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Privacy Policy

Ventient Energy Limited (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data in accordance with the requirements of all applicable data protection legislation, including the EU GDPR, the UK GDPR and the Data Protection Act 2018.

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice applies to our use or processing of any personal data that we may collect from you when you visit our website (regardless of where you visit it from), when you call us, when you email us, when you engage in communications with us through any other means, or when you otherwise deal with us in the course of the operation of our business or community engagement (e.g. landowners, service providers, business partners or other stakeholders). This privacy notice also applies to any personal data that we may collect about you from a third party in the course of the operation of our business or community engagement.

It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.

Controller

We are the controller in respect of the personal data that we hold about you. This means that we are responsible for determining the purposes and means of processing and using the relevant personal data.

Contact details

If you have any questions about this privacy notice or our data protection practices, including any requests to exercise your legal rights, please contact us by using the details set out below:

Postal address: Ventient Energy Limited
Connect House
133-137 Alexandra Road
Wimbledon
London
SW19 7JY

Email address: data@ventientenergy.com

Changes to this privacy notice

We keep this privacy notice under regular review. Accordingly, we may update this privacy notice at any time. Should we update, amend or make any changes to this privacy notice, those changes will be posted on our website.

Website – third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy or privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

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 collect your personal data when you visit our website or when you contact us or communicate with us, or when it is otherwise necessary for us to collect or use your personal data in the course of the operation of our business or as part of our wider community engagement activities. We may collect, use, process, store and transfer different kinds of personal data about you, which can be grouped as follows:

  • Identity and Contact Data: includes your personal or professional contact information and/or other personal identification information, such as your name, last name, title, gender, job role, employer name, email address, telephone number and address;
  • Financial and Transaction Data: includes, where appropriate, details about payments to and from you in the course of the operation or our business or engagement and also a record of your bank account and payment card details;
  • Usage and Technical Data: includes information about how you use our website and other data such as internet protocol (IP) address, your login data, 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 our website;
  • Communications Data: includes details of any communications with you, your communication preferences, any communications which relate to you, and any feedback, responses, comments, or opinions provided by you.
  • Marketing Data: includes your preferences in receiving marketing from us.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage and Technical Data to calculate the percentage of users accessing a specific website 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.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data, Financial and Transactions Data, Communications Data, and Marketing Data and Financial Data by corresponding / communicating with us by post, phone, email, in person or otherwise.
  • Automated technologies or interactions. We will automatically collect Usage and Technical Data about your equipment, browsing actions and patterns as you interact with our website. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy [INSERT LINK] for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties, such as analytics providers, search information providers, and providers of technical, payment and delivery services. We may also receive personal data about you from publicly available sources such as Companies House.

If you fail to provide data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, a contract with an individual landowner or service provider). In this case, we may have to cancel a service or we may be unable to enter into the contract, but we will notify you if this is the case at the time.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although in certain circumstances we may seek to obtain your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of some of the ways we plan to use your personal data and the legal bases we rely on for these processing activities. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
Administering and protecting our business and our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. Identity and Contact Data
Usage and Technical Data
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Using data analytics to improve our website and user experience and to improve our marketing and communications activities. Usage and Technical Data Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
If you are (or work for) a contractor or service provider:
Managing our relationship with you and your organisation, including but not limited to reviewing and responding to any communications with you in relation to the supply of your services, and performing our obligations under the contract with you, e.g. processing / making all necessary payments owed to you.
Identity and Contact Data
Communications Data
Financial and Transaction Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure the efficient and effective management of our contracts with service providers or contractors)
If you are (or work for) a business partner:
Managing our relationship with you and your organisation, including working with you and communicating with you in relation to relevant projects, business opportunities and community engagement activities.
Identity and Contact Data
Communications Data
Financial and Transaction Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to generate potential business opportunities, to develop and grow our business, and to participate in wider community engagement activities)
If you work for a public authority:
Managing our relationship with your organisation, including communicating with you in relation to any relevant decision, application, review, appeal, investigation, consultation, proposal, and /or contract that may affect our business and/or community engagement activities.
Identity and Contact Data
Communications Data
(a) Necessary for our legitimate interests (to engage effectively with public authorities in relation to decisions which have an impact on us, our assets, our projects, the operation of the business, and/or community engagement activities).
(b) Necessary to comply with a legal obligation
If you are a landowner:
Managing our relationship with you, including communicating with you in relation to granting rights to property or resolving / addressing issues at or nearby our sites, complying with our legal obligations in relation to use / occupation of our sites, and performing our obligations under our contract with you, e.g. processing / making all necessary payments owed to you.
Identity and Contact Data
Communications Data
Financial and Transaction Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to engage effectively with landowners (including neighbouring landowners) in order to resolve / address any issues which may have an impact on our sites)
(c) Necessary to comply with a legal obligation
If you are a stakeholder:
Managing our relationship with you, including but not limited to reviewing and responding to any communications with you in relation to any projects, business activities, or community engagements activities that may involve you or affect you or your interests in any way, and providing you with news / updates on any relevant developments.
Identity and Contact Data
Communications Data
Necessary for our legitimate interests (to engage effectively with stakeholders and keep them up-to-date with any relevant news / developments on aspects of our projects, business activities and/or community engagement activities that may have an impact on them)
Responding to you when you call us, when you email us, or when you contact us via our website or any other means, including responding to any queries, enquiries, complaints, and/or expressions of interest in relation to our projects. Identity and Contact Data
Communications Data
Necessary for our legitimate interests (to operate our business effectively, and to respond to all queries, enquiries, complaints, and/or expressions of interests that we receive from time to time)
Initiating or engaging in communications with you in relation our business (including our projects and asset management activities) or our community engagement activities. Identity and Contact Data
Communications Data
Necessary for our legitimate interests (to operate our business effectively, manage our assets and projects, and to engage effectively with the wider community)
Sending marketing or promotional communications to you with news, updates and/or recommendations about our business or community engagement activities. Identity and Contact Data
Marketing Data
(a) Consent
(b) Necessary for our legitimate interests (to develop and grow our business and to promote our wider community engagement activities)

Marketing

You will receive marketing communications from us if you have requested information from us or if have provided consent to the receipt of marketing communications from us and you have not opted out of receiving that marketing. Where appropriate, and in accordance with the requirements of the EU GDPR and the UK GDPR, you may receive marketing communications from us where this is necessary for the purposes of our legitimate interests in developing and growing our business and/or promoting our wider community engagement activities, and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Change of 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 obtain 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.

Cookies

This website (www.ventientenergy.com) uses cookies to store information about visitors’ preferences, to record user-specific information on which pages the site visitor accesses or visits, and to personalise or customise our web page content based upon visitors’ browser type or other information that the visitor sends via their browser.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

HOW WE SHARE YOUR PERSONAL DATA

We may share your personal data with the following categories of third parties where it is necessary to do so for the purposes of the operation of our business or wider community engagement:

  • Internal third parties, such as other companies within our corporate group.
  • External third party service providers, including providers of IT services, cloud / hosting services, system administration services, and payment processing services.
  • External third party professional advisers, including lawyers, surveyors, financial advisers, bankers, auditors and insurers.
  • Local authorities / councils, HM Revenue & Customs, regulators, and other relevant public authorities.

We also may share your personal data with 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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We aim not to transfer your personal data outside the United Kingdom (UK) or European Economic Area (EEA). However, if an external third party (e.g. third party supplier of IT services) is based outside the UK or EEA, the supply of services by the external third party may involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented.

Please contact us if you would like further information on the appropriate safeguards used by us when transferring your personal data out of the UK or EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please contact us if you require further details of retention periods for different aspects of your personal data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have legal rights under data protection laws in relation to your personal data.

You have right to:

  • Request access to your personal data (commonly known as a “data subject access request”) – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data – this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data – this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data – you can exercise this right 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing your personal data – this enables you to ask us to suspend the processing of your personal data in the following circumstances: (i) where you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; or (iv) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • Request transfer of your personal data – we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to withdraw consent – you can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Please contact us if you wish to exercise any of the rights set out above.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Regulators

Please note that under the UK GDPR you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). To the extent that the EU GDPR applies to our processing of your personal data, you have the right to make a complaint at any time to a supervisory authority in the EEA. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or any supervisory authority, so please contact us in the first instance.

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