Privacy policy

Voltaware Services Ltd (“we” or “us”) are committed to protecting and respecting your privacy. We are keeping the privacy of your data in mind at all times. Your privacy is paramount to us and how we sell our sensor. We believe that your data belongs to you, and this is why we have anonymised and/or aggregated it so that your information is not personally identifiable.

This policy together with our Terms and Conditions https://www.voltaware.com/terms-and-conditions and Consumer Standard Terms https://www.voltaware.com/consumer-standard-terms and any other conditions where these terms are referred to and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. “Personal Data” means any information that identifies or makes identifiable a natural (living) individual.

Voltaware Services Ltd, a company registered in England and Wales under company number 09844696, at 1st Floor, 282 Earls Court Road, London, SW5 9AS, UK, is the data controller and is responsible for, and controls, the processing of your personal data in accordance with the General Data Protection Regulation 2016/679 (“GDPR”) and the Data Protection Act 2018 (“Act”).

We as the data controller, can be contacted via our Data Protection Officer Rishabh Jaipuria on the below contact details:

Name: Rishabh Jaipuria (Data Protection Officer)

Email: rishabh@voltaware.com

Address: Voltaware Services Limited, 1st Floor, 282 Earls Court Road, London, SW5 9AS

Information we may collect about you

We may collect and process the following data about you:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, property size, number of people living, number of bedrooms, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, records of any communications between us (including a record of phone conversations between you and our teams).
Energy Data includes information about your energy usage (overall energy usage, performance of appliances, breakdown by appliance etc)

We also collect, use and share Aggregated Data derived from your Energy Data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How we collect your information/data

We collect this information when you complete forms on our site www.voltaware.com, register to use our site, subscribe to our service, post material or request further services, report a problem with our site, and complete surveys that we use for research purposes, although you do not have to respond to these.

We may also ask you for information or obtain this from third parties when you enter a competition or promotion sponsored by Voltaware Services Ltd.

Energy data such as required to provide end users with information via the Volta service, is collected from a sensor installed in your property.

When you visit our website we collect and monitor some basic information such as your IP address and internet service provider’s domain name, which pages you access and when, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access. Such data and information, to the extent that you are individually identifiable from it, shall constitute personal data as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

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 (for example, to provide you with services or goods). In this case, we may have to cancel a service or product you have with us but we will notify you if this is the case at the time.

How we collect your personal data

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

Direct interactions. You may give us your Identity, Contact, Address, Financial and Energy Data by filling in forms or by corresponding with us by post, phone, email, app or otherwise.
Website and App interactions. As you interact with our website and app, we may automatically collect Technical, Energy, Contact and Identity Data. Sometimes we collect this personal data using cookies (please see our website terms and conditions and the section on cookies further below for more information).
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Payments Europe Limited based outside the EU.

When you visit our website we collect and monitor some basic information (such as your IP address and internet service provider’s domain name, which pages you access and when, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access. Such data and information, to the extent that you are individually identifiable from it, shall constitute personal data as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

In some cases, personal data may be collected directly from a third-party. For example, the electrician you use for the installation of the sensor may require certain personal data from you (such as your Wi-Fi code) to install the sensor. You will need to make yourself familiar with their privacy policy, as Voltaware will not be a party to this data collection and use.

Uses made of the information

In accordance with the GDPR/Act, we may only process your personal data if we have a legal basis (i.e. a legally permitted reason) for doing so. Most commonly, we will use your personal data in the following circumstances:

(1) Where we need to perform the contract we are about to enter into or have entered into with you.

(2) 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.

(3) Where we need to comply with a legal obligation

For the purpose of this policy, our legal basis for processing your personal data is set out in the table below. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Type of data we collect	Why we process your personal data	The legal basis for doing this is...
Identity, Contact, Technical	To identify you when you use our site and to ensure that the content from our site is presented in the most effective manner for you and for your computer.	This is necessary for the legitimate interests we pursue in keeping our site up to date and competitive, subject to you raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
Identity, Contact	To respond to and maintain a record of any queries you raise or contact you make with us.	This is necessary for the legitimate interests we pursue in responding you your queries and utilising your comments to keep our business competitive, subject to you raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
Identity, Contact, Profile Technical, Usage, Financial, Energy Data	To register you as a new customer. To carry out our obligations arising from any contracts entered into between you and us.	This is necessary for the performance of the contract between us and your personal data is processed to enable us to provide our services to you.
Identity, Contact, Profile, Usage, Energy Data	To monitor your energy usage and allow you to participate in interactive features of our service. Further, to notify you about changes to our service.	This is necessary for the performance of the contract between us and your personal data is processed to enable us to provide our services to you.
Identity, Contact, Technical, Usage, Financial	To advance or defend a claim, including a claim against us, to seek any payment due etc.	This is necessary for the legitimate interests we pursue in advancing or defending any claims relating to our services and seeking payment for these, subject to you raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
Identity, Contact, Technical, Energy Data, Profile, Usage, Marketing and communications	To research how energy is being used across the world by various user groups	This is necessary for the legitimate interests we pursue in keeping our business current and identifying market opportunities, subject to you raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
Identity, Contact and Energy Data	To contact you for marketing purposes, including to provide you with information about products or services that you request from us or which we feel may interest you.	This processing is necessary for the legitimate interest we pursue in marketing other products and services to you, subject to you raising an objection, requiring us to check that our interest is not overridden by any risk to your rights. (see the marketing sections below for further details)
Identity, Contact, Financial, Technical	To enable us to comply with any legal or regulatory requirements, including credit reference searches, anti-money laundering searches, fraud detection etc	This processing is necessary to comply with our relevant legal obligations.

It is important that we keep your personal data accurate and up to date and so we ask you to provide accurate information and inform us of any changes.

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please 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 information

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may also disclose your personal data to third parties, including:

Service providers, acting as processors who provide IT and system administration services.
Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.
Any subcontractor, supplier, installer, we might have dealings with under the umbrella of providing our products and services or the performance of any contract with have with them.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
To any third-party that we are under a duty to disclose or share your personal data with, in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions www.voltaware.com/terms-and-conditions and other agreements; or to protect the rights, property, or safety of Voltaware Services Ltd, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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 personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

How long we will retain your data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will review the maintenance of your personal data on an annual basis with a view to safely deleting the relevant information. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ’Your Rights’ below for further information.

Where we have anonymised your personal data (so that it can no longer be associated with you) for our electricity usage trend and statistical purposes, we may use this information indefinitely without further notice to you.

In certain circumstance we may be required to retain your personal data for longer. For example, if required we will be entitled to hold your personal data for longer periods in order to comply with our legal or regulatory obligations.

Automated decision making and profiling

Profiling is the automated processing of personal data to evaluate and/or predict aspects about a person’s behaviour. We will monitor your energy usage in order to provide our services to you such as overall energy consumption, usage and health check of appliances, and recommendations for energy saving.

Automated decision making is where we make a decision based solely on automated means. We will use the information obtained from monitoring and profiling your energy use to decide what products or services may be of interest to you. For example, where we detect that your dishwasher is not as energy efficient as it could be we will inform you of this and suggest alternatives.

This decision making will not have a significant or legal effect on you. But we will carry out regular checks to ensure that our software is working as intended.

Keeping your personal data secure

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We have put in place appropriate security measures to prevent your personal data for 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, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

While we will use all reasonable efforts to safeguard your personal data, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Overseas transfers

The data that we collect from you may be transferred to, and stored by a third party service provide, and/or at a destination outside the European Economic Area (“EEA”).

It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Marketing

We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you.

For the purposes of the GDPR and Act we have a legitimate interest in processing your personal data (name and contact details) for marketing communications.

For marketing communications that are business to business we do not require your permission, in line with current regulations.

If you are an individual, then in accordance with the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by contacting us.

Further, with your permission, we may share your details with carefully selected third parties and they may contact you directly (unless you ask them not to) by telephone, email or post about products, services, promotions and special offers that may be of interest to you.

You have the right at any time to ask us, or any third party, to stop processing your information for direct marketing purposes. If you wish to exercise this right please follow the unsubscribe link on the communications or contact us on the below details, or the relevant third party, giving us or them enough information to identify you and process your request.

Cookies

Like most websites, our site uses cookies in order to help provide you with the best experience we can. Cookies are small text files that are placed on your computer, mobile phone or other device when you browse websites.

Our cookies help us:

Make our website work as you’d expect
Save you having to login every time you visit the site
Remember your settings during and between visits
Improve the speed/security of the site
Continuously improve our website for you
Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)

We do not use cookies to:

Collect any personally identifiable information (without your permission)
Collect any sensitive information (without your permission)
Pass data to advertising networks
Pay sales commissions
You can learn more about all the cookies we use below

Granting us permission to use cookies

If the settings on your software that you are using to view this website (your browser) are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below, however doing so will likely mean that our site will not work as you would expect.

More about our Cookies

We use cookies to make our website work including: Determining if you are logged in or not
There is no way to prevent these cookies being set other than to not use our site

Anonymous Visitor Statistics Cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows which helps to identify when our site isn’t working as it should for particular technologies), how long they spend on the site, what page they look at etc. This helps us to continuously improve our website. These so-called analytics programs also tell us if, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before helping us to put more money into developing our services for you instead of marketing spend.

We use Google Analytics.

Turning Cookies Off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites.

It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

Your rights

This section sets out the legal rights of individuals in respect of the personal data we are holding and/or processing. If you wish to exercise any of your legal rights please contact us (using our contact details below). You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the 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), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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 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:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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 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. We will advise you if this is the case at the time you withdraw your consent.

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 could 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 any 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 could 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.

Links to other sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

Complaints

If you have any concerns about how we collect or process your personal data then you can complain to enquiries@voltaware.com in the first instance.

You also have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to 1st Floor, 282 Earls Court Road, London, SW5 9AS, UK or enquiries@voltaware.com.