- The personal information we collect about you;
- How we will use your information;
- Who your information might be shared with;
- How we keep your data secure; and
- Your rights to your information.
Our uses of your information include:
- enabling you to access and use the Youtility service within third party platforms/applications (Partners);
- optimising and personalising your experience in our service and improving aspects of our service;
- research (e.g. measuring how many people consider changing provider);
- arranging communication between you and a new service provider; and
- if required, we will disclose any regulatory or governmental bodies that receive your information.
This Policy will occasionally be updated. This policy was last updated on 18 November 2020.
Firstly, who we are…
The Youtility service is operated by Youtility Limited (Youtility). Youtility Limited (‘we’ or ‘us’ or ‘our’) are a ‘data controller’ for the purposes of UK data protection legislation, (i.e. we are responsible for and control the processing of your personal information). Youtility’s registered office is Office 7, 35-37 Ludgate Hill, London, EC4M 7JN, our registered company number is 09802196, our Financials Conduct Authority (FCA) reference number is 803462 our ICO number is ZA255938.
… and how to contact us?
1. The personal information we collect about you and how we collect it.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data including:
a) Information you have provided to our Partner’s platform/application, that is required to deliver the service.
b) Information you provide us while utilising our service, such as the type of meter you have in your home.
c) Personal information about other individuals. If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can:
- give consent on their behalf to the processing of their personal data;
- receive on their behalf any data protection notices;
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 when requested, we may not be able to perform the contract we have or are trying to enter into with/for you. In this case, we may have to cancel a service or contract you have with us, but we will notify you if this is the case at the time.
2. How will we use your information?
We will use your information to:
- enable you to access and use the service;
- optimise and personalise your experience in the service and to improve aspects of our services;
- customise our services to your particular preferences;
- aggregate and anonymise your information so that we can conduct statistical analysis, behavioural analysis and research (e.g. measuring how many people consider changing provider). This research is only undertaken by us and only disclosed by us to selected third parties in an anonymised aggregated format that does not identify you personally or your specific postal address;
- carry out customer profiling and analyse service provider purchasing preferences;
- notify you of any changes to our services that may affect you;
- detect and prevent fraud;
- administer the services accessed via us
Service provider switching
3. Who your information may be shared with.
As part of the service, we, or you, may disclose your personal information to:
- Our third-party technology partners who help facilitate the switch of your service providers;
- Third party providers (such as broadband providers) that are offering a product or switch, where that switch will be conducted directly via that relevant third-party provider’s system or website; and
- Law enforcement agencies in connection with any investigation to help prevent unlawful activity.
4. How we keep your data secure.
We use technical and organisational measures to safeguard your personal data, in addition to those followed by our Partner’s application/platform, as outlined below:
- We use secure servers with all information transmitted over industry standard Secure Socket Layer (SSL) connections and Transport Layer Security (TLS);
- The Youtility infrastructure and database is hosted on Microsoft Azure, a platform that implements all levels of security controls to safeguard against potential application level weakness and recognizes any potential threats. You can see Microsoft Azure’s security policy here: www.microsoft.com/en-us/trustcenter/security/azure-security.
- Microsoft Azure meets a broad set of international and industry-specific compliance standards, including ISO 27001, HIPAA, FedRAMP, SOC and SOC 2, as well as country-specific standards (e.g. UK G-Cloud). On top of that, rigorous third-party audits conducted by the British Standards Institute verify Azure’s adherence to these strict security controls.
- Your personal information which we collect is sent to and stored on secure servers located in the UK. Such storage is necessary in order to process the information for the purposes of providing our service. Personal information may be transferred by third parties mentioned in the circumstances described above, which may be situated outside the UK and may be processed by staff operating outside the UK. Where we (or our partners) transfer your personal information outside the UK we will take all reasonable steps to ensure that your privacy rights continue to be protected.
- While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any concerns about your information, please contact us (see ‘How to contact us?’ above).
5. How do we use your data and what is the legal basis for our processing your information?
We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract with, and services provided to, you;
- 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; and
- Where we need to comply with a legal obligation.
For some uses of your information the legal basis for our processing of your personal data is your consent. In other cases, the legal basis is that the processing is necessary to provide you with the service you have contracted with us to provide. In other cases, the legal basis is our legitimate interest in engaging in commerce and offering products and services of value to you, as set out above. Any consent you provide may be withdrawn at any time by emailing us at email@example.com.
6. How long will we retain your data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Where such requirements do not need to be met, we ensure that all personally identifiable information is deleted within 1 week of a submitted switch. We will use reasonable endeavours to ask that third party providers who are handling a switch directly (such as broadband providers that handle the switch on their website) also do the same.
We will ensure that all of your personally identifiable information is permanently deleted within 14 days of you requesting us to delete it by emailing us at firstname.lastname@example.org.
What rights do you have?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
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.
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.
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
Object to 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.
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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
Not to be subject to automated individual decision making
We will not make decisions based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We will however be conducting some analysis for the purpose of matching you with suitable switches, as set out in the “Service Provider Switching” section above. We will use reasonable endeavours to ask that third party providers who are handling the switch directly (such as broadband providers that handle the switch on their website) also comply with this paragraph.
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.
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
If you would like to exercise any of those rights, please contact us at email@example.com. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.
What you can do to keep your information safe
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
If you make a complaint to us regarding the use of your personal data and you think that we have not dealt with it to your satisfaction, you may send your complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues for investigation. For more information on the Information Commissioner, and how to make a complaint, please visit their website at www.ico.org.uk.