This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it and how we will keep it safe.
For the purpose of the Data Protection Act 2018, the data controller is Virtus Energy Limited.
You have the right to make a complaint at any time to the Information Commissioner’s Office (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 our Data Protection Officer in the first instance by emailing email@example.com or writing to Data Protection Officer, Virtus Energy Limited, 8 Tyers Gate, London, England, SE1 3HX.
Information we may collect from you
1. We may collect and process the following data about you:
1.1 Information you give us. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to our service or place an order for services and/or products. The information you give us may include your name, address, e-mail address, phone number, financial and credit/debit card information, and personal description.
1.2 Information we collect about you. With regard to each of your visits to our website we may automatically collect the following information:
1.2.1 technical information, including the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
1.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (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 and any phone number used to call our contact number.
1.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
1.5 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.
1.6 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 to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. Uses made of the information
We use information held about you in the following ways:
3.1 Information you give to us. We will use this information:
3.1.1 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us.
3.1.2 to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about.
3.1.3 to provide you with information about products or services where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
3.1.4 to notify you about changes to our service.
3.1.5 to ensure that content from our Website is presented in the most effective manner for you and for your computer.
3.1.6 where we need to comply with a legal or regulatory obligation.
3.2 Information we collect about you. We will use this information:
3.2.1 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
3.2.2 to improve our website to ensure that content is presented in the most effective manner for you and for your computer.
3.2.3 to allow you to participate in interactive features of our service, when you choose to do so.
3.2.4 as part of our efforts to keep our website safe and secure.
3.2.5 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
3.2.6 to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.
3.3 Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. Disclosure of your information
4.1 We may share your information with selected third parties including:
4.1.1 business partners, suppliers, and sub-contractors we work with to help us to provide our services to you. This is for the performance of any contract we enter into with them or you. This includes, where necessary, the sharing of your personal information with your chosen energy provider.
4.1.2 advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 300 women aged under 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in SE1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
4.1.3 analytics and search engine providers that assist us in the improvement and optimisation of our website: and
4.1.4 credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
4.2 We may disclose your personal information to third parties:
4.2.1 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
4.2.2 if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or
4.2.3 to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Where we store your personal data
5.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
5.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
5.2.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
5.2.3 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
5.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5.4 All information you provide to us is stored on our secure servers. Any payment transactions are protected using either Worldpay or Stripe payment platforms details of which can be accessed at https://www.worldpay.com/global/products/fraud-risk-management or https://stripe.com/gb/radar.
5.5 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; 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.
6. How long we will store your personal data
6.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
6.2 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 requirements.
6.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
6.4 In some circumstances you can ask us to delete your data: see request for erasure in the next section below for further information.
6.5 In some circumstances we may 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.
7. Your legal rights
7.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data, these are as follows:
7.1.1 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.
7.1.2 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.
7.1.3 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
7.1.4 Object to processing of your personal data:
You can object to processing of your personal data 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
7.1.5 Request restriction of processing your personal data:
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
7.1.6 Request transfer of your personal data:
If requested, 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.
7.1.7 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. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
7.2 If you wish to exercise any of the rights set out above, please contact us.
7.3 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 may refuse to comply with your request in these circumstances.
7.4 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.
7.5 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.