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TILI PRIVACY POLICY

 

We’re committed to protecting and respecting your privacy.

 

This policy explains what personal information we’ll collect from you on our home move assistant website Tili at www.asktili.com (Tili). This policy also describes how we collect, store and use your personal information and tells you how we make sure we’re meeting our legal obligations to you, under the UK data protection laws (including associated guidance).

 

  1. WHO WE ARE

 

Tili is a home move assistant website operated by Spark Energy Limited, a company registered in Scotland (registration number SC301188), whose registered office is at Ettrick Riverside, Dunsdale Road, Selkirk, United Kingdom, TD7 5EB (Spark).

 

In this policy we also mention Spark Energy Supply Ltd (registration number: 05857467) and Home Telecom Limited (registration number: 07412021). These are companies in our group who supply some of the products and services which you’re able to select when using Tili.

 

For the purpose of data protection laws, we are the "controller". That means we’re responsible for looking after the personal information that we hold about you.  We’ll use your personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws. You can contact us at dataprotection@sparkenergy.co.uk

 

  1. THE INFORMATION WE COLLECT ABOUT YOU

 

A) Information we ask you to provide or confirm to us

 

You may give us information about you by filling in information and completing sections on Tili, or by communicating with us by phone, e-mail or other means. This includes information you provide when you register to use Tili, search for a product or service or place an order – and when you report a problem with our site.

 

We’ll ask you to provide or confirm the following information:

  • your name;
  • your date of birth;
  • your postal address;
  • your phone number (landline and/or mobile);
  • e-mail details;
  • details about the property you’re moving into and the number of people living there;
  • bank account details (if you want to set up a Direct Debit); and
  • credit, debit or other payment card details (if you want to set up a payment).

 

B) Information we collect when you visit Tili or when you contact us

Each time you visit Tili, we’ll automatically collect the following information: 

  • technical information, including the Internet protocol (IP) address used to connect your computer to the web, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Tili (including date and time), products you viewed or searched for, 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 and any phone number used to call us.

We’ll also record calls that we hold with you for quality, training and audit purposes (and to ensure that calls meet legal and regulatory requirements), but only having notified you of this.

 

C) Information we collect from other sources

We work with your letting agent and we’ll collect the following information about you from them:

 

  • your name;

 

  • your telephone number and email contact details;

 

  • the address of the property you’re moving out of;

 

  • the address of the property you’re moving in to; and

 

  • the date on which you’ll move into the new property.

 

D) Credit reference and fraud prevention agencies

 

When you enter into a contract for the supply of energy to your property with Spark Energy Supply Ltd or a contract for the supply of telecoms services with Home Telecom Limited, they may collect information about you from credit reference agencies and fraud prevention agencies. When credit reference agencies receive a search request, they’ll place a search footprint on your credit file that may be seen by other lenders. They supply both public (including the electoral register) and shared credit and fraud prevention information.

 

We may also make checks such as assessing your application for credit and verifying identities to prevent and detect crime.

 

  1. HOW WE’LL STORE AND USE YOUR INFORMATION

 

We (or a third party acting on our behalf) may collect, store and use your personal information listed in section 2 above (including energy consumption data) for the following purposes:

  • to tell your local council and water authority that you’ve moved into your new property, so they’ll know who’s responsible for paying any council tax and water charges;
  • to communicate with you in relation to your use of Tili and to contact you by phone and email to confirm your details are correct for local council and water authority notifications;
  • where you’ve selected this, to transfer your energy supply to Spark Energy Supply Ltd, from your previous energy provider or to transfer you to a new tariff supplied by Spark Energy Supply Ltd.
  • where you’ve selected this, to set up your telephone and broadband service with Home Telecom Limited;
  • where you’ve selected this, to call you about your choice to purchase a Sky package;
  • to provide you with information about how much of a particular service you’ve used and what charges will apply;
  • to allow you to participate in interactive features and as part of our efforts to keep Tili safe and secure and to administer Tili for internal operations;
  • to contact you (including by SMS, phone and e-mail) with products and services that we offer which are similar to those you’ve already enquired about, or information about services or products you’ve opted in to receiving from us;
  • in connection with system maintenance, testing and training;
  • to run credit checks, the results of which may impact the energy, telecoms and other services which we offer you (these credit checks may be completed by Spark Energy Supply Ltd or Home Telecom Limited in connection with the services you ask then to supply to you);
  • to undertake or assist fraud prevention, identity or money laundering verification and legal enforcement where necessary;
  • to create profiles and marketing opportunities where you’ve explicitly consented for your data to be used for such purposes; and
  • in connection with market research activities.

 

 

We won’t keep personal information longer than is necessary for the purpose or purposes for which they were collected. For marketing purposes, unless you tell us otherwise, we’ll keep this for six months after you register with Tili.

 

  1. WHO WE SHARE YOUR INFORMATION WITH

 

We may share your personal information for the purposes listed above with the following organisations:

  • Home Telecom Limited, a company in our group, so that they can contact you about the broadband, phone and other telecoms services you select when using Tili;
  • Spark Energy Supply Ltd, a company in our group, so that they can contact you about any energy products you select when using Tili;
  • our other service providers and subcontractors in order to provide the products and services that you’ve requested;
  • Government and/or regulatory bodies, such as Ofgem in order to discharge our obligations under laws and regulations which apply to us;
  • third parties where there is a legal duty to disclose or share such information or in order to enforce or apply the terms of our contract with you;
  • other utility service providers who may supply your property as well as your local authority, water company, social services, charities, healthcare or other support organisations and/or housing associations relevant to your property and/or use of our services;
  • payment providers in order to process payments you make in Tili;
  • online email service providers in order to send you communications about your use of Tili;
  • credit reference and fraud prevention agencies for the purpose of performing credit checks and identifying instances of fraud;
  • a governmental body or a law enforcement agency, where we’re required to do so by applicable law; and

 

  • market research organisations in order to ask you about your experience using Tili.

 

If a third party acquires all (or substantially all) of our business and/or assets, we may disclose your personal information to that third party in connection with the acquisition.

 

If you give us false or inaccurate information and we suspect or identify fraud we’ll record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.

 

  1. USING YOUR DATA FOR MARKETING PURPOSES

 

If you have a contract with us or where you’ve opted in to receive marketing information from us, then we may contact you (including by SMS, telephone, e-mail or by social media (for example through Facebook)) with information about products and services that we offer which are similar to those you already receive from us, or information about services or products you’ve opted in to receive from us.

 

If you would prefer not to receive this information please let us know by writing to: Marketing Communications, Spark Energy, Ettrick Riverside, Dunsdale Road, Selkirk TD7 5EB or by emailing communications@sparkenergy.co.uk or by updating your preferences at www.asktili.com – If you are writing to us, please include your name, address and postcode and whether you’d like to opt out of email, text messages, or both.

 

You can also tell us at any time if you want us to stop sharing your personal information with other organisations for marketing purposes.

 

  1. HOW WILL WE COMPLY WITH DATA PROTECTION LAWS?

Data protection laws require that we meet certain conditions before we’re allowed to use your personal information in the ways explained in this privacy policy. We take our responsibilities under data protection laws very seriously, including meeting these conditions. To use your personal information, we’ll rely on the following conditions:

  • Performance of a contract: we use your data primarily in order to provide you with the products and services that you’ve requested or which we’ve been appointed by your letting agent to provide on behalf of you or your landlord.
  • Consent: we may provide you with marketing information about our services or products where you’ve provided your consent for us to do so.
  • Legitimate interests: to use your personal data for any other purpose described in this privacy policy, we’ll rely on a condition known as "legitimate interests". It’s in our legitimate interests to collect your personal data as it provides us with the information we need to send notifications to your local council and water authority and provide our services to you more effectively. This means we need to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with the information, products and services you request from us), against the interests you have as a citizen and the rights you have under data protection laws (for example, to not have your data sold to third party marketing companies without your knowledge, or store your personal data in insecure or unstable countries or regions). The outcome of this balancing test will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we’ll always rely on your explicit consent). We’ll always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.

 

 

  1. SPECIAL CATEGORIES OF PERSONAL DATA

Data Protection Laws define certain personal data as falling into ‘special categories of personal data’ such as personal data regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying a person, data concerning your health (including mental and physical health), or data concerning your sex life or sexual orientation.  If you provide this information, this will be an indication that you explicitly consent to us processing it. 

 

  1. WHAT AUTOMATED DECISIONS DO WE MAKE ABOUT YOU?

We use automated decision-making tools to determine the likely energy consumption and broadband speed at the property you are moving.

         

  1. HOW WE MAY CONTACT YOU

 

We may contact you by email, phone, text or multimedia message, or other forms of electronic communication, unless you’ve told us you don’t want us to communicate with you in one or more of these ways.

 

 

  1. COOKIES

 

Cookies are small text files that are placed on your computer or mobile device when you visit a website or when you open an email or SMS communication. They’re used to make websites and other forms of communication work more efficiently as well as to track certain actions. You can disable cookies.

 

When you use Tili, we don’t use any cookies or place them on your computer or mobile device.  However, SagePay and Google Analytics may use cookies.

 

  1. HOW LONG YOUR DATA IS KEPT BY US

 

We won’t keep personal information longer than is necessary, for the purpose or purposes for which they were collected.

 

If we only use your data for local council and water authority notifications, we’ll keep it until we’ve completed the notifications. If you sign up to any energy or telecom products Spark Energy Supply Ltd and Home Telecom Limited will keep your data for the periods, they outline in their own privacy policies.

 

For marketing purposes, unless you tell us otherwise, we’ll keep this for six months after you register with Tili.

 

 

  1. THIRD PARTY WEBSITES

 

Tili contains links to other websites operated by third parties. Please note, this privacy policy applies only to the personal information that we collect through Tili and from your letting agent and we can’t be responsible for personal information that third parties may collect, store and use through their websites. You should always read the privacy policy of each website you visit carefully.

 

  1. SECURITY

 

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Whilst we take appropriate technical and organisational measures and have in place physical and electronic procedures necessary to safeguard the personal information that you provide to us, no transmission to or from us by post, email, phone, SMS or over the Internet can ever be guaranteed as entirely secure. Communications over the web are not secure and as such, we can’t accept any liability or responsibility for any unauthorised access or loss of personal information.

 

We also have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach where we’re legally required to do so.

Where we’ve given you (or where you’ve chosen) login details which enables you to access Tili or other services of ours, you’re responsible for keeping these details confidential.  You agree that you won’t share your login details with anyone else.

 

  1. YOUR RIGHTS

 

You have a number of rights under data protection law in relation to the way we process your personal information. These are set out below.  You may contact us using the details below to exercise any of these rights and we’ll respond to any request received from you within one month.

Your right

What does this mean?

1. You have the right to request access to your personal information

You have the right to request confirmation that your personal information is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal information. 

2.  You have the right to ask us to rectify your personal information

You have the right to request that we rectify your personal information if it’s not accurate or not complete.

3.  You have the right to ask us to erase your personal information

You have the right to ask us to erase or delete your personal information where there’s no reason for us to continue to process your personal data.  This right would apply if we no longer need to use your personal data so you can use Tili; where you withdraw your consent for us to process special categories of your personal information; or where you object to the way we process your personal information (see right 6 below).

4.  You have the right to ask us to restrict or block the processing of your personal information

You have the right to ask us to restrict or block the processing of the personal information that we hold about you. This right applies where you believe the personal information is not accurate. If you’d prefer that we block the processing of your personal data rather than erase your personal information, then you can ask us to do this. You can also ask us to restrict or block processing of your personal information where we don’t need to use your personal information for the purpose we collected it for, but you may require it to establish, exercise or defend legal claims. 

5.  You have the right to port your personal information

You have the right to obtain and reuse your personal information from us so that you can reuse it for your own purposes across different services.  This allows you to move personal information easily to another organisation, or to ask us to do this for you.

6.  You have the right to object to our processing of your personal information

You have the right to object to our processing of your personal information on the basis of our legitimate business interests, unless we’re able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal information for the establishment, exercise or defence of legal claims.

7.  You have the right not to be subject to automated decisions

You have the right to object to any automated decision-making, including profiling, where the decision has a legal or significant impact on you.

8.  You have the right to withdraw your consent

You have the right to withdraw your consent to our processing of your special categories of personal information.

 

  1. HOW TO FIND OUT MORE

 

If you have any questions about how we collect, store and use personal information, or wish to raise any concerns then please contact us:

 

Email us: dataprotection@sparkenergy.co.uk

 

Phone us: 0345 034 7474

 

Write to us: Spark Energy, Customer Services, Ettrick Riverside, Dunsdale Road, Selkirk TD7.   

 

  1. CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be updated on Tili and, where appropriate, notified to you by e-mail.  Please check back frequently to see any updates or changes to our privacy policy.

This policy was last reviewed and updated in April 2018.

 

  1. COMPLAINTS

 

If you have any concerns regarding our processing of your personal information, or are not satisfied with our handling of any request by you in relation to your rights, please contact us at dataprotection@sparkenergy.co.uk or phone us on 0345 034 7474.

You also have the right to make a complaint to the Information Commissioner's Office.  Their website is www.ico.org.uk and you can write to the First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.