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Privacy Policy | Switch365: Your Business Energy Comparison Guide

We are Switch 365 Ltd, incorporated in England and Wales with registered office address Unit 18 Blackpool Technology Management Centre, Faraday Way, Blackpool, FY2 0JW. Our company number is 08166557, and we are committed to protecting and respecting your privacy. We are registered with the Information Commissioner's Office ("ICO") under registration number ZA022978

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us on our website, Switch365.com. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. When you provide your personal data to us, you are deemed to have read this privacy notice and to have accepted the terms set out herein.

1. Important Information and Who We Are
We are the controller and responsible for your personal data. We trade under the name Switch 365 Ltd. Our full contact details are: Switch 365 Ltd Unit 18 Blackpool Technology Management Centre Faraday Way Blackpool FY2 0JW

Alternatively, you can email our data protection officer at: crystal.paraskeva@switch365.com Questions, comments, and requests regarding this privacy notice are welcomed by using the contact details above.

Please note that you have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

2. Changes to our privacy notice

We keep our privacy notice under regular review to ensure that it properly reflects our use of your personal data. We may make periodic changes to our privacy notice in the future, please check this page for any updates on your next visit to our website. This privacy notice was last reviewed and updated on 17th April 2024. It is important that the personal information we hold about you is accurate and current. Please let us know if any personal information which we hold about you needs to be corrected or updated at any time.

3. How we collect personal data
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 use different methods to collect personal data about you, and there are different ways that we might do so. This privacy notice tells you what to expect when we collect personal data via the following methods:

Visitors to our website;

Anyone who interacts with us (including via our online advertising) or contacts us through social media; and

anyone who uses our website;

This privacy notice also explains the types of personal information we collect from you, and the lawful basis we rely on under data protection legislation to use your personal data. Under data protection legislation, we are only permitted to use your personal data if we have a lawful basis for doing so as set out in the data protection legislation. Where we rely on our legitimate interests (or those of a third party) as the lawful basis for processing, we have done so on the basis that our legitimate interests (or those of a third party) do not override your interests and fundamental rights. This is called the "balancing test" and you have the right to ask us for information on the test that has been undertaken, by using the contact details above. We explain in the below table why we consider processing is necessary for our legitimate interests.

3.1 Visitors to our website

We develop our website (https://switch365.com/) in collaboration with Ravenware, a third- party web development company. All personal data collected about your visit to our website is handled internally by our employees and Ravenware. You can rest assured that all our employees and Ravenware staff receive training on data security, and we take the protection of your personal data seriously. Ravenware acts as a processor on our behalf and is bound by contractual obligations to handle your data securely and in accordance with data protection laws.

End-User Analytics and Cookies

We will collect details of your visits to our websites, including traffic data, location data, weblogs, and other communication data, and the resources you access on our website. We also collect information about your device and your visits to and use of our site, including, where available, your device's IP address, geographical location, operating system, referral source, browser type, length of visit, and number of page views. We will collect this information for the purposes of system administration, optimizing the use of our site, and reporting aggregate information to third-party suppliers. This is statistical data about our users' browsing actions and patterns and does not identify any individual. To the extent this data constitutes your personal data, we explain in the below section the lawful basis we rely upon to process such data.

In particular, we use an analytics service provider for website traffic analysis and reporting and to track information such as which browser, screen resolution, and IP address you are using to access our website, in addition to tracking your movements around our website. Please see section 3.3 for more details on how we use this information. Please note that we do use cookies on our website. More information on how we use cookies can be found in our Cookies Policy. This section ensures transparency regarding Ravenware's involvement in website development and clarifies their role as a processor for Switch 365 Ltd's website.

3.2 Social media

Any information you provide to us via social media (including messaging, "liking" or "following" and other communications) is controlled by the relevant social media network. Our website contains links to our social media pages. We currently use: Facebook - Its privacy notice can be located here We recommend that you read their privacy notices and contact them directly if you have any concerns regarding their use of your personal data. We recommend that you read their privacy notices and contact them directly if you have any concerns regarding their use of your personal data.

3.3 Using our website

Our website enables you to submit your details to us. We will collect personal data from you when you complete a form on our website or when you contact us by email. The table below sets out the categories of personal data we collect from you, the purposes for which we use your personal data and the lawful basis we rely upon for processing your personal data:

Category of personal dataPurposeLawful basis of processing
Title, first name, surname, email address, telephone number, mobile number, address, To share your data with our partners to enable them to provide you with a price comparison It is in our legitimate interests to use this information to be able to deliver our service and to provide Category of personal data Purpose Lawful basis of processing services you are interested in
Any other personal data you provide us withTo ensure that content from our website is presented in the most effective manner for you and your deviceIt is in our legitimate interests to study how customers use our products/services, to develop them and to grow our business
Any other personal data you provide us withTo ensure that content from our website is presented in the most effective manner for you and your deviceIt is in our legitimate interests to study how customers use our products/services, to develop them and to grow our business
Title, first name, surname, email address, telephone number, mobile number, address and IP address; andTo enable us to effectively administer, develop, support and improve our website and improve your browsing experience by personalising our websiteIt is in our legitimate interests to study how customers use our products/services, to develop them and to grow our business
Any other personal data you provide us withTo enable us to effectively administer, develop, support and improve our website and improve your browsing experience by personalising our websiteIt is in our legitimate interests to study how customers use our products/services, to develop them and to grow our business
Title, first name, surname, email address, telephone number, mobile number, and address; andTo enable us to provide customer services in relation to our website and to deal with enquiries and complaints made by or in relation to our customersIt is in our legitimate interests to investigate and resolve your enquiry or complaint
Any other personal data you provide us withTo enable us to provide customer services in relation to our website and to deal with enquiries and complaints made by or in relation to our customersIt is in our legitimate interests to investigate and resolve your enquiry or complaint

We may also use your personal data for analytical purposes. Where this takes place, your personal data will be anonymised as far as we are able to do so for this purpose, and we rely on our legitimate interests to tailor our service, grow our business and to inform our marketing strategy.

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.

3.4 PPC advertising

From time to time, we use “pay per click” advertising to target potential website users and customers. You may have accessed our website by clicking on one of our online adverts displayed by Google or other search engines. PPC advertising allows us to bid for ad placements in a search engine’s “sponsored” links, which appear when you search for keywords that relate to our business.

In this case, we rely on legitimate interests as our lawful basis to process your personal data, as it is in our interests to increase brand awareness and target customers and website users that we think would be a great fit for our services.

3.5 Subscribing to our marketing

If you are interested in our products and services, we will provide you with a clear choice to consent to receiving marketing promotional material, updates, reminders and communications by giving you an opt-in to receiving such communications. If you have provided your consent we will collect your contact details (name, postal address and email address) to provide you with such communications. You have the right to withdraw your consent at any time. For full details on how to withdraw consent please see above.

If you ever decide you no longer wish to receive our marketing communications, you can opt out at any time by unsubscribing from the mailing list, using the link provided in the marketing communications email, or by using the contact details above. If you do unsubscribe, please note that we will still keep your email in a separate secure list so that we can make sure that you do not receive our marketing communications again in the future.

4. What happens if you do not provide the personal data that we request?

We will need some of your personal data as a necessity in order to provide you with our services or contact you and follow up with you in respect of any query or complaint you have submitted on our website. For example, we need to know your personal contact details in order to identify you and contact you.

Where information is needed for these purposes, if you do not provide it we will not be able to provide you with our services, or contact you and follow up with you in respect of the query or complaint you have submitted on our website. We explain this is the case at the point where we collect this information from you.

5. Your data and third parties

We use third parties to provide services to us from time to time. We will share data with them where it is in our legitimate interests for our business administrative needs. A list of third parties that we use and how they process personal data is set out in the table below. Please note that these third parties are located within the UK or the European Economic Area, unless otherwise stated below

Third partyWhat data?Why do we share this data?How long is this data kept by this third party?
Cloud hosting service providersTitle, first name, surname, email address, home number, mobile number, business postcode (if this is also your home address) and any other personal data you provide to usHosting of our servers and all of our customer data.We are responsible for deleting your personal data from the servers of our cloud hosting service providers in accordance with sections 3.3 above.
Electronic waste recycling service providersTitle, first name, surname, email address, home number, mobile number, business postcode (if this is also your home address), IP address and any other personal data you provide to usTo dispose of our hardware where we longer use itThe hardware received by these providers are securely wiped of any personal data on receipt before the hardware is recycled.
6. Disclosure of your information

We will not usually disclose your personal data other than as already explained in sections 3 and 5 above. However, there may be circumstances where we need to share personal data other than as anticipated in sections 3 and 5 above. These include:

where we are legally required to disclose the information. This includes sharing the personal data with tax authorities and law enforcement agencies for the purposes of the prevention and detection of crime;

where we need to disclose the personal data for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights; disclosure is required to protect our interests, or someone else's interests (for example, to prevent fraud or credit risk reduction);

disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance);

it is to a third party for the purposes of providing administrative or processing services on our behalf. If such disclosure is required we will take steps to ensure that the third party protects the personal data in the same way that we do and notify you of any changes to this privacy notice; and to any prospective purchaser of our business assets or organisation.

7. Keeping your personal information secure

We know that you provide your personal data in good faith and expect it to be looked after. This is why we take the security of your personal data seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal data. This includes: locating all personal data that we control on servers located in the United Kingdom and EEA. Aside from this, we do not transfer personal data outside of the UK; ensuring strict access controls to your personal data on a need to know basis and monitoring such access to customer personal data; encryption of the personal data on our website and all electronic transactions using SSL technology; and where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential, together with any login details and/or user details. We ask you not to share your password, login or user details with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and prior to us receiving it. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access including those measures set out above.

8. Automated Decisions

We do not currently undertake any automated decision making on our website.

9. Your rights

You have rights in respect of your personal data and this section explains a bit more about those rights that are applicable to how we use your personal data, and the circumstances in which you are able to exercise these rights. If you would like more information about any of your rights, please contact us on the details set out above.

9.1 Accessing your personal data

We want you to fully understand and be comfortable with how we use your personal data. You can contact us at any time to ask whether we process any personal data about you. If we do hold or use your personal data in any way, you have the right to access that personal data. All we ask is that: if you’re able to do so, you make your request to access in writing to the contact details above; if we ask you to do so, you verify your identity; and note if your request is clearly unfounded, repetitive or excessive, , we may charge an administrative fee for processing any further requests or alternatively we could refuse to comply with your request. We will notify you prior to incurring an administrative fee. Please allow us up to one month from receipt of your request (or verification of your identity, whichever is the later) in order to provide you with our response.

9.2 Requesting more information

We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal data. We have tried to be as clear and as open as we can and will continue to update this privacy notice as our use of personal data develops. However, if you have any questions regarding our use of your personal information, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details above.

9.3. Additional rights

You also have some additional rights that you may exercise as set out below. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses above and provide verification of your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to exercise any of the below 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. 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.

You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address).

You have the right to request that we erase your personal data. Please be aware that we can only comply with such a request if your personal data is no longer required for the purposes it was collected for (for example, we need your personal information to respond to a communication or query); the collection, storage or use of the personal information by us is prevented by law; your personal data is not required for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings.

You have the right to request that we restrict or refrain from processing your personal data: for the time it takes us to verify the accuracy of your personal data where you have disputed its accuracy; where the collection, storage or use of the personal data by us is unlawful but you decide not to ask for erasure; where, we no longer need your personal data but you need them for the purposes of establishing, exercising or defending a legal claim; for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal data, where you have exercised your right to object to processing. You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into a contract (contractual necessity). If you exercise this right, we will transfer a copy of the information that you have provided to us at your request. You have the right to object to our use of your personal data: where we are using that information based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal data; at any time, where we use your personal data to send you marketing, in which case it will no longer be used for that purpose, but we may use it for another lawful purpose; or where we have made a decision about you using automated decision making. You have the right to withdraw your consent at any time where we have collected your personal data based on your consent. Please note that this will not affect the lawfulness of any processing based on your consent prior to you making such withdrawal.

Making a Complaint

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745

crystal.paraskeva@switch365.com