Privacy Policy

Welcome to Loop’s privacy policy. This privacy policy applies your use of our website www.loop.homes 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 when you visit our website and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. If anything is not clear please contact us – we don’t want there to be any confusion.

 

  1. Who we are and how to contact us
  2. Purpose of this privacy notice
  3. How is your personal data collected?
  4. The personal data we collect from you
  5. How we use your personal data
  6. Direct Marketing
  7. Recruitment
  8. Cookies
  9. Keeping your personal data up to date
  10. Third parties we use and share your personal data with
  11. International transfers
  12. Data Security
  13. How long will we keep your personal data for?
  14. Your legal rights
  15. Changes to the Privacy Policy

 

  1. Who we are and how to contact us

Loop is owned and operated by Trust Power Limited, trading as ‘Loop’. We are a limited company registered in England and Wales under company number 10144503). Our registered office is at Second Floor, 13 Berkeley Street, London, United Kingdom W1J 8DU. Trust Power Limited s the controller and responsible for the personal data we collect through your use of our website and the Loop app.

Please contact us if you have any questions about this privacy notice 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, Second Floor, 13 Berkeley Street London, United Kingdom, W1J 8DU

  1. Purpose of this privacy notice

Trust Power collects and processes your personal data through your use of our website www.loop.homes and the Loop app.

This website is 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 notice supplements the other notices and is not intended to override them.

 

  1. 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 website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • signing up to use the app;
    • carrying out a price comparison;
    • apply for a job or submit a job application;
    • subscribe to receive our updates;
    • request marketing to be sent to you; or
    • make a general enquiry.
  • Automated technologies or interactions. As you interact with our website, 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.
  1. 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 follows:

  • Identity Data includes names 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
  • Energy usage includes information about your energy usage including patterns of usage, the energy supplier you have chosen, the cost of your energy usage
  • 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 this website.
  • Usage Data includes information about how you use our website and the loop app.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Recruitment Data includes details from your CV or job application that you submit to us.

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.

 

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

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

 

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.

 

  1. 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.

 

  1. Recruitment

Our parent company, the Oxygen House Group, may, from time to time, assist with our recruitment process. We may transfer any Identity Data, Contact Data and Recruitment Data you have provided to us in any enquiries, applications or CVs submitted by you in connection with any vacancies advertised by Trust Power (whether via our website or otherwise) to Oxygen House, who will store your personal data in our applicant tracking system, Recruitee, and only use your personal data for the purposes of our recruitment process. Your personal data may also be disclosed to any of our directors, employees or professional advisers who are involved in our recruitment process.

Your personal data will be retained by us for 6 months following the relevant vacancy being filled.  Once this period has elapsed, your personal data will be permanently deleted unless you specifically ask us to keep your application for longer to consider you for other opportunities.

In the event that you are unsuccessful for the role in respect of which you have submitted an application and where you have provided consent to do so via the recruitment process, we may consider you for other appropriate opportunities within our group and, in the event that such opportunities are identified, your personal data may be shared with, and used by, other companies within our group (and their directors, employees or professional advisers) for recruitment purposes only. You may withdraw your consent to this data sharing at any time by contacting us.

If you apply to us via a third party such as a recruitment consultant then they may be the controller of your personal data also and you should refer to their privacy policy to find out how they handle your personal data.

 

  1. Cookies

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 this website may become inaccessible or not function properly. Where necessary we will also obtain your consent to use cookies. For further information about we use cookies, see our cookies policy.

 

  1. 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.

 

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

We may have to share your personal data with the parties set out below for the purposes set out in ‘How we use your personal data’. We may share you information with the following entities:

  • If you decide to switch energy supplier after carrying out a price comparison on the Loop app, we will provide your details to your new chosen energy supplier.
  • Companies within our group of companies. This does not apply to information provided by you with us in connection with Trust Power’s recruitment process, which is covered under “Recruitment”.
  • 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.
  • Law enforcement agencies where we are required to do so by law.

Our domestic online energy comparison and switching service is supported by our trusted Partner, Fundraising Innovations Ltd (company number 04426857), trading as energyhelpline (registered address – The Cart Wagon Lodge, Friday Street Farm, Friday Street, East Sutton, Kent, ME17 3DD) who processes data securely and in line with Data Protection regulations.

As Data Controller the Partner is responsible for capturing the information you enter into a switch application in order to forward it to your chosen supplier, to enable them to set up your new energy account(s). Once your data is passed to your chosen supplier they will process it in line with their Privacy Policy, which we are not responsible for.

Our domestic telephone based energy comparison and switching service is also provided by our trusted Partner, Fundraising Innovations Ltd (company number 04426857), trading as energyhelpline (registered address – The Cart Wagon Lodge, Friday Street Farm, Friday Street, East Sutton, Kent, ME17 3DD) who processes data securely and in line with Data Protection regulations.

As Data Controller the Partner is responsible for capturing the information you enter into a switch application and forwarding it to your chosen supplier in order for them to set up your new energy account(s). Once your data is passed to your chosen supplier they will process it in line with their Privacy Policy, which we are not responsible for.

For further information on how your data is processed please refer to the Partner’s Privacy Policy on their website.  You can find the Partner’s Terms & Conditions here and their Privacy Policy here.

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.

 

  1. 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.

 

  1. 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.

 

  1. 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, 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.

 

Specific information about how long we keep recruitment data is set out in the “Recruitment” section of this privacy notice.

In some circumstances you can ask us to delete your data: see “Request 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.

 

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

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.

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 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.

Your rights explained

You have the right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you.

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.

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.

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.

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.

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.

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.

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.

 

15. Changes to the Privacy Policy

This version was last updated on 24th September 2019. We may change this policy from time to time and when we do 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 website.