your first name and surname;
• your billing address;
• electricity supply address;
• telephone numbers;
• email addresses;
• energy usage (e.g. meter readings and units of gas and electricity used over a period or general fuel use);
• financial information (e.g. bank account details);
• permissions (e.g. we will record if you have consented to marketing);
• survey responses;
• information about any energy supplier accounts, including your Meter Point Reference Number (MPRN), including the name of the supplier
• details necessary for an SEAI Grant in ROI;
• if you visit our website, we store your IP address, the browser software you use and your behaviour on our website (for example, the pages that you click on). This information is collected through cookies. More information about how we use cookies can be found in our cookie policy on our website;
• if you engage with us through social media, we collect your name and store a link to your relevant social media profile, which we combine with details of your previous correspondence with us;
• if we carry out a site visit, we may collect personal information about you or a member of your household from that visit. E.g. we may record information that has been supplied to us and obtained fairly about you or a member of your household;
• if you proceed with a site survey for services with us, we create and record customer ID numbers for you and record the date of your initial interest as well as proceeding correspondence. We need this personal information so we can provide services and/ or products to you. If you don’t provide us with that personal information, you may not be able to access certain products and/or services.

 

How do we use your personal information?

We, or third parties on our behalf, collect, use and store the personal information collected about you to:

(a) Provide, or obtain on your behalf, relevant products and/or services, benefits, and rewards;

(b) Respond to any enquiries or issues you have;

(c) Identify you;

(d) Detect and prevent crime, fraud or loss;

(e) Contact you, or authorised third parties, about our services and/or products, such as sending you information on service announcements and administrative messages;

(f) Train our staff and improve our products and services, which may mean that we monitor and record communications that we have with you including phone conversations, emails, SMSs and web or video chats;

(g) Conduct, and contact you in relation to, market research e.g. through customer satisfaction surveys and questionnaires;

(h) Obtain government funding for the supply of energy efficiency measures to individuals;

(i) Identify offers and advice tailored to your needs or lifestyle;

(j) Ensure the health and safety of you, our staff and contractors;

(k) Use information collected from your visit to our website for administrative purposes; for troubleshooting, data analysis, testing, research and statistical and survey purposes; to ensure content is presented in an effective manner; and to enable you to participate in interactive features;

(l) Respond to or resolve any enquiries or requests that you may have from social media;

(m) Enable internal corporate reporting, business administration, adequate insurance coverage, the security of company facilities, research and development, and to identify and implement business efficiencies;

(n) Comply with any procedures, laws and regulations which apply to us – including where we reasonably consider it is in our (or others) legitimate interests to comply; and

(o) Establish, exercise or defend our legal rights – including where we reasonably consider it is in our (or others) legitimate interests.

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Marketing Communications
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With your consent, we may contact you in writing, by phone and via email or SMS with information on products, services and rewards that we offer.

We may use third parties to send marketing communications. Unless you have asked us not to, we may also use your email address to show you digital advertisements via your social media newsfeed, on search engine results pages, or on other websites. Unless you have asked us not to, we may profile your data to provide you with marketing and offers that are relevant to you. If you opt out of profiling we will still run analysis that includes your data, but any decisions or marketing output that result from that analysis will not be used to market to you. You will be sent generic marketing that may not be relevant to you. To opt out of receiving marketing messages, or to object to our use of profiling for direct marketing purposes, contact us at any time using the details in section 11.

 

How do we use your sensitive personal information

We treat the information that we collect about your (or a member of your household’s) requirements for your welfare (e.g. due to age, health, disability or financial circumstances) as being particularly sensitive. We will use this information in the following ways:

(a) provide products and/or services to you in the most appropriate way;

(b) manage staff and third party contractors.

With your consent, we may also share this information with other relevant organisations, such as emergency responders or local authorities, which may be able to provide support.

 

What information do we receive from third party sources?

We also receive your personal information from the following third party sources:

(a) Third party introducers (such as price comparison websites) to set up an account for you and to provide the products and/or services that you have requested;

(b) data providers – we collect information from third party data providers, including aggregated geodemographic and lifestyle data, and combine this with account information to conduct statistical analysis. These customer insights help us to plan our marketing activities and conduct market research and business development;

(c) Councils, local authorities or housing associations – we may receive your name, address and contact details where they would like carbon-saving measures applied to your property under relevant government funding schemes;

(d) Letting agents, landlords, cohabitants or previous tenants – if you have recently moved into a property that we supply energy to

(e) Law enforcement agencies (such as An Garda Síochana) to identify and prevent fraud or crime.

 

Legal Bases for Processing

We’ve assessed that the legal bases for using your personal information as set out in this notice are as follows:

(a) Contract – our use of your personal information is necessary to perform our obligations under any contract we have with you; or

(b) Legal Obligations – our use of your personal information is necessary for complying with our legal obligations; or

(c) Our Legitimate Interests – to: (i) Run, grow and develop our business; (ii) Detect and prevent fraud; (iii) Enhance the security of our network and information systems; (iv) Ensure that our own processes, procedures and systems are as efficient as possible; (v) Better understand how people interact with our website; (vi) Analyse and enhance the information that we collect; (vii) Determine the effectiveness of our promotional campaigns and advertising; and (viii) Enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers. If you have concerns about the processing activities based on our legitimate interests, please see section 11.

Consent – We rely on your consent to use your personal information to send you marketing information by post, phone, mobile phone, email or SMS. If you later change your mind, you may withdraw your consent by contacting us using the details in section 11 and we will stop using your information in this way.

 

Who do we share your personal information with?

We will share your personal information with the following categories of third parties:
(a) our third-party suppliers, partners and sub-contractors that provide, review and/or receive services in relation to our website, services and/or products, which include: payment processors; suppliers of technical, support and installation services; insurers; logistics providers; security providers; cloud services providers; research agencies; and if you are entitled to claim government funding for energy efficiency measures, installers, energy performance assessors and sales advisers.
(b) where appropriate, family members or cohabitants, previous tenants, who/which may require information about you or your premises, or who introduced you to SolarSmart;
(d) if we’re under a duty to disclose your information to comply with any legal obligation, government or law enforcement officials as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(e) regulators or other legally appointed bodies (such as CRU/UR) for legal or regulatory purposes, e.g. if requested we may send your information to CRU to prove that you qualify for relevant government funded schemes;
(f) companies or partner organisations which provide services in relation to, or use information as part of, market research;
(g) third parties that help us with advertising and marketing. For example, we share limited personal information with the following third parties who serve advertising on their platforms on our behalf or on our behalf on external platforms: Facebook, LinkedIn and Google Adwords.
(h) authorised third parties or named account holders on any account you hold with us;
(i) if we sell, merge, or perform any internal re-organisations in relation to any of our (or any third party’s) business or assets, the personal information will be one of the transferred assets to the relevant buyer and/or new data controller of such business or assets;
(j) any third party where required to:
(i) enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; and
(ii) protect the rights, property or safety of SolarSmart, our staff, customers or others.
(k) credit reference agencies
(l) fraud prevention agencies
(i) To help us identify fraud and energy theft, we will give details of your account to fraud prevention agencies who will use the information to check public and other databases they hold and may provide information to us to help identify fraud and energy theft.
(ii) If we suspect or can confirm theft has occurred, a record will be kept by fraud prevention agencies which may include sensitive information about alleged criminal offences. The fraud prevention agencies may provide the information to other energy companies to help identify fraud and detect energy theft but only in limited circumstances where you have accounts with them. Where theft has been identified, your account terms may change, but we will notify you separately if this is the case.

 

How is your personal information transferred outside of the EEA?

We, or a third party who we share personal information with, may host, store and handle that personal information outside of the European Economic Area (EEA).

?We will only permit this to happen if adequate safeguards have been put in place to protect your personal information. This means that we will: (a) ensure that the country in which your personal information will be handled has been deemed “adequate” by the European Commission under Article 45 of the General Data Protection Regulation (GDPR); (b) include standard data protection clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the GDPR); or (c) (in the case of transfers from the EEA to the USA), ensure that the recipient of the personal information has certified with the US-EU Privacy Shield Framework, as permitted by Article 46.2 of the GPDR.

 

How long do we hold your personal information?

We keep your personal information for no longer than is necessary of the purposes for which the personal information is processed. The length of time we retain it for depends on the purposes for which we use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

?This means that some of your personal information will be kept for a short time e.g. we may keep copies of correspondence. Other information may be kept for a longer period, e.g. we keep your contact details for a period of up to five years when you do not fully proceed with solar (but for a shorter period if that is possible).

 

How will we change this privacy notice?

We may update our privacy notice from time to time. Any changes we make to our privacy notice in the future will be posted on the SolarSmart website and, where appropriate, notified to you by post or email.

 

What choices and rights do you have in relation to your personal information?

You may contact us using the contact details provided in section 11 to request that we: (a) confirm whether your personal information is being processed; (b) provide you with further details about how we process your personal information; (c) provide you with a copy of any personal information which we hold about you; (d) where we rely on your consent as a legal basis to justify using your personal information, withdraw your consent to that use; (e) consider any valid objection to the processing of your personal information (including the right to object to processing where we are relying on our legitimate interests as a legal basis for processing); (f) ask us to update or delete personal data which we hold about you; (g) restrict the way that we process your personal data; (h) provide you with a copy of your data in a machine-readable format. Where technically feasible and (i) where we carry out automated decision-making that has legal or similarly significant effects on you, ensure that we manually review that decision, provide an explanation of that decision and/or consider your appeal of that decision.

We will consider all those requests. However, certain personal information may be exempt from those requests in certain circumstances, which may include needing to keep processing your personal information for our legitimate interests or to comply with a legal obligation.

If an exemption applies, we will tell you this when responding to your request. We may ask you to provide us with information necessary to confirm your identity before responding.

 

How can you contact us?

If you would like to contact us in relation to your rights or if you are unhappy with how we’ve handled your information, you may contact us by sending a letter to: Data Protection Officer, SolarSmart Energy Limited, 20 Rock Lodge, Dublin A96A0K8 or sending an email to dpo@dev.mindmap.ie

If you would like to contact our Data Protection Officer, you may do so using the following details: Email: dpo@dev.mindmap.ie Phone: +353 085 875 2105 and request to speak to the Data Protection Officer or alternatively, send us a letter to: Data Protection Officer Data Protection Officer, SolarSmart Energy Limited, 20 Rock Lodge, Dublin A96A0K8

If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the relevant Data Protection Office: Data Protection Commissioner Dublin Office; 21 Fitzwilliam Square Dublin 2 D02 RD28 Data Protection Commissioner Portarlington Office Canal House, Station Road Portarlington, Co. Laois R32 AP23.

 

Updated November 2023