Privacy Policy

Welcome to Loop’s privacy policy. This privacy policy applies to your use of our websites www.loop.homes, www.loophome.app, www.trustpower.com and the Loop app. 

We respect your privacy and are committed to protecting your personal data. 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. 

By signing up to use our app, websites, or services, you are accepting and consenting to the practices described in this policy. 

For the purpose of the Data Protection Act 2018, we act as a data controller in relation to your personal data. We use data processors as listed under Section 9 who only process personal data in line with our instructions, unless it is required to do otherwise by law. 

1. Who we are and how to contact us

Loop is owned and operated by Trust Power Limited (we, our). We are a limited company registered in England and Wales under company number 10144503. Our registered office is at Stirling Square, 5-7 Carlton Gardens, London, United Kingdom, SW1Y 5AD.  

Trust Power Limited is the data controller and is responsible for the personal data we collect through your use of our websites and the Loop app. 

Please contact us if you have any questions about this privacy policy or the information, we hold about you. Our full details are: 

Full name of legal entity: Trust Power Limited 

Email address: [email protected] 

Postal address: The Privacy Officer, Trust Power Limited, Stirling Square, 5-7 Carlton Gardens, London, United Kingdom, SW1Y 5AD

2. Purpose of this privacy notice

Trust Power collects and processes your personal data through your use of our websites www.loop.homes, www.loophome.app, www.trustpower.com and the Loop app. 

These websites are not intended for children, and we do not knowingly collect data relating to children. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This privacy policy supplements the other notices and is not intended to override them.

3. How is your personal data collected?

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

• Direct interactions. You may give us personal data by filling in forms on our websites and app or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

• signup to use the app and give consent to retrieve your smart meter data;  
• carrying out a price comparison; 
• subscribe to receive our updates; 

• participate in discussion boards or other social media functions on our service; 
• request marketing to be sent to you; or 
• make a general enquiry. 

• Automated technologies or interactions. As you interact with our websites and app, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Further information about cookies can be found in our Cookies Policy.

4. The personal data we collect from 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

• Identity Data includes name, address, credit or bank card details that you provide us. 
• Contact Data includes email address and telephone numbers that you provide us. 
• Log-in Details includes your username and password 
• Household Information includes information about your household such as the number of members information about the size of your home and roof details. 
• Energy usage includes information from your smart meter about your energy usage, patterns of usage, the energy supplier you have chosen, the cost of your energy usage and your property’s supply point reference number (MPAN). 
• Technical Data includes internet protocol (IP) address, 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 these websites. 
• Usage Data includes information about how you use our websites and the Loop app. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

Aggregated data

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 

We use your energy usage to provide us with information about patterns of usage. This data is aggregated when used in this way so you would not be identifiable. We use this aggregated data to allow users to compare themselves against similar households and for our business purposes such as analysing patterns of usage to help us target our marketing and that of third parties and suggest tariffs. 

We may aggregate your Usage Data to calculate the percentage of users accessing a specific Loop app 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. 

5. 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 services 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 have your consent. 
• Where we need to comply with a legal or regulatory obligation. 

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 get 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.

6. Direct Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional communications from us when you are a Loop User 

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. 

Non-Loop Users 

If you do not use the Loop app, you may still sign up to our e-newsletter via our website. In this circumstance we will only send communications to you where we have your consent to do so. 

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any company outside of Loop for marketing purposes. 

Opting out 

You always have a right to opt out of direct marketing. You can ask us to stop sending you marketing messages at any time by contacting us at any time. 

7. Cookies

Our websites use cookies to improve your experience while you navigate through the websites. Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the websites. We also use third-party cookies that help us analyse and understand how you use these websites. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience. Further information about cookies can be found in our Cookies Policy. 

8. Keeping your personal data up to date

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 or if you move address. 

Once every 24 months will we request a revalidation of your address and consent to collect, store and process your energy consumption, generation, and tariff information. 

9. Third parties we use and share your personal data with

We use selected organisations to help us deliver the services to you. We may share your personal data with selected external third parties and may receive information about you from them, including: 

• Hosting providers, and other service providers that we use purely for the purposes of carrying out our obligations and exercising our rights; 
• Price comparison sites that we use to provide our tariff and energy price comparison service to you;
• Third parties who provide us with your Smart Meter data (provided you have asked us to obtain such Smart Meter data from them), in particular we may need to provide them with sufficient information to allow them to verify your identity and the fact that we are authorised to access your Smart Meter data;
• Third parties where you ask us to send your referral code to them, for example selected solar installers;
• We may share your personal information with any member of our company, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• 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, we will let you know. The new owners may use your personal data in the same way as set out in this privacy notice.
• Law enforcement agencies where we are required to do so by law. 

Third Party Links 

We will share your personal data with the parties set out below for the purposes set out in ‘How we use your personal data’.  

These are Data Processors. Processors act on behalf of the Data Controller and under their authority. In doing so, they serve the controller’s interests rather than their own. 

Stripe ID validation service 

With your consent, we use Stripe.com payment platform to verify your name and address using your credit or bank card for the property you are giving consent for us to collect, store and share your Smart Meter data.  

Smart meter data services 

With your consent, we use n3rgy data service (https://data.n3rgy.com) to interface with the national smart meter systems in order to collect, store, manage and share with us your Smart Meter data. This service uses the Smart Energy Code (https://smartenergycodecompany.co.uk/). You can withdraw consent at any time by contacting us. 

For further information about the n3rgy data service please refer to our Terms of Use.  

With your consent, we use Electralink data service (https://www.electralink.co.uk/) to provide real-time access to current supplier information, address confirmation, MPAN number and a subset of meter technical details. This service provider is permitted by the DTSA (as defined below) to access, copy, store and process data transmitted across the Service Provider’s data transfer network. 

“DTSA” the Data Transfer Services Agreement made up of various participants of the electricity industry initially dated September 1997 (as amended) for the provision of the Data Transfer Service. 

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. We also use external third parties who are our processors and process personal data on our behalf. This includes out IT providers and other service providers. 

10. International transfers

Our data is hosted with the European Economic Area. 

If we do need to transfer your personal data out of the EEA or UK, and it is not transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission, we will ensure protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

(a)  Use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union. If you would like to obtain a copy of these contracts you can contact us. 

(b)   Where we use service providers based in the US, we may transfer personal data to them if they are certified under the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.

11. 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. 

If you are provided with a username, password or other login details or credentials, you agree that you will always keep them safe and confidential and will immediately notify us and request a change of password if you become aware of any unauthorised disclosure, use or loss of the same. 

You’re responsible for keeping your password confidential. We don’t have access to your current password, and for security reasons, we may only provide you with instructions on how to reset your password. In addition, you represent and warrant that all information you provide to us when you establish an account, and when you access and use the Service, is and will remain complete and accurate.  

12. How long will we keep your personal data for?

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, audit or reporting requirements. 

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. 

Once every 24 months will we request a revalidation of your address and consent to collect, store and process your energy consumption, generation, and tariff information. 

If your user account is inactive for 24 or more months, we may terminate your account. Once your account is terminated, you acknowledge and agree that we will permanently delete your account and all the personal data associated with it. 

You can ask us to delete your data at any time. See ‘Right to erasure’ below for further information. 

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. 

13. Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can exercise any of these rights by contacting us. 

Right of access 

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. 

You can ask us to provide you with a copy of the information we hold about you by making a ‘Data Subject Access Request’. This enables you to receive a copy of the personal data we hold about 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. 

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. 

Right to rectification 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. 

Right to erasure 

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. However, 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.  

From within the Loop app, you can go to Settings>Account>Delete account to initiate the deletion of your account and personal data.  

Your account will be closed, your personal data including backup data will be deleted and we will stop communicating with your smart meter within 1 day.  

Alternatively, you can send a request to [email protected]. Your account will be closed within 30 days of receipt of the email, your personal data will be deleted, and we will stop communicating with your smart meter. You will receive an email confirmation once this is complete. 

Please note: We are required by the Smart Energy Code to retain a log of who provided consent for N3rgy to access smart meter(s) associated to your meter point administration number (MPAN) for auditing purposes for up to 4 years after the closure of your account. 

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. 

Right to object 

Object to processing of your personal data where 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. 

Right to restrict processing 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the certain scenarios. 

Right to data portability 

Request the transfer of your personal data to you or to a third party. 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. 

Your right to complain to the ICO 

You have the right to make a complaint at any time to the Information Commissioner’s Office (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.

14. Changes to the Privacy Policy

Updated: 20 April 2023

This policy was previously updated on 24th September 2019.  

We may change this Privacy Policy from time to time. If we make a significant change to how we use your information, we will inform you via email if you are a user of the Loop app or subscribe to our marketing emails, and a pop-up notice on our websites.