Privacy Notice

Last updated on 12^th January, 2021

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General

Homeflo (“we” or “us”) take the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us in person, over the phone, via our websites, associated apps and other or collected through other means.

This notice applies to personal data provided by our customers and their families, or our potential customers. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff).

In this notice references to the “Site” are references to our website.

This notice is governed by the EU General Data Protection Regulation (the “GDPR”).

The basis on which we process personal data

Personal data we hold about you will be processed either because:

• the processing is necessary for the pursuit of “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your data which is not overridden by your interests in data privacy and security;
• you have consented to the processing for the specific purposes described in this notice;
• the processing is necessary for us to comply with our obligations under a contract between you and us.

Personal data we process, purpose and legal basis

We have explained below the personal data we may process and in each case the reason we process that data and the legal basis we are relying on:

• information you provide when setting up an account with us (“Set Up Information”); We process this information when we set up your account based on our legitimate interest in obtaining the necessary information to provide our services.
• The categories of personal data obtained by Us (“Name”, “Address” “Number”, “Email Address”)
• information you provide to us relating to your account with us (“Account Information”); We process this information to monitor and administer your account based on our contract with you to provide services to you.
• information we collect which relates to call-outs or orders you have placed with us, including products and services ordered (“Services Information”); We process this information to provide our services to you based on our contract with you to provide services to you and our legitimate interest in operating our business.
• information provided relating to payment (“Payment Information”), but please note that credit or debit card information may be supplied directly to a third party payment processor who will process the data in accordance with their privacy notices or policies (see below); We process this information to provide our services to you based on our contract with you to provide services to you and our legitimate interest in operating our business.
• a record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”); We process this information to provide our services to you based on our contract with you to provide services to you and our legitimate interest in operating our business.
• details of your visits to the Site, the resources and pages that you access and any searches you make (“Technical Information”); We process this information to monitor the performance of our website and improve our site based on our legitimate interest in defining the types of customers for our products and services, keeping our website updated and relevant, developing our business and informing our marketing strategy.
• information we may hold about you for marketing purposes (“Marketing Information”). We process this information to communicate with you about our products and services based on our legitimate interests in communicating with you about our services or on the basis that you have consented to receive the information.
• We will not collect any sensitive personal data without your prior consent. By sensitive personal data, we mean data which falls within certain ‘special categories’ which are defined in the GDPR (e.g. health data) and which require additional protection and consent measures.
• Generally, we will collect personal data directly, but we may obtain data from third parties from time to time. For instance, we may licence data from a postcode database to deliver our services efficiently.
• If we do obtain your data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
• You may withdraw our authority to process your data (or request that we restrict our processing – see clause 9) at any time but we will be entitled to complete any orders we are then processing and we may need to withhold some personal data for legal or other reasons (see below).

Cookies and IP Address

• A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
• On our Site, we use cookies to track users' progress, allowing us to make improvements based on usage data. We also use cookies if you log in to one of our online services to enable you to remain logged in to that service. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service.
• Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
• We are required to obtain your consent to use cookies. We will obtain this consent with a toolbar which appears when you first visit the Site.
• If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
• An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

Category of personal data Length of retention

Records relevant for tax purposes 8 years from the end of the tax year to which the records relate

Personal data processed in relation to a contract between you and us 7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contracting party is entitled to make a legal claim

Personal data held on marketing or business development records 3 years from the last date on which you have interacted with us

• For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.
• The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
• We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
• If you wish to request that data we hold about you is amended or deleted, please see clause 9 below, which explains your privacy rights.

Sharing your information

We do not disclose any personal data you provide to any third parties other than as follows:

• Payment information may be processed by our payment partners;
• we may provide information about your name, location and your boiler system to our independent contractors who are engaged to deliver services to you;
• we may host personal data with third-party hosting partners;
• certain third party suppliers including IT technical support providers, website developers, marketing and business development service providers may have access to personal data;
• where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
• in order to enforce any terms and conditions or agreements for our services that may apply;
• we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
• to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• Other than as set out above, we shall not disclose any of your personal information systematically unless it is required for us to provide our services or you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

Email and Other Communications

If you have placed an order for services with us we may from time to time contact you about similar goods or services. We may also contact you with information about our services if you have expressly consented to receive such communications (e.g. by signing up to our newsletter) or if you are a business customer.

When we send an email and other electronic communications we will comply with applicable regulations including the Privacy and Electronic Communications Regulations 2003. In particular, we will identify the nature of the message and the sender clearly and you will have an opportunity to opt-out of receiving any further communications from us.

You can opt-out of receiving marketing communications from us at any time.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

• protecting our servers with firewalls;
• locating our data processing storage facilities in secure locations;
• encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
• ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry-standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
• when necessary, disposing of or deleting your data so it is done so securely;
• regularly backing up and encrypting all data we hold.

We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

This notice and our procedures for handling personal data will be reviewed as necessary.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site. Once we have received your information, we will use the procedures and security features referred to in this notice to try to prevent unauthorised access.

Your privacy rights

The GDPR gives you the following rights in respect of personal data we hold about you:

• The right to be informed You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
• The right of access You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
• The right to correction Please inform us if the information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
• The right to erasure (the ‘right to be forgotten’) Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in a certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
• The right to restrict processing You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.
• The right to data portability You have the right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to a third party (where technically possible).
• The right to object Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing unless we have overriding legitimate grounds.
• Rights with respect to automated decision-making and profiling You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
• Right to withdraw consent If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).

All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to the contact information at the bottom of this notice.

We will endeavour to comply with such requests as soon as possible but in any event, we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Cancellation

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Other websites

Our Site may contain links and references to other websites. Please be aware that this notice does not apply to those websites.

We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

In addition, if you came to this Site via a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Transferring your information outside Europe

We will not transfer your personal data in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:

• If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services;
• We may communicate with individuals or organisations outside of the services in providing goods and services, those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you;
• From time to time, your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.

Notification of changes to the contents of this notice

We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances if any, we share it with other parties.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via 08004220124, write to us at the following address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ Or send an email: complaints@homeflo.co.uk

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.