Privacy Policy

This privacy policy (the “Privacy Policy”) is designed to give you useful information about the way we collect and use your personal information through your use of the www.eco.anesco.co.uk website (“Our ECO Site”), and to tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy 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 Policy supplements other notices and privacy policies and is not intended to override them.

1. BACKGROUND
   Anesco understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our ECO Site and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

1. DEFINITIONS AND INTERPRETATION
   In this Privacy Policy, unless the context otherwise requires, the following expressions have the following meanings:

“cookie” means a small file placed on your computer or device by Our ECO Site when you visit certain parts of Our ECO Site and/or when you use certain features of Our ECO Site;

“ECO” means the Energy Company Obligation energy efficiency scheme;

“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 on the basis of our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you. 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 using the details in section 15; 

“Obligated Energy Supplier” means an energy supplier that has an obligation under the ECO scheme to install ECO measures in customers’ homes. A list of all energy companies that are “Obligated Energy Suppliers” for ECO can be found in the ECO section of the Ofgem website: www.ofgem.gov.uk; and

“personal data” means any information relating to an identified or identifiable natural person.  

• INFORMATION ABOUT US

The Anesco Group is made up of different legal entities. This privacy policy is issued on behalf of Anesco Energy Limited. When we mention “Anesco”, “we”, “us” or “our” in this privacy policy, we are referring to Anesco Energy Limited. 

1. WHAT DOES THIS POLICY COVER?
   This Privacy Policy applies only to your use of Our ECO Site. Our ECO Site may contain links to third-party websites, plug-ins and applications. We have no control over how your data is collected, stored, or used by other websites and are not responsible for their privacy statements. We advise you to check the privacy policies of any such websites before providing any data to them.

1. WHAT DATA DO WE COLLECT AND WHY?
   Depending upon your use of Our ECO Site, we may collect some or all of the following personal data (please also see our Cookie Policy):

 

Activity	Categories of personal data	Legal ground(s) for processing and purposes for processing
Visiting Our Site	IP address; web browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform; other technology on the devices you use to access this Site; a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to; information about how you use Our Site, products and services; demographic information such as preferences, and interests; information about how you use Our Site, products and services. For detailed information about our use of cookies, we refer to our Cookie Policy.	We collect this personal data on the basis of your consent or, in case we are not legally required to obtain consent, on the basis of our legitimate interests, namely improving our online services. This is the case with regard to technical cookies necessary for the functioning of Site and several analytics cookies that are not used to treat you differently from other users.  We process your personal data for purposes of (i) providing and managing your access to Our Site, (ii) administering and protecting our business and Our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), (iii) analysing your use of Our Site to enable us to continually improve Our Site and your user experience, or (iv) market research.
Providing our services to you – installers and customers interested in having ECO measures installed	name; job title; location; contact information such as email addresses and telephone numbers; demographic information such as preferences, and interests.	We collect this personal data as this is necessary for the performance of a contract or on the basis of our legitimate interests, namely carrying out our business. We process your personal data for the purpose of supplying our services to you.
Providing our services to you – installers	company name; Trustmark registered number; company registration number; PAS accreditation; type of ECO measures installed; amount of LTS per week.	We collect this personal data as this is necessary for the performance of a contract or on the basis of our legitimate interests, namely carrying out our business. We process your personal data for the purpose of supplying our services to you.
Providing our services to you – customers interested in having ECO measures installed	Details of your energy supplier Demographic information such as preferences, and interests Information about your home property (including the type of property and the nature of your tenure, such as, for example, whether you live in social housing) Copies of documents showing proof of benefits and income and other information evidencing your eligibility for the ECO scheme Proof of identity if required to demonstrate eligibility for the ECO scheme	We collect this data on the basis of your consent. We process this data for the purpose of supplying our services to you. If you are an individual applying for ECO measures to be installed, we will also use your name, address, identity information and copies of documents showing proof of benefits, income and tenure in order to evidence to an Obligated Energy Supplier (who will contribute towards the cost of ECO measures) that you are eligible for the ECO scheme or, if you are not eligible for the ECO scheme, to evidence whether you are eligible for another energy efficiency scheme.
Customer service or otherwise corresponding with you	name; company name; job title; location; contact information such as email addresses and telephone numbers.	We collect this personal data as this is necessary for the performance of a contract or on the basis of our legitimate interests, namely verifying your identity for reasons of security, improving our services and providing customer service. We process your personal data for the purposes of (i) responding to emails and contact requests from you, (ii) where you have downloaded information from Our Site, contacting you to give you more information about our products and services where you have consented to us doing so, (iii) managing our relationship with you which may include notifying you about changes to our terms, or asking you to leave a review, or (iv) if you indicate that you would like to be contacted in relation to the installation of energy efficiency measures, to allow our energy efficiency installers to contact you to discuss providing services to you.
Newsletters	name; company name; job title; location; contact information such as email addresses and telephone numbers; your preferences in receiving marketing from us and your communication preferences.	We collect these personal data on the basis of your consent or, in case we are not legally required to obtain consent, on the basis of our legitimate interests, namely our commercial activities and informing you of products or services that you might like. Consent: we send you our newsletters and marketing e-mails (other than for marketing regarding similar products or services), always on the basis of your prior consent. You always have the option to unsubscribe from our mailings, e.g. via the unsubscribe link in our newsletter and marketing e-mails. Legitimate interest: we send offers about similar products or services that you have previously ordered with us on the basis of our legitimate interest. You always have the option to unsubscribe from our mailings, e.g. via the unsubscribe link in our marketing e-mails. We process your personal data for purpose of supplying you with emails that you have opted into.

We will not ask you for, and we ask you not to share with us, information regarding any health condition that has led to you receiving benefits. In addition, if you share information regarding child benefits or tax credits with us, we ask that you do not include any details regarding your children. 

We do not collect any personal data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or genetic and biometric data. 

If and insofar your personal data is processed on the basis of legitimate interests, information can be obtained by you as to the so-called balancing test that was carried out to allow us to rely on this processing ground. This test shows why our legitimate interests outweigh your right to privacy in those specific cases.

• HOW IS YOUR PERSONAL DATA COLLECTED?

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

• Direct interactions. You may give us personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services through Our ECO Site or in any other way;
  • request marketing to be sent to you; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with Our ECO Site, we will automatically collect technical data (such as your 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 Our ECO Site) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from (a) analytics providers such as Google; (b) advertising networks; and (c) search information providers. We may also receive personal data about you, including sensitive personal data, from an Obligated Energy Supplier who asks us to assess whether your property is suitable for the ECO scheme after you make an enquiry to them regarding the ECO scheme.

• 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 would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details in section 15. 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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. HOW DO WE STORE YOUR DATA?
   We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In addition, by law for tax purposes we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. 

 

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 the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

You have the right to withdraw your consent to us using your personal data at any time, and in some circumstances you can ask us to delete your data.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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.

1. DO WE SHARE YOUR DATA?
   Other than in the circumstances set out below, we will not share any of your data with any third parties for any purposes.

In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.

We may compile statistics about the use of Our ECO Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

We may share your personal data with the parties, and for the purposes, set out below:

• to other companies in the Anesco Group which provide services, such as IT services, to us;
• in relation to the provision of energy efficiency services, to third party installers in order for them to discuss the provision of services with you where you have requested such information, as referred to in section 5 above;
• if you are an individual applying for ECO measures to be installed, we may share some of your data with an Obligated Energy Supplier, as described in section 5 above;
• to third parties who help us provide any part of Our ECO Site or the Services, to the limited extent required for such help, and on condition that they may not further disclose your data or use it for any other purpose; or
• to 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 policy.

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.

• INTERNATIONAL TRANSFERS

Some of our external third parties, including service providers and professional advisers, are based outside the EU or UK so their processing of your personal data will involve a transfer of data outside the EU or UK. Whenever we transfer your personal data out of the EU or 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; and
• Where we use certain service providers, we may use specific contracts approved for use in the EU or UK which give personal data the same protection it has in the EU or UK.

1. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?
   We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

1. HOW CAN YOU CONTROL YOUR DATA?
   In addition to your rights under data protection law, set out in section 17, when you submit personal data via Our ECO Site, you may be given options to restrict our use of your 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).

1. YOUR RIGHT TO WITHHOLD INFORMATION AND YOUR DUTY TO INFORM US OF CHANGES
   You may access Our ECO Site without providing any data at all. However, to use all features and functions available on Our ECO Site you may be required to submit or allow for the collection of certain data, and if you withdraw your consent to sharing data before an ECO measure is installed, we may not have sufficient evidence that you are eligible to receive an ECO measure under the ECO scheme.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data where requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods and services) In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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

You may restrict our use of Cookies. For more information, see Our Cookie Policy.

1. HOW CAN YOU ACCESS YOUR DATA?
   You have the right to ask for a copy of any of your personal data held by Us (where such data is held). In most circumstances, no fee is payable, and we will provide any and all information in response to your request free of charge. Please contact us for more details using the contact details below in section 15.

1. CONTACTING US AND MAKING A COMPLAINT
   If you have any questions about Our ECO Site or this Privacy Policy, please contact us at [email protected], by telephone on 0845 894 4444, or by post at Anesco Energy Limited, The Green, Easter Park, Benyon Road, Reading, Berkshire RG7 2PQ. 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1. CHANGES TO OUR PRIVACY POLICY
   We may change this Privacy Policy from time to time (for example, if the law changes). This version was last updated on 1 April 2024. We recommend that you check this page regularly to keep up-to-date.

• YOUR LEGAL RIGHTS – GENERAL

Under certain circumstances, you have rights under data protection laws in relation to your personal data. This includes the right to: 

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. If you want us to establish the data’s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

1. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
2. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• YOUR LEGAL RIGHTS – OBJECTING TO PROCESSING ON GROUNDS OF LEGITIMATE INTERESTS AND TO DIRECT MARKETING

Under certain circumstances, you have rights under data protection laws to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.