Privacy Policy

Last updated: December 2024

1. Introduction

Impliciarl Energy Solutions Ltd ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website impliciarl.com, use our services, or otherwise interact with us.

This policy applies to all information collected through our website, mobile application (if applicable), and any related services, sales, marketing, or events (collectively, the "Services").

2. Information We Collect

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Register for an account
• Subscribe to our newsletter
• Request information about our services
• Contact our customer service
• Apply for energy supply services
• Participate in surveys or competitions

The personal information we may collect includes:

• Name and contact information (address, email, phone number)
• Date of birth and identification information
• Financial information (bank details, payment information)
• Energy usage data and meter readings
• Property information
• Communication preferences

2.2 Automatically Collected Information

When you visit our website, we may automatically collect certain information, including:

• IP address and location information
• Browser type and version
• Operating system
• Pages visited and time spent on our website
• Referring website addresses
• Device information

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information about our use of cookies, please see our Cookie Policy.

3. How We Use Your Information

We use the information we collect for various purposes, including:

3.1 Service Provision

• Processing your energy supply applications
• Managing your account and billing
• Providing customer support
• Processing payments and managing debt
• Meter reading and energy usage monitoring

3.2 Communication

• Sending service-related communications
• Providing newsletters and marketing materials (with consent)
• Responding to inquiries and support requests
• Sending important updates about our services

3.3 Legal and Regulatory Compliance

• Complying with legal obligations and regulations
• Reporting to industry bodies and regulators
• Preventing fraud and ensuring security
• Conducting credit checks and risk assessments

4. Legal Basis for Processing

Under the UK GDPR, we process your personal information based on the following legal grounds:

• Contract: Processing necessary for the performance of a contract with you
• Legal obligation: Compliance with legal requirements and regulations
• Legitimate interests: For our legitimate business interests, such as improving our services
• Consent: Where you have given explicit consent for specific purposes

5. Information Sharing and Disclosure

We may share your information in the following circumstances:

5.1 Service Providers

We may share information with third-party service providers who perform services on our behalf, including:

• Payment processors and financial institutions
• IT service providers and data hosting companies
• Customer service and call center providers
• Marketing and communications agencies
• Debt collection agencies

5.2 Industry Participants

As part of the energy supply business, we may share information with:

• Network operators and distributors
• Other energy suppliers (during switching processes)
• Industry databases and central systems
• Regulatory bodies and government agencies

5.3 Legal Requirements

We may disclose information where required by law, regulation, or legal process, or to protect our rights, property, or safety, or that of others.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication measures
• Staff training on data protection
• Incident response procedures

However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Factors we consider in determining retention periods include:

• Legal and regulatory requirements
• Contractual obligations
• Business needs and legitimate interests
• Your consent and preferences

8. Your Rights

Under UK data protection law, you have several rights regarding your personal information:

8.1 Right of Access

You can request a copy of the personal information we hold about you.

8.2 Right to Rectification

You can request that we correct inaccurate or incomplete information.

8.3 Right to Erasure

You can request deletion of your personal information in certain circumstances.

8.4 Right to Restrict Processing

You can request that we limit how we use your information in certain situations.

8.5 Right to Data Portability

You can request a copy of your information in a structured, machine-readable format.

8.6 Right to Object

You can object to certain types of processing, including direct marketing.

8.7 Right to Withdraw Consent

Where processing is based on consent, you can withdraw consent at any time.

To exercise any of these rights, please contact us using the details provided in Section 11.

9. Marketing Communications

We may send you marketing communications about our products and services if you have consented to receive them or where we have a legitimate interest to do so. You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in our emails
• Contacting our customer service team
• Updating your preferences in your online account

10. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

11. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

12. Complaints

If you believe we have not handled your personal information properly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator:

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided personal information to us, please contact us immediately.

15. International Transfers

We may transfer your personal information to countries outside the UK for processing. When we do so, we ensure appropriate safeguards are in place to protect your information, such as:

• Adequacy decisions by the UK government
• Standard contractual clauses
• Binding corporate rules
• Other appropriate safeguards as required by law