Intelligent Data Technologies Limited Privacy Statement
1. Purpose of our privacy statement
- Under the Data Protection Act and the UK General Data Protection Regulation, we are required to explain to you why we are asking for information about you, how we intend to use the information you provide to us and whether we will share this information with anyone else.
- It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
2. Who we are
- Lucid is owned and operated by Intelligent Data Technologies Limited, a company with trading name ‘Lucid’. We are a limited company registered in England and Wales under company number 11852854).
- Our registered office is at Consort House, 1 Princes Road, Weybridge, Surrey, United Kingdom KT13 9TU. Intelligent Data Technologies Limited is the controller and responsible for the personal data we collect through your use of our website and the Lucid app.
3. Our Data Protection Officer
- Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
- If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to email@example.com.
4. Who is this for?
- This policy is intended to be read by any individual who may at any time provide data to us or whom we are likely to collect data from.
- This will likely be (but is not limited to) those browsing the Lucid.house website, using the Lucid app, participating in trials, enquiring about Lucid, or business clients.
- This website is not intended for children and we do not knowingly collect data relating to children.
5. Why are we collecting your information?
- We are collecting your information in order to both enable us to carry out our function as an energy management company and to improve and grow our business.
6. How do we collect your information?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Sign up to use the app, either as a trialist or as normal user;
- carry out our digital home survey;
- Tell the Lucid hub which appliances and systems exist in your home;
- carry out a price comparison;
- apply for a job or submit a job application;
- subscribe to receive our updates;
- request marketing to be sent to you; or
- make a general enquiry (including filling out the contact form on our website).
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
7. What information are we collecting?
- 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 about you which we have grouped together as follows:
- Identity Data includes names that you provide to us.
- Contact Data includes email address and telephone numbers that you provide to us.
- Log-in Details includes your username and password.
- Household Information includes information about your household such as the number of members, information about the size of your home, and the appliances in your home.
- Energy usage includes information about your energy usage including patterns of usage, the energy supplier you have chosen, and the cost of your energy usage.
- Technical Data includes internet protocol (IP) address, 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 this website.
- Usage Data includes information about how you use our website and the Lucid app.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Recruitment Data includes details from any CV or job application that you submit to us.
- Aggregated data
- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
- We use your energy usage to provide us with information about patterns of usage. This data is aggregated when used in this way so you would not be identifiable. We use this aggregated data to allow users to compare themselves against similar households and for our business purposes such as analysing patterns of usage to help us target our marketing and that of third parties and suggest tariffs.
- We may aggregate your Usage Data to calculate the percentage of users accessing a specific Lucid app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
- We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
8. What is the lawful basis for using your information?
- In accordance with the data protection laws, we need a "lawful basis" for collecting and using information about you. There are a variety of different lawful bases for processing personal data which are set out in the data protection laws.
- The lawful bases on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
- that using your information is necessary for us to be able to provide a service to you, such as keeping your energy usage data so we are able to provide tailored consumption forecasts or switching services;
- that you have provided consent to our use of your information;
- that using your information is necessary to fulfil a contract you have with us, or because you have asked us to take specific steps; or
- that using your information is necessary for the pursuing of our legitimate interests, such as developing our products and services and growing our business.
9. How will we process your energy data?
- Any data collected either by the Lucid Hub or the Lucid App will be used to provide a set of features via our App to enable you to make choices around energy usage within your home.
- Using our algorithms and analytics we provide statistical analysis of your data consumption, both historical and live as well as forecasts for your future consumption requirements. We identify the different energy usage areas within your home to provide you with a breakdown of each area and how this makes up our daily, weekly, monthly intake of energy from the national grid.
- We can also provide tips and advice on how to reduce costs and/or energy consumption, improve your self-sufficiency or reduce your carbon footprint.
10. Direct Marketing
- We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- Promotional communications from us when you are a Lucid App User:
- We may use your Identity, Contact, Technical and Usage Data to form a view on which products or services you may be interested in. We may then send you marketing communications containing offers, services or promotions based on these views.
- You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
- Non-Lucid Users: If you do not use the Lucid app, you may still sign up to our e-newsletter via our website. In this circumstance we will only send communications to you where we have your consent to do so. This will likely be through a checkbox on the website that you can check to receive the marketing communications.
- Third-party marketing: We will ask for your express opt-in consent before we share your personal data with any company outside of Lucid for marketing purposes.
- Opting out: You always have a right to opt out of direct marketing. You can ask us to stop sending you marketing messages at any time by contacting us at any time. There is also an ‘unsubscribe’ link at the bottom of all our promotional material that, when clicked on, will inform us you no longer wish to receive further direct marketing.
11. Sharing your information
- Contractors and sub-contractors:
- It may be necessary to share your information with our contractors and sub-contractors so they can provide a service to you or to enable us to deliver services you have agreed to. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act and the UK General Data Protection Regulation.
- Our contractors and sub-contractors will not share your information with any other parties (except in the case of our file storage contractor) and will only be able to use the information when completing work on behalf of us.
- We may also share your information with the following entities:
- Energy suppliers. If you carry out a tariff switch through the Lucid app, we will share the necessary information with your new chosen energy supplier.
- Companies within our group of companies.
- 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 notice.
- Law enforcement agencies where we are required to do so by law.
12. Transferring your information abroad
- Our data is hosted with the European Economic Area.
- If we do need to transfer your personal data out of the EEA or UK, and it is not transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission, we will ensure protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union. If you would like to obtain a copy of these contracts you can contact us.
- Where we use service providers based in the US, we may transfer personal data to them if they are certified under the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.
13. Security of your personal information
- The information that you provide will be stored securely on our electronic systems. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information. These measures and procedures are audited and reviewed.
- Only relevant members of staff will have access to the information you provide to us. Those members of staff will have received appropriate data protection training.
- Any payment transactions will be encrypted (using SSL technology).
14. Can we use your information for any other 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
- 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.
15. Storing your information and deleting it
- In accordance with our obligations under the Data Protection Legislation, Intelligent Data Technologies Limited shall only retain personal data for as long as is necessary for the legitimate purposes for which the personal data is processed. This includes information provided to Intelligent Data Technologies Limited, or a third party acting on our behalf, for research purposes.
- When those purposes come to an end, IDTL shall securely delete the personal data unless the retention of the personal data is required for archiving purposes which are in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) of the UK GDPR or other applicable provisions under the Data Protection legislation.
- When one of the above situations arise, we will review the information which we hold concerning you and determine whether there are any legal reasons why we need to continue holding that information. Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to hold on to your information, we will delete your information.
- If you provide information for research purposes, at the end of the research project the information will be deleted or kept in an anonymised or pseudonymised format unless you are specifically notified otherwise.
- If you would like further information about our data retention and disposal schedule then please contact firstname.lastname@example.org.
16. Your rights
- In relation to the information which we hold about you, you are entitled to:
- see a copy of the information;
- ask us to rectify the information where it is inaccurate or is incomplete. If we agree the information is inaccurate or incomplete and make the rectification, we will inform any recipients of the information of the change, where possible;
- ask us to erase the information, but we will not be able to comply where we hold your information to fulfil our statutory regulatory and representative obligations;
- ask us to restrict what we do with your information, but there are a number of exemptions relating to this right;
- object to our use of your information and ask us to stop that use, in certain circumstances; and
- instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation.
- Our obligations to comply with the above rights are subject to certain exemptions.
- Where we are using some of your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected. You can do this by emailing email@example.com.
- You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO – see https://ico.org.uk/global/contact-us/ for details.
17. Other websites