Purpose of this privacy notice

This privacy notice aims to give you information on how Bryt Energy collects and processes your personal data, including any data you may provide through this website, or other channels, when you interact with us in relation to products or services from the Bryt Energy Group. It also describes how in the course of providing our services we collect and use your personal data in order to deliver personalised advertisements for products and services you might be interested in.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Bryt Energy Limited is the controller and responsible for your personal data (collectively referred to as “Bryt Energy”, “we”, “us” or “our” in this privacy notice). 

The Bryt Energy Group is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Bryt Energy Group so when we mention “Bryt Energy”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Bryt Energy Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Bryt Energy Limited is the controller and responsible for this website. 

We have appointed a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any queries about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact the DPM using the details set out below.

Contact details

Full name of legal entity: Bryt Energy Limited

Email address: dpm@brytenergy.co.uk

Postal address: Bryt Energy Ltd, 1 Victoria Square, Birmingham, B1 1BD 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk or phone 0303 123 1113 or by post to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

Previous versions are archived and can be obtained by contacting us. 

It is important that the personal data we hold about you is accurate and kept up to date. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

Personal data, or personal information, is any information that could directly, or indirectly relate to a person. Any personal data that has been completely striped of any identifiers is then considered anonymous data and the GDPR will no longer apply.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, date of birth, address, Unique identifier (GUID), username or similar identifier.
• Contact Data includes billing address, delivery address, email address, telephone numbers, details of all meters located at a property together with electricity usage at each and every property being supplied with electricity, any criminal offences or allegations of energy theft, and records of any conversations and correspondence (including recordings of telephone conversations) between you and us.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes your login and session data, browser type and version, time zone setting and location on the devices you use to access this website.
• Profile Data includes your username and password (when an account has been created), feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.
• Social Media includes information either in the public domain or you share with us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data by law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. 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 notice.

We do not collect any Special Categories of Personal Data about you. This includes; details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data.

If you fail to provide personal data

Where we need to collect personal data by law or in order to fulfil a contractual agreement and you fail to provide that data, we may not be able to perform the contract we have or are trying to provide. For example, for us to set up or continue to supply you with electricity, we would require primary contact details. In this case we may cancel our products or services, but you will be notified of this and our reasons for doing so.

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us via our website, post, phone, email, social media or otherwise.

This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• provide us feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. This includes:
• Contact, Financial and Transaction Data from providers of credit reference agencies such as Creditsafe Business Solutions Ltd based in the United Kingdom;
• Identity and Contact Data from electricity meter operators (including meter data collectors or aggregators) such as Siemens plc, Lowri Beck Services Ltd, SSE Metering Ltd, IMServ Europe Ltd and Stark Software International Ltd, all of whom are based in the United Kingdom;
• Identity and Contact Data from Third Party Intermediaries (TPIs) and brokers that you have appointed as your agent (where relevant) in respect of your electricity supply arrangements, all of whom are based in the United Kingdom or elsewhere inside the EU;
• Identity and Contact Data from publicly available sources, such as Companies House and the Land Registry based in the United Kingdom.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into
• 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
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Apart from as stated above, generally we do not rely on consent as the legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to opt out of marketing communications at any time by contacting us.

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from Bryt Energy where you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Bryt Energy group of companies for their marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt-out of receiving these marketing messages, this will not apply to communications required for our legitimate interest as a result of a product or service purchased by you.

Cookies 

Please see our cookie policy.

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.

Where it is permitted by law, we may process your personal data without your knowledge or consent, in compliance with the above rules.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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 notice.

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.

Some of our External Third Parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, 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.
• Where we use certain service providers, we may use specific contracts approved by the UK supervisory authority which give personal data the same protection it has in the UK. For further details, see the Information Commissioners Office: International Transfers.

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

We have put in place appropriate security measures to prevent your personal data from 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.

How long will you use my personal data for? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law, we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Please see our Data Retention Policy for more details.

In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.

At any time, you have the right to ask us to:

• provide you with a copy of the personal data you have provided to us.
• update or correct your personal data.
• delete any personal data that we no longer have legal grounds to process.
• provide further information on how we use your personal data.
• Stop the processing your personal data where we use legitimate interest as the lawful basis.
• provide you with your personal data in a structured, machine-readable format or transmit the data to another controller upon your request.
• restrict how we use your information.
• provide information about the logic involved in the automatic processing of your personal data in the case of the automated decision-making.

If you wish to exercise any of the rights set out above, please contact us. You can read more about your rights here.

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 may 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 calendar month. Occasionally, it may take us longer than 30 days to respond 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.

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Bryt Energy Group, details of which can be found here, who are based in the United Kingdom and provide IT and system administration services and undertake group reporting.

 External Third Parties

• Service providers acting as data processors who provide IT and system administration services such as, Ensek Ltd (based in the United Kingdom) and salesforce.com EMEA Ltd (all data is processed inside the European Economic Area (EEA)).
• Credit reference agencies such as Creditsafe Business Solutions Ltd, based in the United Kingdom.
• Service providers acting as debt collection agents and solicitors such as EOS Solutions UK Plc, Echo Managed Services Ltd, 1st Locate (UK) Ltd, Wilkin Chapman LLP and Judge & Priestley LLP, all of whom are based in the United Kingdom.
• Electricity meter operators (including meter data collectors or aggregators) such as Siemens plc, Lowri Beck Services Ltd, SSE Metering Ltd, IMServ Europe Ltd and Stark Software International Ltd, all of whom are based in the United Kingdom.
• Energy market administrators such as ECOES and the Meter Point Administration Service, as we may need to check that your meter is correctly registered against your address.
• Professional advisers including Deloitte LLP (our statutory auditor) based in the United Kingdom who provide audit and tax compliance services.
• Regulatory, governmental and industry bodies such as Ofgem, HM Revenue & Customs, and Elexon based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Service providers acting as data processors who provide marketing services including the distribution of marketing material on our behalf, such as The Rocket Science Group LLC (trading as Mailchimp), Twilio, and SendGrid, based in the US, or Force24 Ltd based in the UK. 
• The Third Party Intermediary (TPI) or broker you appointed as your agent (where relevant) in respect of your electricity supply arrangements, performing services such as obtaining quotations, entering into contracts and validating invoices. Where the TPI performs these services it has your authority to act on your behalf, and where the TPI purports to enter into a contract on your behalf or to exercise any of your rights under a contract, the authority to do so is expressed in writing.
• Other electricity suppliers if and when you switch electricity supplier.