Introduction

As your energy supplier, we’ll have access to some of your personal and sensitive information. This privacy notice sets now and why we collect your personal information.

If you have any questions or concerns, please email our data security team at info@threecountiesenergysolutions.co.uk.

Collecting your information

We will collect personal information about you during our sign-up process, when you get in touch with us, use our website or just as part of providing our services to you.

We may also be provided with your personal information by other parties.

• Comparison websites or energy switching companies – this is so that we can provide our service to you.
• Energy industry partners – this includes energy supply data and vulnerability data so that we can supply your energy safely and accurately, these partners may include your previous supplier(s) and metering agents.
• Landlords and estate agents – those moving in or out of a property, or a landlord or estate agent may provide us with contact information. We may use this information to contact you in relation to the continuation of the energy supply to your property.
• Councils, postal services, and data brokers – may provide us with contact information, moving-home status and other details.
• Referral scheme – customers can share a link with others to recommend Three Counties Energy Solutions so if you come to us using this option you will provide us with your contact information.

Categories of information

We have set out below different categories of data that we may process and include some of the reasons why we need this information.

• Contact information – this includes your name, date of birth or age range, address, email address and telephone number. We need this to verify your identity and to become your energy provider.
• Financial data – your bank details and payment details so you can pay for your energy services.
• Energy supply data – your energy use, technical information on your meter(s), supply history and smart meter data. As well as billing purposes, this information lets us know that your meter is safe and operating and recording correctly.
• Technical data – this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile data – includes your account log in information, your interests, preferences, feedback and survey responses.
• Data about your communications or interactions with us – such as information about how you communicate with us (by phone, emails, or chat) and how you use our website and app or interact with our ads and content on other websites. More information on this is in the ‘Cookies and analytics’ section.
• Marketing and communications data – includes your marketing preferences for us and third parties and your communication preferences.
• Vulnerability data – information relating to your health, disability or financial circumstances. This information helps us to provide you with appropriate services to keep you safe and to determine your eligibility to be on the Priority Services Register (PSR).
• Customer service data – when you get in touch by phone, email, chat or on social media we monitor, record and review those communications so we can provide the best possible service to you and all our customers and so we can show evidence of transactions or events.
• Other products – Information about how you use other products and services that we supply such as solar, batteries, and EV charging.

How we’ll use your information

We’ll only use your personal information where necessary and allowed to by law. Generally, this will be under one or more of the following circumstances.

• To provide our services. We need to process your information to set up your account, supply your energy and the services you’ve asked for, and bill you accordingly. For example, we will use your information to arrange your switch over to us, manage payments towards your energy and maintaining your meter(s), monitor use, and generate and send bills. We also use your personal information to add you to the Priority Service Register if necessary.
• To help us improve or develop our website, services and products. We will aggregate data, to improve our operations and make sure we are providing you with the best service possible. All aggregated data is anonymised and doesn’t reveal your identity.
• To fulfil our legal and regulatory obligations. We are governed under Gas and Electricity Supply Licence conditions and by Ofgem directions and Codes. We may need to comply with court orders and disclose information to law enforcement agencies if required.
• To help us prevent and monitor any debt, fraud and loss that may occur.
• To make sure that our employees are trained properly as well as meeting our regulatory and legal responsibilities. To achieve this we may monitor and record your calls, emails or webchat to do so.
• Incentives, schemes, products and services: if you have given consent, we will get in touch with you about these that we or our partners are offering.
• To administer and protect our business, website and app (including monitoring and recording troubleshooting, data analysis, testing, system maintenance, support and reporting.
• To maintain and improve our services: for example, we may use information contained in your emails and calls to train our team. We may also use your information to make sure that our services are working as intended, for example, understanding which parts of the website are easiest to use or whether service emails are correctly delivered. We may also contact you for suggestions on how we can improve the way we provide our services to you.
• To provide personalised advertising
• To communicate with you about our services: we may contact you about product updates on our website and app, and through other marketing channels, such as third-party social networks, like Facebook.
• To help you switch to another energy provider: we provide limited account information to other energy suppliers if you switch to them.
• To run loyalty and reward programmes you may have signed up to these programmes
• To analyse account and payment activities to help identify alternative, or more appropriately tailored price plans and payment schedules that could be offered
• To provide your contact details to service providers and partners to provide you with the services or assistance you’ve requested

Some of these purposes are for our legitimate business interests. This means that using your information is necessary for us to build our business and provide our services to you. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

Getting in touch with you

We’ll always contact you by the method we’ve agreed with you when you signed up to us.

Smart meter

Taking your smart meter readings with your consent

If you use a smart meter and we are able to operate this remotely, we’ll normally collect readings from your smart meter once a day. You can decide whether we take a reading for the entire 24-hour period or for each half-hour period. We won’t take more than one reading a day unless you have given us your consent. If you’d prefer us to only take one reading a month, you can email us at info@threecountiesenergysolutions.co.uk.

Analysing your smart meter readings to offer you new products and services with your consent

If you use a smart meter and we are able to operate this remotely, we could use your smart meter readings to understand how you use your energy. For example, we could learn how to buy energy for lower prices and be able to build and offer you new products and services. We will only use your smart meter readings to do this if you have given us your consent.

If you have any questions or concerns about how we use your personal information, please email our data security team at info@threecountiesenergysolutions.co.uk.

Withdrawing consent

You can email us at info@threecountiesenergysolutions.co.uk at any time to withdraw this consent.

Marketing information

If you decide you want to change your marketing preferences, you can do so in your Three Counties Energy Solutions online account or you can just send an email to info@threecountiesenergysolutions.co.uk and we’ll update your preferences for you.

Disclosing your information

We sometimes need to allow our service providers to process your personal information on our behalf for the reasons set out above or as otherwise required by law.

We may also transfer your personal data to third parties for the purposes set out in ‘How we’ll use Your Information’.

• To give you the product or services you’ve requested. We may have to give information to one of your family members, household, anyone acting on your behalf or other people who have an interest (like landlords or letting agents).
• To help find and prevent debt, fraud or loss.
• We’ll have to disclose your details if any unpaid debt is transferred to another organisation.
• For legal or regulatory purposes such as our regulator, Ofgem, or for consumer protection organisations such as the Energy Ombudsman.
• Service providers who provide engineering services, industry data collection and aggregation, call-centre, IT and system administration services.
• Marketing agencies to provide you with information about our products and services or other products and services which may be of interest to you (provided you’ve given your consent) and to help manage any reward or loyalty schemes.
• If you’re leaving us as an energy customer, we’ll pass on your information on to your new suppliers. This may include any special assistance requirements and information about you as an energy customer.
• If we are asked to provide information to the police or law enforcement agencies we will require them to provide a warrant, unless we feel that it is in the best interests of our customers or the public to provide the information without a warrant.

We make sure that these third parties won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law.

Sending your data outside the UK

Occasionally, we may need to pass your information to our agents and service providers, this may involve people or organisations outside the UK. The laws of some of the jurisdictions in which these people or organisations are located may not be as robust as those of the UK.

If we do, we will take all steps reasonably possible to make sure your personal information is handled securely and in line with this privacy notice. Accordingly, we have put in place strong contractual commitments with these organisations.

If you give us information on behalf of someone else, you’re confirming that they know about it and agree. You should show them this privacy information.

How we protect your information

We follow strict security procedures to protect personal information. This includes following certain guidelines (for example, checking your identity when you phone us).

We recommend that you do not disclose your account login details to anyone. Please always remember to log out of your account when you have finished accessing your online account.

We regularly review our practices for collecting, processing and storing personal information, including physical security measures, to guard against unauthorised access to systems and backups to prevent the loss of information. We will continue to enhance our security procedures as new technology becomes available.

We restrict access to personal information wherever possible to people who need to know that information to process it and who are subject to contractual confidentiality requirements.

We use encryption to keep your information private while in transit.

Retaining your information

We will only keep your personal information we collect for as long as it is necessary for the purposes for which we collected it. The length of time depends on the purposes for which we used it, or otherwise to meet our legal obligations.

We will delete any information as soon as we no longer have a valid reason to hold it. if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and prevent any further processing until deletion is possible.

Your rights

You have various rights in relation to your personal information.

• Request access to your personal information – you can request a copy of the personal information we hold on you.
• Request correction of your personal information – if any personal information we hold on you is incorrect, you can request to have it corrected. You can update personal information that we have on you through your online account.
• Request deletion of your personal information – you can ask us to delete your personal information in certain circumstances. If we are not able to do this we will explain why not.
• Object to processing or restrict processing of your personal information – you may object to our processing or ask us to restrict our processing of your personal information in certain circumstances.
• Request the transfer of your personal information – to provide you, or a third party you have chosen, with your personal information.
• Withdraw consent to processing of your data – where we’re relying on consent to process your personal information.

If you want further information about your rights, you can contact the Information Commissioner’s Office. You can also complain to them although we prefer you to contact us first. For all requests please email us at info@threecountiesenergysolutions.co.uk.

Lawful bases

UK data protection law requires an organisation to have a lawful basis for its personal information collection and use, and there are several lawful bases available.

Performance of a contract

When you use our services, almost all the personal information collection and use is necessary to provide the service.

If you provide us your contact details to ask us a question, request more information or contact us, we use your details to reply and resolve any issues.

Legitimate interests

Some personal data collection and use is in our legitimate business interests. To use this lawful basis we assess both our interests and yours, to make sure that what we’re doing does not cause any unjustified privacy intrusion.

Examples: identity checks; fraud prevention and reporting; marketing campaign records.

Legal obligation

We have legal obligations to collect, use and keep certain information for certain purposes.

Examples: diligence on corporate customers; records of who has unsubscribed from marketing.

Marketing: if you have provided us your contact details to hear about our products and services and you no longer want to hear from us, we are obliged by law to stop contacting you. To meet this legal obligation we will add your details to a suppression list so you no longer hear from us.

Consent

Where we require consent, we will explain why and provide sufficient information to allow you to make an informed decision. When we receive consent to perform such activities, that consent may be withdrawn at any time by contacting us. If you decide you want to change your marketing preference, you can change your preference in your Three Counties Energy Solutions online account or you can just send an email to info@threecountiesenergysolutions.co.uk and we’ll update your preferences for you.

Examples: to contact you by email or SMS to make you aware of new products that may be of interest to you; analysing your smart meter readings to offer you products and services.

Cookies and similar technologies

We use cookies and similar technologies to collect information and store your online preferences to create a smoother browsing experience. A ‘cookie’ is a piece of information stored on your computer that records how you’ve used a website. Some cookies are necessary for our website to function. Some allow us to monitor how our customers and visitors use our website, so we can make improvements to its design, layout and functionality. Some cookies recognise your computer and remember non-personal information each time you use the site, so you can just pick up where you left off each time.

Visit our Cookie Policy for more information on the data we collect. You can enable and disable specific sets of cookies from your browser at any time by clicking the ‘Cookie Preferences’ link at the bottom of all our pages.