PRIVACY POLICY

Your information will be held by Wainstones Estates Limited.  We are committed to protecting and respecting your privacy.  This privacy policy describes your rights under the UK General Data Protection Regulation 2016/679 and the Data Protection Act 2018 (together the "Data Protection Laws"), and how we will use and protect your personal data.

The current version of this privacy policy is available on request at accounts@carltonpower.co.uk. We will update this from time to time and will contact you (by email or letter) to notify you of any updates in relation to where:

·       we are doing something with your personal data, which you might not expect based on the information provided in this privacy policy; or

·       we are making substantial changes to the privacy policy.

In this privacy policy, the terms "we", "our", "us" are used to refer to Wainstones Estates Limited.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

WHAT we mean by "PERSONAL DATA"

Personal data is information that can permit someone to identify you either directly through your name, or indirectly through your address, card payment details or email address.

Information we may collect from you

In order to provide you with the services, we need to collect and use your personal data. We will collect and process the following information about you:

Information you give us.  This is information about you that you give us when you register and then use the services, or by corresponding with us by phone, e-mail or otherwise or information requested by us that you provide for the verification of your identity.  The information you give us may include your name, address, e-mail address, phone number, correspondence that you send to or receive from us, and financial and credit card information.

HOW WE USE YOUR information

Your privacy is protected by the Data Protection Laws.  We are allowed to use your personal data only if we have a proper reason to do so. We use information held about you in the following ways:

·                   Information you give to us. We will use this information:

o          to provide you with the services;

o          to perform account administration (including debt collection);

o          to perform risk assessments;

o          to conduct research and to analyse your supply account history;

o          to carry out our obligations arising from any agreements entered into between you and us and to provide you with information, products and services that you request from us;

o          to provide you with marketing information about other services or products we offer that are similar to those that you have already enquired about; and/or

o          to notify you about changes to our services and/or products.

Please note we will not use any financial or credit card information for any purpose other than to process payments made in connection with the provision of the services.

·                   Information we receive from other sources. We will combine this information with information you give to us and information we collect about you.  We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS

The Data Protection Laws require that we meet certain conditions before we are allowed to use your personal data in the manner described in this privacy policy.  To use your personal data, we will rely on the following conditions, depending on the activities we are carrying out:

·                   Fulfilment of our contractual obligations: In order to effectively provide you with the services, we are required to use your personal data. If you choose not to give us this personal data, we will not be able to provide you with the services.

·                   Consent:  We may provide you with marketing information about our services or products where you have provided your explicit consent for us to do so. 

·                   Legitimate interests:  To use your personal data for any other purpose described in this privacy policy, we will rely on a condition known as "legitimate interests".  A legitimate interest is when we have a business or commercial reason to use your information (for example, to enhance our services or to carry out direct marketing).  However, this legitimate interest must not unfairly go against what is right for you. We will therefore ensure that any collection and processing of your personal data:

·                   is not overly intrusive to you;

·                   is proportionate in order to meet our legitimate interests; and

·                   will always be kept to a minimum.

HOW LONG WE KEEP YOUR INFORMATION FOR

When your personal data is no longer required for the purposes listed above, we will delete it within six years of termination of your relationship with us.

Disclosure of your information

In order to provide the services to you, we may share your personal data with:

·                   authorised agents and service providers if this is necessary to allow us to provide the services; and

·                   members of our group and third party suppliers for the purposes listed under HOW WE USE YOUR INFORMATION above.

We will disclose your personal data to third parties:

·                   in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

·                   if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

·                   in order to enforce or apply the agreement under which we supply the services to you;

·                   to protect the rights, property, or safety of us, our customers, or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and

·                   if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

Where we store your personal data

The data that we collect from you will occasionally be transferred to, and stored at, a destination outside the UK or the European Economic Area ("EEA").  If we do transfer your personal data, we shall ensure that appropriate safeguards are put in place, such as a contract with the recipient that means it must protect it to the same standards as the UK and EEA.  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.  This includes staff engaged in, among other things, the processing of your payment details and the provision of support services.  We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers.  Unfortunately, the transmission of information via the internet is not completely secure.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have a number of rights under the Data Protection Laws in relation to the way we use your personal data.  These are set out below.  You may contact us at accounts@carltonpower.co.uk to exercise any of these rights. We will respond to any request received from you within one month from the date of the request.

DESCRIPTION OF RIGHT

Right of access: A right to access personal data held by us about you.

Right of rectification: A right to require us to rectify any inaccurate personal data held by us about you.

Right of erasure: A right to require us to erase personal data held by us about you. 

Right of restriction: A right to restrict our processing of personal data held by us about you. 

Right of data portability: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format.

Right to object: A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you and for the purposes of profiling).

Right to withdraw consent: A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request made by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office.  Find out on their website how to report a concern at ico.org.uk/concerns.

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CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and place any updates on this web page. This privacy policy was last updated in November 2021.

HOW TO CONTACT US

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to accounts@carltonpower.co.uk.