Smart Home Charge Privacy Notice

Version number: 2.0.0
Effective date: 11/7/2022

1.    Who are we?
1.1    We are (Response) EPR Limited trading as “Smart Home Charge”. For privacy queries, you can contact us at [email protected]. Other contact details are on our website. 

2.    What’s the point of this notice?
2.1    It tells you what to expect when we collect your personal information via our website or otherwise in connection with our service. Please only use our service if you are completely happy with this privacy notice. 

2.2    Generally, the privacy notice covers only information provided to us. If you give personal information to other people, such as payment or credit providers or other websites, please check their privacy notices. 

3.    Might the notice change?
3.1    Yes. Please check it whenever you visit our website.

4.    What do we collect? 
4.1    Information which you upload to our service or otherwise give us such as:
•    your name and contact details;
•    other information you provide to us such as your vehicle details and information about your property relevant to installation and about your finances if you opt for payment by instalments;
•    details about your transactions on our service;
•    information included in your reviews or which you otherwise provide for display on our service or which you include in messages sent via our service;
•    contact or other information which you give or allow us to use for newsletters or other marketing; and
•    your communications with us.

4.2    Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.  

4.3    The following information about you may be provided to us by other people:
•    Your contact information sent to us by charger manufacturers who refer you to us.
•    Limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing / delivery addresses.

5.    What’s our reason / legal basis for collecting the information?

5.1    We are only able to use your personal data when the law allows us to. This is called the legal basis. What do we mean by lawful bases? Privacy law allows us the following bases under which we can process your personal data:

Consent - You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time. To do so please contact us.

Contact - We need to use your data to fulfil a contract you have with us. Alternatively, it's necessary to use your data because we have asked you to, or you have taken yourself, specific steps before entering that contract.

Legal Obligation -  We need to use your data to comply with the law.

Vital Interests - Processing your data is necessary to protect your vital interests or of another person. For example, to prevent you from serious physical harm.

Public Task - Using your data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law, for example, for a statutory function.

Legitimate Interests - Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests.

In line with this, we have the following reasons for processing your personal data, as outlined in the next subsections. -

5.2    Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract, e.g., send service messages, process payments and fulfil orders. This applies to initial enquiries and to contact and transaction details. 

5.3    Because it’s in our “legitimate interests”, e.g., to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data as well as to reviews and similar information which you provide for public display on our service.

5.4    Because you’ve specifically agreed on our service (e.g, by ticking a consent box). This applies to contact or other information which you give or allow us to use for newsletters or other marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.  

6.    How long do we keep personal information? 
6.1    Until our contract with you has ended or you request us to delete your information by emailing us at the above email address.

6.2    We may hold on to some of your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.

6.3    We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.    

7.    To whom do we send or make available your personal information? 
7.1    To other people who supply us with a service, e.g. engineers, couriers, software developers, website hosts, payment and credit providers, and businesses which help us send communications or monitor our website and which provide us with e-commerce, online advertising, analytics, and other IT services. 

7.2    To other users of our service, if you enter personal information into a review or other public action on our service.  You can ask us to remove displayed information by emailing us at the above email address.

7.3    To credit reference agencies, regulators and the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.

7.4    To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.5    To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

7.6    In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice

8.    Do we send your information outside the United Kingdom or the European Union?
8.1    If your personal data is transferred outside of the UK and to the EU, this is done because the EU has comparable data protection standard as determined by the UK Government. This is known as Adequacy. The same applies where your data is transferred from the EU to another country which also has adequacy.

8.2    If your personal data is transferred to a country outside the UK or EU where there is not an adequate level of data protection, we use other safeguards such as enhanced contractual clauses. These may include the EU Standard Contractual clauses, in conjunction with the UK International Data Transfer Addendum (IDTA) for transfers outside the UK. Your personal information may be transferred to the US by the following companies: Google (analytics / advertising), Facebook (advertising), Mailchimp (email delivery).

You can find information on the EU SCCs here, and UK IDTA and other UK transfer mechanisms here.

9.    What rights do you have? 
9.1    If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).

9.2    You may also have the right to object to use of your personal information in certain circumstances.

9.3    If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you also have the right to complain to the Information Commissioner’s Office (ICO).

9.4    For more information about your rights, visit the ICO’s website: www.ico.org.uk.

10.    What about cookies?
10.1    We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser.  Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). Also, some cookies specifically require your consent before they can be used, such as performance cookies or analytical cookies, while other cookies which are essential do not require your consent.

For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org. Our site’s functionality will be limited if you configure your browser to reject cookies.

10.2    We ourselves may place the following types of cookies:

10.3    Companies which provide us with a service also place cookies. Some of these cookies (e.g. from Google) may involve certain information, such as your IP address and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. These cookies are subject to your consent before they can be used. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:

•    Google Analytics (“GA”). More:
-    general information about the types of cookies placed by Google including analytics 
-    a technical explanation of GA cookies
-    Google’s use of its partners’ data including how to control information collected by Google
-    how to specifically opt out from GA cookies 
-    Google’s privacy policy

Advertising cookies: These kinds of cookies are typically used to personalise ads on this or other sites based on your use of our site, to measure ad effectiveness (for example, how often you click on or view ads and whether you go on to buy something from the advertiser) and to stop you being shown the same ad repeatedly. These cookies are subject to your consent before they can be used. These cookies are provided by:

•    Google (including Analytics Ad Features / AdSense / Doubleclick)
-    general information about the types of cookies placed by Google including advertising
-    how Google uses cookies and other technologies in advertising including how to opt out of advertising cookies (this explains how ad personalisation works)
-    Google’s use of its partners’ data including how to control information collected by Google
-    Google’s privacy policy

•    Facebook (including “Facebook Pixel”)
-    Facebook’s cookies policy (see especially under “Advertising, recommendations, insights and measurement”) including how to control Facebook’s use of cookies
-    Facebook’s privacy policy

Note that there are various places where you can go to opt out of many companies’ advertising cookies in one go including some or all of the above:
-    www.networkadvertising.org/choices
-    http://www.youronlinechoices.com/
-    http://optout.aboutads.info 

•    Social media cookies: These kinds of cookies are placed by social media companies when you use their features on another site, for example if you play embedded audio or video, click a Facebook “like” or sent a tweet. These features may involve the relevant companies using cookies to collect information relating to your visit to our website or your interaction with their services or otherwise. Click the following links for further information including how to opt out where this is possible: Facebook, Twitter, LinkedIn, Instagram, YouTube