Labrador Ltd. (Labrador, we, or us) is a company incorporated in England and Wales. Our registered office is 8 Greencoat Place London SW1P 1PL.
This policy sets out the basis on which any personal data we collect from you, or that you or others provide to us, will be processed by us. The data we process mainly relates to energy usage by you and other members of your household.
For the purpose of data protection laws, the data controller is Labrador Ltd.
- Why we process personal data
- Paragraphs 1.2 – 1.7 below explain why we process your personal data, as well as the data processing conditions we rely on when we carry out this processing. More information on what the data processing conditions mean and why they are important is available here.
- To enter into contracts with you: Where you enter into a contract with us for our energy analysis services, we need to process your personal data to provide these services to you. Our use of your personal data in this way includes sharing your personal data with energy companies and credit reference agencies, in order to switch your energy tariff, provide energy efficiency and smart home advice, and for the purposes of assessing fraud, credit and/or security risks. We need to process your personal data in this way to enter into and perform the contract for the services you have asked us to provide. If you do not wish to provide us with your personal data in this way, you will be unable to use our services.
- To make our site better: We will also process your personal data in order to provide you with a more effective user experience (such as by displaying our website in a way which is tailored for your device and browsing habits). This processing means that your experience of our site will be more tailored to you, and that the services and energy tariffs you see on our site may differ from someone accessing the same site with different energy usage or browsing habits. We also use various cookies to help us improve our site (more details are set out in section 3), and share your personal data with third party analytics and search engine providers that assist us in the improvement and optimisation of our site.
- To provide customer services to you: We may also process your personal data in order to provide various supporting customer services to you (such as where you contact us with a question in connection with a product). The data processing condition we rely on when we process your personal data in these circumstances is our legitimate interest to provide effective customer support services. If you do not provide us with the personal data we request from you for customer services purposes, we may not be able to fully answer your queries.
- For marketing purposes: Where you have opted in via our site to receive marketing communications from us, we will process your personal data to provide you with marketing communications in line with the preferences you have provided. The data processing condition we rely on when we process your personal data in these circumstances is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at email@example.com or, where relevant, by following the unsubscribe link in every marketing communication you receive from us.
- If our business is sold: We will transfer your personal data to a third party:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with data protection legislation); or
- if Labrador or substantially all of its assets are acquired by a third party, in which case personal data held by Labrador about its customers will be one of the assets transferred to the purchaser.
In each case, the data processing condition we rely on when we process your data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.
- In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with a legal obligation.
We will also process your personal data for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The data processing condition we use in these circumstances is our legitimate interest to provide you with the best customer experience we can, and to ensure that our site is kept secure.
- Categories of information we collect from you
We will collect and process the following personal data:
- Information you give us: This is information about you that you give us by filling in forms on our site, purchasing our services and completing your online account profile, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our services, install our Labrador device, participate in social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include names, addresses, email addresses, energy supplier details, tariff information, and phone numbers.
- Information we collect about you via our site: When you visit our site, we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our site (including date and time), 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.
- Information we collect about you via our Labrador device: When you use our Labrador device, we will collect energy usage data related to your household. The data we collect using the Labrador device varies depending on which smart meter you have in your home, but usually includes tariff information, energy usage and unique identifiers relevant to your smart meter and energy usage (such as serial numbers). You can obtain a complete list of the data we collect about your particular smart meter by contacting us as firstname.lastname@example.org.
- Information we receive from other sources: Where you have ordered services from us, we may also be provided with your personal data via organisations we interact with in the energy sector, such as the type of smart meter you have and, if you have recently switched energy suppliers, what stage you are at in that process. We only use this data in order to deliver our service. We also work with other business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers from whom we may also receive information about you.
- We do not process any special categories of personal data (also commonly referred to as “sensitive personal data”).
- A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.
Cookie Name Purpose More information Pingdom _cfduid Measuring page speed Pingdom Cookies Policy _ga, _gaid, _gid Google analytics Google Cookies Policy
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site, and our site may be less tailored to your needs and preferences.
- All cookies have default expiration, one week for Pingdom, two years for Google Analytics.
- Uses made of the information
- We will combine the information you provide to us with information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- We will also create aggregated, anonymised data based on the information we have collected about you. This data helps us to understand general load profiles in the energy sector, as well as energy trends. We may use this data to improve our services, or for other research and commercial purposes.
- Where we store personal data
- All information you provide to us is stored on secure servers.
- Period of storage
- Where you order services from us, we will retain your data for as long as you are a customer of Labrador, and for six years afterwards, to ensure that we are able to assist you should you have any questions, feedback or issues in connection with a service you have received from us.
- Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with our service) subject to section 6.1 above, we will retain your data for 12 months.
- Your right to object under data protection laws
- You have the right to object to us processing your personal data where we are processing your personal data:
- based on our legitimate interests to improve our site, provide customer services, or on the sale of our business (as set out at sections 1.3, 1.4 and 1.6 above). If you ask us to stop processing your personal data for these reasons, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and
- for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
- You have the right to object to us processing your personal data where we are processing your personal data:
- Your other rights under data protection laws
- You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. You can exercise the right in a variety of ways, and the easiest way for you do to this is likely to be by emailing us at email@example.com.
- If you exercise this right before 25 May 2018, your request will be subject to a £10 fee.
- You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
- You have the right to restrict our processing of your personal data where:
- the accuracy of the personal data is being contested by you;
- the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;
- we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or
- we are processing your data on the basis of our legitimate interest to improve our site, provide customer services, or on the sale of our business (as set out at sections 1.3, 1.4 and 1.6 above) and you:
- object to our processing as set out at section 7.1.1 above; and
- want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.
- Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
- You have the right to receive your personal data in a structured, standard machine readable format and the right to transmit such personal data to another controller.
- You have the right to require we erase your personal data which we are processing where one of the following grounds applies:
- the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed;
- our processing of personal your data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data; you object to the processing in as set out in section 7.1.1 of this policy and we have no overriding legitimate interest for our processing;
- the personal data have been unlawfully processed; and
- the erasure is required for compliance with a law to which we are subject.
- You have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.
Right of access
Right of rectification
Right to restriction
Right to data portability
Right to erasure
- Links on our site
Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. Our service connects you to different websites. If you follow a link to any of these websites or use our service, please note that you have left our site and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before you submit any personal data to these websites.