SUFL – Customer Privacy Notice
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Stark Utility Funding Limited collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The personal information we collect and use
We collect the following personal information when you provide it to us:
- Contact information (e.g. your email address or telephone number)
- Address information (both for invoicing purposes and site detail information)
- Consumption information
- CCTV footage (when captured on CCTV cameras at our premises)
- Other personal data (including sensitive personal data) you provide to us voluntarily.
Most of this information is collected directly from the individuals that we interact with, when they contact us in writing, by telephone or electronically (by email, though our website or through social media). Information may be collected as a result of our services being used or interaction with us by an individual. We may also obtain such information from third parties, for example credit reference agencies.
How we use your personal information
We use your personal information to:
- identify you and manage any accounts you hold with us;
- process your order;
- conduct research, statistical analysis and behavioural analysis;
- carry out customer profiling and analyse your purchasing preferences;
- if you agree, let you know about other products or services that may be of interest to you;
- detect and prevent fraud;
- do a credit check;
- customise our website and its content to your particular preferences;
- notify you of any changes to our website or to our services that may affect you;
- carry out security vetting;
- improve our services; and
- ensure that customers can access the pages they are subscribed to.
Who we share your personal information with
We may share your relevant personal data (e.g. your name and site address details) with:
- other companies within our group;
- our agents, service providers and regulatory authorities (for a list of our sub-contractors – please send your request to firstname.lastname@example.org); and
- credit reference agents.
This data sharing enables us to carry out services and verify financial status.
We will also share your information with your Utility Supplier(s) and any other third party authorised by you in writing from time to time.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other unauthorised third party.
How long your personal data will be kept
- We will retain your personal data to ensure retention periods of any applicable regulatory body or as required by law are adhered to.
- Currently, we work to retaining your personal data for no longer than 72 months from termination/conclusion of all services with us.
Reasons we can collect and use your personal information
In the majority of cases where we carry out services, our lawful basis for processing is contractual.
We may process your personal information due to a legal obligation (e.g. tax reasons).
In relation to marketing, we rely on legitimate interests as the legal basis on which we collect and use your personal data. Our legitimate interests are to offer the same or similar products/services to existing customers. If a customer wishes to opt out of receiving marketing materials from us, we will ensure this request is complied with.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email, call or write to us (see contact information provided below). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 28 days for this to take place for electronic communications, and postal communications should stop within two months.
- let us have proof of your identity and address, and
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone)
We may also process your personal information if you consent to us doing so. However, if you wish to withdraw consent the above opt-out rules will apply.
Transfer of your information out of the EEA
We may need to transfer your personal data outside the European Economic Area, for the purpose of providing services. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data.
If you would like further information please contact us (see contact information provided below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
If you would like to exercise any of those rights, please:
- email, call or write to us (see contact information provided below)
- let us have enough information to identify you (e.g. account number, user name, meter reference),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates, including any account or reference numbers, if you have them.
If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 28 days for this to take place for electronic communications, and postal communications should stop within two months.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected or actual data security breach. We will notify you and any applicable regulator of a suspected or actual data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulations also give you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published on 22/05/2018 and will be reviewed annually.
We may change this privacy notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please send an email to email@example.com or you can write to us at: Stark Utility Funding Limited, Sentinel House, 10-12 Massetts Road, Horley, Surrey, RH6 7DE or call us on 01293 776747.
June 09, 2020