Privacy Policy

Introduction

We’re committed to giving you top-notch customer service, including taking your data and privacy seriously. We understand how important your personal information is, so we handle it with the utmost care. This page explains how and when we collect, use, and share the personal information you provide to us, or that others provide on your behalf. Please read this Privacy Policy carefully; if you have any questions, you can always contact our friendly customer service team at hello@dwellow.co.uk.

Information about us

The privacy policy applies to Dwellow Limited and it subsidiaries (or future subsidiaries), a limited company registered in England under company number 15114137. Registered address: Hermes House, Fire Fly Avenue, Swindon, Wiltshire, SN2 2GA.

We have appointed a data protection officer who can help you with any questions you may have in relation to this policy. They can be contacted at compliance@dwellow.co.uk.

Our website may contain links to other websites. We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any website you visit.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

In simpler terms, personal data is any information about you that enables you to be identified. It includes obvious information such as your name and contact details, but it also includes less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold - if you would like to discuss any of these rights please contact us at compliance@dwellow.co.uk:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us if you have any questions
2. The right to access the personal data we hold about you. Section 9 will tell you how to do this.
3. The right to rectify your personal data if any of your data held by us is inaccurate or incomplete.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to withdraw consent. If we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
8. The right to data portability. This means that if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means. In many cases, you can ask us for a copy of that personal data to re-use with another service or business.
9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
   

Your personal data must be kept accurate and up-to-date. If any personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to complain to the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first at compliance@dwellow.co.uk

How do we collect and use your data?

We only collect and process your data with a valid reason, and always within the boundaries of data protection law. This section explains how we gather and use your information. Depending on how you use our website and services, we may collect and use personal and non-personal data. Please keep your details updated so we can better serve you. If anything changes, please don't hesitate to let us know.

‍When you purchase products or services

‍When you buy products or services from us, we use your personal information to process your purchase. Depending on how you use our website and services, we may collect and use personal and non-personal data, such as address, phone number, MPAN/MPRN meter details, and payment information like credit or debit card details or direct debit arrangements. We need to handle your personal information in this way to set up and fulfil the contract for the product or service you’ve chosen. This might also involve sending you important account information and occasional updates about our services

‍When you contact us by phone, email, web chat or on social media

‍When you get in touch with us, we may need to process your personal information, such as your name, address, contact details, and any other information you share during our conversation. We rely on your consent to handle your information in this way. If you choose not to provide the data we request for customer service purposes, we might not be able to fully address your questions.We also record the conversations and interactions you have with us, such as recording phone calls, when you open an email from us and click on links to help us better serve you in future.

‍Marketing communications

‍With your consent, or if you purchase from us or interact with our services and don't opt out of receiving our emails (known as 'soft opt-in'), we’ll use your personal data, preferences, and details of your purchases and interactions to keep you updated. This could be through email, web, text, phone, or our contact centres. We’ll share information about relevant products and services, including special offers, discounts, promotions, events, competitions, and more—all tailored to you.Every marketing email we send will include easy instructions on how to unsubscribe, or you can contact us anytime at hello@dwellow.co.uk.We may also use legitimate interest as a basis to share information about our products and services through post, phone, targeted or generic adverts on our website or apps, or via services from other Dwellow group companies.

‍Advertising on third party platforms and websites

‍From time to time, we may deliver personalised advertising to you through third-party platforms and websites. When we do this, we'll hash your data (so it can't be read by anyone) and match it against the platform's database. This ensures you only see tailored information about our products and services that are relevant to you.

‍If you apply for any government grants or funding

‍If you apply for or enquire about government grants or funding from schemes such as the Boiler Upgrade Scheme or Home Energy Scotland (or schemes that replace them in the future), then we will collect information relevant to your application to these schemes, including your name, address, contact details and any eligible benefits your receive. We do this to support your application to these schemes.

‍Smart meters

‍If you choose to let us access data from your smart meter to better understand your energy usage, we’ll collect consumption and tariff information directly from the meter, based on the consent you give when you opt into this service.We might also analyse the data we gather from smart meters to help us develop new products and services tailored to your needs. We do this because we have a legitimate interest in creating innovative solutions for the energy-saving market.‍

To improve our website and apps

‍We use your personal information to enhance your experience, like showing you services we think you'll find interesting. By using your information this way, we can tailor our website and apps to better suit you, meaning the content you see might be different from what others see.We also share aggregated, anonymous data with third-party analytics and search engine providers who help us improve and optimise our website and apps. Additionally, we use your personal information to manage our website and apps, making them more secure through troubleshooting, data analysis, testing, research, statistical, and survey purposes. We do this because we have a legitimate interest in providing you with the best experience and ensuring our website and apps are secure. To do this we automatically collect technical data like your computer’s IP address, browser type, screen resolution and operating system. We also collect information about how you use our website for example which pages you visit, the length of time you spend on pages and how you interact with it (like scrolling, clicking and when you leave a page). We may also collect your location data when you access our website or app, based on the location settings you have set on your device.If you'd prefer us not to use your personal information this way, you can activate the “do not track” functionality in your internet browser. Just keep in mind that enabling this feature might make our website less tailored to your needs and preferences

‍To improve our products and services

‍We are always looking to improve the services we offer and sometimes process your data where we have a legitimate interest for doing so, for example

1. To better understand how customers respond to the content of our communications to make more engaging campaigns in the future
2. To predict how customer usage may change in the future which is especially important in support energy transition and decarbonisation of homes
3. To conduct data analysis, testing, research and surveys.

Information we receive from third parties

In addition to the information you provide us with directly, we also receive information from some third parties.

We work with affiliates and partners, such as lead generation sites, mortgage lenders, and price comparison websites, to help us identify consumers who may benefit from our products or services. These affiliates and partners may send us your personal information with your consent.

If you are introduced to us through a friends and family referral scheme, then we will receive your initial details through the form you complete. We will also tell the person whose link you used that you have done so.

When you make a payment for our products and services or apply for finance, we may receive information about the transaction, its status, and the method or methods used to complete the transaction. This information is used to enable us to provide you with the product and service purchased and for fraud detection purposes.

We also use datasets provided by both public agencies and commercial organisations, and we may receive information about your property (including its energy efficiency and construction type) and its smart meter.

Where we have a legal obligation

In some circumstances, we may need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation, to allow us to comply with regulators' requirements or our consumer code obligations, or to investigate something like theft or fraud.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s)for which it was first collected. 

As part of delivering services to you, we may be required to hold data for extended period. For example, if you participate in the Boiler Upgrade Scheme, we are required to hold your data for a minimum period of six years after your installation has been completed.

We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical analysis, such as looking at email open rates, or to improve our website and develop new products. In these cases, we may use this information indefinitely without your further notice.

Where do you store my personal data?

We are a UK-based business, but some of the third parties and agents we work with may be located outside the European Economic Area (EEA). This means that processing your personal information might involve transferring data outside the EEA.

Whenever we transfer your personal information outside the EEA, we make sure it’s protected by putting safeguards in place. This might involve only transferring your data to a country that the European Commission has deemed to provide an adequate level of protection, or using specific contractual protections. If you’d like more details on how we protect specific transfers of your data, you can reach us at compliance@dwellow.co.uk.

All the information you provide is stored securely, either on our servers or those of our third-party data storage providers. Protecting your personal data is a top priority for us, and we take several important measures to ensure its security, including:

(1) Limiting access to your personal data to employees, agents, contractors, and other third parties who have a legitimate need to know, and ensuring confidentiality obligations bind them

(2) Implementing procedures to handle data breaches (including the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your personal data), and notifying you and the relevant authorities when required by law

Do You Share My Personal Data?

Where we share your information with any third parties, we always do so in line with this privacy policy and in compliance with data protection laws. We also ensure that these third parties only use your data in line with our instructions. We do not sell your data to third parties.

Some of the organisations we may share your information with include:

• Other companies that are part of (or may be in the future) dwellow group, where necessary for the provision of our products and services
• Subcontractors we use to help us supply and install certain products and / or services. Where we utilise our network of installers and fitters to carry out work in your home, we will share some personal details to enable them to carry out said work (for example your name, address and contact details)
• Meter operators, where your opt in to using our smart meter services we may need to share information such as your meter number and address to connect with your meter
• Anyone who is named and authorised to support with the provision of the supply of our products and services (for example a family member)
• Our affiliates and partners, including white label partners and price comparison website, to the extent necessary to enable us to deliver our products and services to you
• Payment providers, to help us process your payments to us
• Finance providers, to enable you to apply for finance products
• Debt collectors where we have a legitimate interest to recover sums owed to us for our services.
• Network operators, to enable the safe connection of your new renewable products to the grid
• Grant and incentive administrators to support with the application for grants and incentives that may be available to you from time to time - for example mortgage lender cashback, the Boiler Upgrade Scheme
• Consumer code providers, to allow us to register your installation and for you to benefit from their services (for example insurance backed warranties and deposit protection)

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. We process your personal information in this way because we have a legitimate interest to ensure our business can be continued by the buyer.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation when you submit personal data via our website or app, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details.
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You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Mailing Preference Service (“the MPS”), and the Your Choice Preference Service (“the YCPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to compliance@dwellow.co.uk or the address at the top of this policy.

‍There is normally no charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 14 days and, in any case, not more than one month after receiving it. Usually, we aim to provide a complete response, including a copy of your data within that time. In some cases, however, mainly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do You Use Cookies?

You can read further detail about how we use cookies in our separate Cookie Policy.

Our website and app may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our website / app and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our website and apps, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us.

Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to place cookies, you are enabling us to provide you with the best possible experience and service. You may, if you wish, deny consent to the placing of Cookies; however, certain features of our website and apps may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

‍Certain features of our website and apps depend on Cookies to function - those identified as “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that our website and apps may not work properly if you do so. 

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our website and apps more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and consult the help and guidance provided by the developer of your internet browser and the manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please get in touch with us at compliance@dwellow.co.uk