It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Encom Energy Limited t/as Encom Energy Systems |
| Our data protection contact | Compliance Director 01 575 9805 |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:
We collect and use this personal data for the purposes described in the section “How and why we use your personal data” below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
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Under data protection law, we can only use your personal data if we have a proper reason, eg:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
| What we use your personal data for Providing products and/or services to you |
| Our reasons To perform our contract with you or to take steps at your request before entering into a contract |
| What we use your personal data for Preventing and detecting fraud against you or us |
| Our reasons For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us |
| What we use your personal data for Inviting you to participate in energy pilot schemes, analysing your participation in such schemes to enable us to monitor the pilot and your energy usage |
| Our reasons For our legitimate interests, ie to be as efficient as we can so we can deliver the most competitive service to you |
| What we use your personal data for Conducting checks to identify our customers and verify their identity |
| Our reasons Depending on the circumstances:
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| What we use your personal data for To enforce legal rights or defend or undertake legal proceedings |
| Our reasons Depending on the circumstances:
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| What we use your personal data for Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
| Our reasons To comply with our legal and regulatory obligations |
| What we use your personal data for Ensuring business policies are adhered to, eg policies covering security and internet use |
| Our reasons For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| What we use your personal data for Operational reasons, such as improving efficiency, training and quality control |
| Our reasons For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price |
| What we use your personal data for Ensuring the confidentiality of commercially sensitive information |
| Our reasons Depending on the circumstances:
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| What we use your personal data for Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures |
| Our reasons For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| What we use your personal data for Preventing unauthorised access and modifications to systems |
| Our reasons Depending on the circumstances:
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| What we use your personal data for Protecting the security of systems and data used to provide the goods and services |
| Our reasons To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| What we use your personal data for Updating and enhancing customer records |
| Our reasons Depending on the circumstances:
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| What we use your personal data for Statutory returns |
| Our reasons To comply with our legal and regulatory obligations |
| What we use your personal data for Ensuring safe working practices, staff administration and assessments |
| Our reasons Depending on the circumstances:
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More details about how we use your personal data and why are set out our Website privacy policy and the Encom Energy app Privacy Policy.
We do not process Special Category personal data relating to our customers.
See “Who we share your personal data with” for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see above “How and why we use your personal data”). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us at sales@encomenergy.ie.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Encom Energy Systems group for marketing purposes.
We routinely share personal data with:
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We occasionally also share personal data with:
We will not share your personal data with any other third party.
If you would like more information about who we share our data with and why, please contact us (see “How to contact us” below).
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who we share your personal data with”).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: “Transferring your personal data out of the UK and EEA”.
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you no longer have an account with us, we are no longer providing goods or services to you, or the warranty or guarantee periods in relation to the goods or services we provide to you have expired, we will delete or anonymise your account data after 1 year.
Countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
You have the following rights, which you can exercise free of charge:
| Access The right to be provided with a copy of your personal data |
| Rectification The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) The right to require us to delete your personal data—in certain situations |
| Restriction of processing The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object The right to object:
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| Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consents If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see “How to contact us” below) or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights.
If you would like to exercise any of those rights, please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any queries or concerns about our use of your personal data (see below “How to contact us”). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
The UK's Information Commissioner may be contacted using the details at ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
This privacy notice was published on October 2022 and last updated on March 2023.
We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email or via Encom Energy applications.
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Compliance Director