Elektro Store (EKORAD UK LIMITED), a subsidiary of Bastian PLC Group, is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.

This policy sets out the following:

• What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
• Where we obtain the data from;
• What we do with that data;
• How we store the data;
• Who we transfer/disclose that data to;
• How we deal with your data protection rights;
• And how we comply with the data protection rules.
• All personal data is collected and processed in accordance with English and EU data protection laws.

Bastian PLC (also referred to as “we”, “us”, “our” or “Bastian PLC Group”) in this policy primarily refers to the operating corporate group to which at the time of this policy includes the companies Foxglove Energy Supply [comprising of Outfox the Market, Eco7 Energy & Fischer Energy], Premier Radiators, Fischer Future Heat, Novorad, Elektro Store (EKORAD UK LIMITED) and Fischer Future Heat GmbH. Bastian PLC Group is the “data controller” of all personal information that is collected and used by the above group companies and brands for the purposes of the UK Data Protection Bill and the EU General  Data Protection Regulation (GDPR). Bastian PLC Group is registered as 08912836 at address Granville Hall, Granville Road, Leicester, Leicestershire, United Kingdom, LE1 7RU.

Personal data: means any information relating to you which allows us to identify you, such as your name, contact details, customer account/reference number, payment details and information about your access to our website.

We will collect personal data from you when you sign up with us (either directly or indirectly through our trusted third party partners), create an Online Account, use our website and/or other websites accessible through our website, participate in a survey or competition, or when you contact us or register interest.

Specifically, we may collect the following categories of information:

• Contact data(your name, email address, postal address, phone number, date of birth, gender and any other relevant information we need in order to contact or identify you);
• Financial data(your bank account and payment details relating to products and services you receive from us);
• Technical data (internet protocol (IP) address, your login data (including your Online Account username and password), browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We track technical data by cookies, please see the section below for more information.
• Usage data (information about how you use our website, products and services) including information about your purchase of our trusted partners’ products and services;
• Marketing and communications data(your preferences in receiving marketing from us and our third parties and your communication preferences);
• Energy supply data(this is your supply start date, meter technical details, tariff and when you have a smart meter installed at your property we’ll also capture your energy consumption data; and
• Special categories of data(health and financial vulnerability data, if applicable, to include you on the Priority Services Register).

We also use aggregated data, in order to improve our operations and ensure we are providing you with the best service possible. It’s really important that the personal data we hold about you is up to date so please let us know if your personal data changes at any time.

When will we collect it?

We and our agents collect certain personal information from and about you during your sign up journey and when you get in contact with us or use our website or as part of providing our services to you. This could be though us directly or through another Bastian PLC Group company.

We may also monitor and record any communications we have with you, including phone calls, emails, web chats, letters and social media exchanges to make sure we are providing an excellent service to our customers. We may contact you by telephone, web chat, email, post or in person as necessary.

Your data may be used for the following purposes:

• Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your contract and account. These communications are not made for marketing purposes and cannot be opted-out of;
• Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
• Administrative or legal purposes: we use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
• Security, health, administrative, crime prevention/detection:  we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
• Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
• Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your contract with us and to personalise the services we offer to you, such as special offers or deals;

Marketing information

When you first provide your personal information to us, we will use Legitimate Interest as the legal basis to process your data.  We may use your identity, contact, usage and profiled data to tell you about exciting new products and services from us and our related businesses in the wider Bastian PLC Group (or they may contact you directly). We collect data through our websites (own brand and third party), direct marketing, contact centres and national advertising.  You may be contacted by email, post or telephone.

If you decide you want to opt-out of receiving marketing communications or want to change how you receive them, you can always change your preferences by contacting us at any time. This won’t affect any marketing information we sent to you before you let us know.

Processing your Data

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for. In most cases we will need to process your personal data so we can enter into our contract with you.

We may also process your personal data for one or more of the following:

•           To comply with a legal obligation;
•           You have consented to us using your personal data (e.g. for marketing related uses);
•           To protect your vital interests or those of another person;
•           It is in our legitimate interests in operating as a company (e.g. for administrative purposes and marketing related uses).

We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with English and EU law on data protection rules, although we cannot be held liable to this extent.

Who do we share your data with?

Your personal data may be shared with other companies within the Bastian PLC Group. We may also share your personal data with the following third parties for the purpose described in this Privacy Policy:

• Government authorities and regulators for compliance with legal requirements;
• Complaints bodies such as the Energy Ombudsman, Citizens Advice Bureau, Extra Help Unit, Trading Standards and other mediatory bodies which you may use, in order to for your complaint to be handled.
• Trusted service providers we are using to run our business such as metering operators, engineering services, industry data collection and aggregation, IT and system administration, price comparison sites and cloud service and e-mail marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns;
• Credit and debit card companies and debt collection agencies, which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction;
• Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
• Social media:You may be able to access third party social media services through our website or before coming to our website. When you are registered with your social media account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalise your use of our website. We may also use social media plugins on our website. As a result your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.

We are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes. Please consult their privacy policies for further information. Our third parties who only process data on our behalf won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law.

Disclosing information outside the EU

Sometimes the organisations listed above may be outside the EU, so we may pass your personal information to countries that do not have the same standards or protection for personal information as the UK. If we, our agents or our service providers do this, we will try and ensure that these organisations adequately secure your personal information.

Energy Switching

We may also ask your previous energy supplier for personal information about you that will allow us to take over your supply (for example, information about your meter readings, meter technical details etc.). Similarly, if you switch away from us, we may provide similar information to your new supplier so they can begin supplying your energy.

Energy Priority Services Register or special needs

If we believe that you (or a member of your household) need extra care (for example, because of your age, health, disability or financial circumstances) and we have your explicit consent to do so, we may record and share this information with the following people to ensure your supply isn’t interrupted:

• other energy suppliers if we believe you are considering changing supplier;
• an outsourced service company that manages a wide range of energy industry data interactions on our behalf;
• the electricity distributor; and
• the relevant gas transporter, metering agents or network operator.

Protecting your personal information

We follow strict security procedures to protect your personal information. This includes following certain guidelines (for example, checking your identity when you phone us).

We strongly recommend that you do not disclose any Online Account login details to anyone. Please always remember to logout of your account when you have finished using any of our websites.

From time to time, our website may provide hypertext links to sites which are created by individuals and companies outside of Bastian PLC Group.  We do this if the site is relevant to the topic you’re reading about. Whilst we always try to check that the content of these sites is suitable, we cannot take any responsibility for the practices of the companies who publish the sites that we link to, or the accuracy or relevance of the content on them.

Online Accounts

All data collected within your Online Account will be processed in line with this Privacy Policy. For clarity, Online Account may refer to My Den, Hero Hub and 24/7 depending on the brand in question.

We understand the importance of taking extra precautions to protect the privacy and safety of children. You must be over 18 to sign up and have a contract with us, therefore anyone under this age should not have access to any Online Account operated by us. We will delete any Online Account created by a person under the age of 18, as soon as are made aware of it.

When our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time by contacting us and requesting this.

We keep your personal information contained in your Online Account until such time you request it is erased. Please note that general retention periods apply to any personal data we collected to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.

Cookies

What are cookies?

• A cookie is a text file containing an identifier (a chain of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
• Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
• Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Why do we use cookies?

We use cookies for the following purposes:

Advertising – we use cookies to help us to display advertisements that will be relevant to you. Information comes from cookies that you collected on website that you visited prior to visiting our website.

Remarketing – we use cookies to retain information through the Google Display Network. This allows us to promote relevant offers and advertisements to you throughout the internet.

Analysis – we use cookies to help us to analyse the use and performance of our website and services.

Cookie Consent – we use cookies to store your preferences in relation to the use of cookies more generally.

What data do we collect?

• We do not collect any personal information that can identify you or an individual.
• We do collect information about your location, browsing habits and device type. This information allows us to improve our website and customer experience.
• This data is stored accumulatively on Google AdWords and Google Analytics.
• We use widgets from Third Party website Trustpilot. This does not collect any sensitive data from visitors to elektrostore.co.uk. However, it does collect the username and review written by the reviewer on Trustpilot.com
• We use Google Adometry, Google Analytics Advertising, Google Adwords Customer Match, Google Display Network Impression Reporting, Google Analytics Demographics.

Cookies used by our service providers

• Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
• We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
• Google AdWords uses the DoubleClick ad exchange to ensure accuracy over how much we pay for online advertising but also to improve the advertising delivered to you. None of the data collected by DoubleClick is personal or sensitive to you.

Managing cookies

• Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

https://support.google.com/chrome/answer/95647?hl=en (Chrome)

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)

https://www.opera.com/help/tutorials/security/cookies/ (Opera)

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)

https://support.apple.com/kb/PH21411 (Safari)

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

Requesting your Data

We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. You have the right to make a complaint at any time to this authority.

Under certain circumstances, by law you have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it. 
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you want to exercise any of these rights, then please contact our DPO by:

• Email at privacy@bastianplc.co.uk
• Post at Bastian PLC Group’s Data Protection Officer, Bastian PLC Head Office, North Mills, Frog Island, Leicester, LE3 5DH
• Phone on 0800 092 7480

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Our Privacy Policy may change from time to time, changes will be posted on this page when they do occur. This is version is up to date as of 24^th May 2018.