1. Introduction
Degluwhitt ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our services, visit our website, or interact with us.
We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number Z1234567. Our registered office is at 123 Energy Street, London EC2V 8AB, United Kingdom.
2. Information We Collect
2.1 Personal Information
We collect the following types of personal information:
- Identity Data: Name, date of birth, gender
- Contact Data: Address, email address, telephone numbers
- Financial Data: Bank account details, payment card information, credit score data
- Account Data: Account numbers, meter readings, energy usage data
- Technical Data: IP address, login data, browser type, device information
- Usage Data: How you use our website and services
- Marketing Data: Your preferences for receiving marketing communications
2.2 Special Categories of Data
We may collect special categories of personal data in limited circumstances, such as:
- Health information if you require priority services due to medical needs
- Information about vulnerabilities if you need additional support
3. How We Collect Your Information
We collect information through various methods:
- Direct interactions: When you apply for services, contact us, or fill out forms
- Automated technologies: Through cookies and similar technologies on our website
- Third parties: From credit reference agencies, energy industry databases, and marketing partners
- Public sources: From publicly available sources such as the electoral register
4. How We Use Your Information
We use your personal information for the following purposes:
4.1 Service Provision
- To provide electricity and gas supply services
- To manage your account and process payments
- To read meters and calculate bills
- To provide customer support
4.2 Legal and Regulatory Compliance
- To comply with energy industry regulations
- To meet our obligations under consumer protection laws
- To respond to regulatory inquiries
- To prevent fraud and money laundering
4.3 Business Operations
- To improve our services and develop new products
- To conduct market research and analysis
- To manage our business operations efficiently
4.4 Marketing and Communications
- To send you marketing communications (with your consent)
- To provide information about our services
- To conduct customer satisfaction surveys
5. Legal Basis for Processing
We process your personal data under the following legal bases:
- Contract: To perform our contract with you or take steps at your request
- Legal obligation: To comply with legal or regulatory requirements
- Legitimate interests: For our business operations, fraud prevention, and service improvement
- Consent: For marketing communications and non-essential cookies
- Vital interests: To protect health and safety in emergency situations
6. Data Sharing and Disclosure
We may share your personal information with:
6.1 Service Providers
- IT service providers and cloud hosting companies
- Payment processing companies
- Customer service providers
- Marketing agencies
6.2 Industry Partners
- Energy network operators
- Energy market operators
- Other energy suppliers (for switching purposes)
- Meter reading companies
6.3 Regulatory Bodies
- Ofgem (Office of Gas and Electricity Markets)
- Energy Ombudsman
- Citizens Advice
- Government departments
6.4 Credit Reference Agencies
- For credit checking and debt recovery
- To prevent fraud
- To verify your identity
7. Data Retention
We retain your personal data for different periods depending on the type of information and purpose:
- Account data: 6 years after account closure (regulatory requirement)
- Financial data: 7 years for tax purposes
- Marketing data: Until you withdraw consent or 3 years of inactivity
- Technical data: Up to 2 years for website analytics
- CCTV footage: 30 days unless required for investigation
8. Your Rights
Under UK GDPR, you have the following rights:
- Right of access: Request copies of your personal data
- Right to rectification: Request correction of inaccurate data
- Right to erasure: Request deletion of your data
- Right to restrict processing: Request limitation of data processing
- Right to data portability: Receive your data in a portable format
- Right to object: Object to processing based on legitimate interests
- Rights related to automated decision-making: Not to be subject to automated decisions
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
- Encryption of data in transit and at rest
- Regular security assessments and penetration testing
- Access controls and authentication systems
- Staff training on data protection
- Incident response procedures
- Regular backups and disaster recovery plans
10. International Transfers
We may transfer your personal data outside the UK in limited circumstances. When we do so, we ensure appropriate safeguards are in place, such as:
- Adequacy decisions by the UK government
- Standard contractual clauses approved by the ICO
- Binding corporate rules
- Certification schemes
11. Cookies and Website Analytics
Our website uses cookies and similar technologies. We categorize cookies as:
- Strictly necessary: Essential for website functionality
- Performance: Help us understand how visitors use our site
- Functional: Remember your preferences and settings
- Marketing: Used to deliver relevant advertisements
You can manage your cookie preferences through our cookie banner or browser settings. For more information, see our Cookie Policy.
12. Children's Privacy
Our services are not directed at children under 16. We do not knowingly collect personal information from children under 16 without parental consent. If you are under 16, please ask your parent or guardian before providing any personal information.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by:
- Posting the updated policy on our website
- Sending you an email notification
- Including a notice in your bill
14. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:
Information Commissioner's Office
You also have the right to lodge a complaint with the Information Commissioner's Office:
Website: ico.org.uk
Phone: 0303 123 1113
Post: Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF