Privacy Policy

1.2 This service is being provided in partnership with Switch Squid Ltd (“Switch Squid”), a company registered in England and Wales, company number 13332631, with its registered office at Fulford House, Newbold Terrace, Leamington Spa, Warwickshire, United Kingdom, CV32 4EA.

1.3 We also provide our Service in conjunction with Gocompare.com Limited, a company registered in England and Wales, company number 5799376, with its registered office at Imperial House, Imperial Way, Coedkernew, Newport NP10 8UH.

1.4 This policy sets out the basis on which any personal data we collect from you, or that you or others provide to us, will be processed by us. The data we process mainly relates to energy information relating to your household.

1.5 For the purpose of data protection laws, the data controllers are Perswitch Ltd and Gocompare.com Limited. Reach is a data processor.

2.1.1 To enter into contracts with you: Where you enter into a contract with us for our energy analysis services, we need to process your personal data to provide these services to you. Our use of your personal data in this way includes sharing your personal data with energy companies and credit reference agencies, in order to switch your energy tariff, provide energy efficiency and smart home advice, and for the purposes of assessing fraud, credit and/or security risks. We need to process your personal data in this way to enter into and perform the contract for the services you have asked us to provide. If you do not wish to provide us with your personal data in this way, you will be unable to use our services.

2.1.2 To make our site better: We will also process your personal data in order to provide you with a more effective user experience (such as by displaying our website in a way which is tailored for your device and browsing habits). This processing means that your experience of our site will be more tailored to you, and that the services and energy tariffs you see on our site may differ from someone accessing the same site with different energy usage or browsing habits. We also use various cookies to help us improve our site (more details are set out in section 4), and share your personal data with third party analytics and search engine providers that assist us in the improvement and optimisation of our site. We will also process your personal data for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey Purposes. The data processing condition we use in these circumstances is our legitimate interest to provide you with the best customer experience we can, and to ensure that our site is kept secure.

2.1.3 To provide customer services to you: We may also process your personal data in order to provide various supporting customer services to you (such as where you contact us with a question in connection with a product). The data processing condition we rely on when we process your personal data in these circumstances is our legitimate interest to provide effective customer support services. If you do not provide us with the personal data we request from you for customer services purposes, we may not be able to fully answer your queries.

2.1.4 For marketing purposes: Where you have opted in via our site to receive marketing communications from us, we will process your personal data to provide you with marketing communications in line with the preferences you have provided. The data processing condition we rely on when we process your personal data in these circumstances is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at [email protected] or, where relevant, by following the unsubscribe link in every marketing communication you receive from us. Please note that if you unsubscribe from an email that is required as part of our Service, we will be unable to provide you with our Service. Emails concerning our energy comparison and switching service are not marketing emails.

2.1.6 If our business is sold: We will transfer your personal data to a third party:

2.1.6.1 in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with data protection legislation); or

2.1.6.2 if Perswitch or substantially all of its assets are acquired by a third party, in which case personal data held by Perswitch about its customers will be one of the assets transferred to the purchaser.

2.1.6.3 In each case, the data processing condition we rely on when we process your data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to

our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

2.1.7 Legal obligations: In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with a legal obligation.

3.1.1 Information you give us: This is information about you that you give us by filling in forms on our site, purchasing our services and completing your online account profile, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our services, participate in social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include names, addresses, email addresses, energy supplier details, tariff information, and phone numbers.

3.1.2 Information we collect about you via our site: When you visit our site, we will automatically collect the following information:

3.1.2.1 Technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types

and versions, screen resolution, operating system and platform; and

3.1.2.2 Information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain

pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

3.1.3 Information we collect about you via your smart meters: When you have smart meters, we may collect energy usage data related to your household. The data we collect varies depending on which smart meters and/ or smart devices you have in your home, but usually includes tariff information, energy usage and unique identifiers relevant to your smart meter and energy usage (such as serial numbers). You can obtain a complete list of the data we collect about your particular smart meter by contacting us as [email protected].

3.1.4 Information we receive from other sources: Where you have ordered services from us, we may also be provided with your personal data via organisations we interact with in the energy sector, such as the type of smart meter you have and, if you have recently switched energy suppliers, what stage you are at in that process. We also obtain, where available, your energy usage history for up to 3 years and switching history for up to 6 years. We only use this data in order to deliver our service, in ensuring we take into account usage patterns that may have been affected by Covid lockdown and other factors, to better recognise the energy products that are most likely to suit you and to seek to negotiate the best prices on your behalf.. We also work with other business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers from whom we may also receive information about you.

3.1.5 We do not process any special categories of personal data (also commonly referred to as “sensitive personal data”).

4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.

4.3 Cookies that we use include:

4.3.1 Pingdom (_cfduid) – Purpose: Measuring page speed. Pingdom Cookies Policy: https://www.solarwinds.com/legal/privacy

4.3.2 Google (_ga, _gaid, _gid) – Purpose: Google analytics. Google Cookies Policy: https://developers.google.com
/analytics/devguides/
collection/analyticsjs/cookie-usage

4.3.3 Lotame (DMP) – Purpose: 1st party data collection. Lotame Data Policy: https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy/

4.3.4 AppNexus (DSP) – Purpose: Track user actions in response to an advertiser’s creatives (via 3rd party cookie). AppNexus Data Policy: https://monetize.xandr.com/privacy-center/

4.4 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

4.5 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site, and our site may be less tailored to your needs and preferences.

4.6 All cookies have default expiration as follows:

4.6.1 one week for Pingdom;

4.6.2 two years for Google Analytics;

4.6.3 up to 18 months for Lotame; and

4.6.4 up to 18 months for AppNexus.

5.1 We will combine the information you provide to us with information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

location outside of the EEA will be subject to compliance with the EU-US Privacy Shield. To learn more about the Privacy Shield Framework, you can visit the US Department of Commerce’s Privacy Shield website:

7.2 Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with our service) subject to section 7.1 above, we will retain your data for 12 months.

8.1.1 based on our legitimate interests to improve our site, provide customer services, or on the sale of our business (as set out at section 2.1.6 above). If you ask us to stop processing your personal data for these reasons, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and

8.1.2 for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.

8.2 Your other rights under data protection laws

8.2.1 Right of access: You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. You can exercise the right in a variety of ways, and the easiest way for you do to this is likely to be by emailing us at [email protected].

8.2.2 Right of rectification: You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.

8.2.2 Right of rectification: You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.

8.2.3 Right to restriction: You have the right to restrict our processing of your personal data where:

8.2.3.1 the accuracy of the personal data is being contested by you;

8.2.3.2 the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;

8.2.3.3 we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or

8.2.3.4 we are processing your data on the basis of our legitimate interest to improve our site, provide customer services, or on the sale of our business (as set out at section 2.1.6 above) and you:

(i) object to our processing as set out at section 8.1.1 above; and

(ii) want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.

8.2.3.5 Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

8.2.4 Right to data portability: You have the right to receive your personal data in a structured, standard machine readable format and the right to transmit such personal data to another controller.

8.2.5 Right to erasure: You have the right to require we erase your personal data which we are processing where one of the following grounds applies:

8.2.5.1 the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed;

8.2.5.1 the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed;

8.2.5.2 our processing of personal your data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data; you object to the processing in as set out in section 8.1.1 of this policy and we have no overriding legitimate interest for our processing;

8.2.5.3 the personal data have been unlawfully processed; and

8.2.5.4 the erasure is required for compliance with a law to which we are subject.

8.3 You have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.