Introduction
Welcome to the Utility-Switch’s privacy policy.
Utility-Switch.co.uk respects your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal data when you visit our website
(regardless of where you visit it from) and tell you about your privacy rights and how the law
protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas
set out below. Please also use the Glossary to understand the meaning of some of the terms used in
this privacy policy.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Utility-Switch collects and processes your
personal data through your use of this website and the comparison services offered via this
website.
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 policy together with any other privacy policy or fair
processing policy 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 other notices and privacy policies and is not intended to override them.
Controller
Tomorrow Media Group Limited is the controller and responsible for your personal data (collectively
referred to as "Utility-Switch.co.uk", "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to
this privacy policy. If you have any questions about this privacy policy, including any requests to
exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
info@tomorrowmediagroup.com
Customer Services
Utility-Switch.co.uk C/O Tomorrow Media Group Ltd
Cali House, 3rd Floor
Vjal, ir-Rihan,
Triq tal-Balal,
San Gwann SGN9016,
Malta
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.
In Writing – The Data Protection Officer, Tomorrow Media Group Ltd, Viewpoint Block D, No.
130,
Triq Andre` Maurois, St. Julians, STJ 1575, Malta
Our UK GDPR representative is the
point of contact for all questions concerning the data protection of UK citizens and the contact
for data protection supervisory authorities. Their contact details are as
follows:
Ian Cruickshank - Lead 365 Ltd
6th Floor, Alexandra Warehouse, West
Quay, Llanthony Rd, Gloucester, GL1 2LG
dataprotection@lead365.co.uk
We keep our privacy policy under regular review. This version was last updated on 22/02/2022. 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.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We
do not control these third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about 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 to enable us to
provide you with our price comparison, switching or other services, which we have grouped together
as follows:
• Identity Data includes first name, last name, internet protocol (IP) address and postcode.
• Contact Data includes email address and telephone numbers.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our
third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data could be derived from your personal data but is not considered personal
data in law as this data will not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 policy.
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.
If you fail to provide personal data
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. 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 or by corresponding with us
by post, phone, email or otherwise. This includes personal data you provide when you:
• fill in forms on our website;
• search for a price comparison;
• enter into a contract for the supply of services;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• correspond with us by phone, email or live chat; or
• give us feedback or contact us.
• Third parties or publicly available sources. We will receive personal data about you from various
third parties as set out Technical Data from the following parties:
• analytics providers such as Google based outside the EU;
• advertising networks based inside OR outside the EU; and
• search information providers based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to.
We will obtain your consent before sending third party direct marketing communications to you. You
have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, 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.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground has
been set out in the table below.
|
Purpose/Activity
|
Lawful
basis for processing including basis of legitimate
interest
|
|
To register you as a
new customer
|
(a) Performance of a
contract with you
|
|
To provide our
services and fulfilling your requests
|
(a) Performance of a
contract with you
|
|
To manage our
relationship with you which will include:
(a) Notifying you
about changes to our terms or privacy policy
(b) Asking you to
leave a review or take a survey
|
(a) Performance of a
contract with you
(b) Necessary to
comply with a legal obligation
(c) Necessary for our
legitimate interests (to keep our records updated and to study how customers
use our products/services)
|
|
To enable you to
partake in a prize draw, competition, complete a survey, comparison
service
|
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to study how customers use our products/services, to
develop them and grow our business)
|
|
To administer and
protect our business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of
data)
|
(a) Necessary for our
legitimate interests (for running our business, provision of administration
and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise)
(b) Necessary to
comply with a legal obligation
|
|
To deliver relevant
website content and advertisements to you and measure or understand the
effectiveness of the advertising we serve to you
|
(a) Necessary for our
legitimate interests (to study how customers use our products/services, to
develop them, to grow our business and to inform our marketing
strategy)
|
|
To use data analytics
to improve our website, products/services, marketing, customer relationships
and experiences
|
(a) Necessary for our
legitimate interests (to define types of customers for our products and
services, to keep our website updated and relevant, to develop our business
and to inform our marketing strategy)
|
|
To make suggestions
and recommendations to you about our services that may be of interest
to you
|
(a) Necessary for our
legitimate interests (to develop our products/services and grow our
business)
|
|
To share your data
with third party advertisers who will send relevant adverts to you or
contact you about their products or services
|
(a) Your
consent
(b) Necessary for our
legitimate interests (to develop our products/services and grow our
business)
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We have established the following personal data control
mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 used
our services and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the
opt-out links on any marketing message sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us to enable us to provide our price comparison, switching or other services to
you.
Cookies
Cookies help websites remember you so things run smoothly. They let you add items to a shopping
basket, and they can keep you logged in to sites where you have an account.
Cookies can also be used to collect demographic information so companies can better understand the
people that use their website. Typically, they only contain two pieces of information; a site name
and a unique user I.D.
Change of purpose
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table
(Purposes for which we will use your personal data) above.
• External Third Parties as set out in the Glossary.
• 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 policy.
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.
6. International transfers
External third party service providers who may process personal data on our behalf may be based
outside the EEA so their processing of your personal data will involve a transfer of data outside
the EEA.
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:
• 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.
• 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.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. 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.
8. Data retention
How long will you use my personal data for?
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.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
In some circumstances we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data.
• [Request access to your personal data].
• [Request correction of your personal data].
• [Request erasure of your personal data].
• [Object to processing of your personal data].
• [Request restriction of processing your personal data].
• [Request transfer of your personal data].
• [Right to withdraw consent].
If you wish to exercise any of the rights set out above, please contact us.
No fee 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 could 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 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.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do not use your personal data
for activities where our interests are overridden by the impact on you (unless we have your consent
or are otherwise required or permitted to by law). You can obtain further information about how we
assess our legitimate interests against any potential impact on you in respect of specific
activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before entering into such a
contract.
Comply with a legal obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
THIRD PARTIES
Scottish Power Limited (“ScottishPower”) - registered number SC193794
whose registered office
is at 320 St. Vincent Street, Glasgow, G2 5AD.
https://www.scottishpower.co.uk/legal/privacy-policy
Utilita Energy Limited - Hutwood Court, Bournemouth Road, Chandler's Ford, Eastleigh SO53 3QB
https://utilita.co.uk/terms
Lead 365 Limited - 6th Floor, Alexandra Warehouse, Llanthony Road,
Gloucester, GL1 2LG
https://www.lead365.co.uk/privacy-policy/
DeadFastBroadBand - Cali House, 3rd Floor, Vjal ir-Rihan
Triq tal-Balal, Malta
https://deadfastbroadband.com/
iSave - Cali House, 3rd Floor, Vjal ir-Rihan
Triq tal-Balal, Malta
http://www.isave.co.uk/privacy-policy/
External Third Parties
• Service providers acting as processors based in the UK who provide IT and system administration
services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers based in the UK.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers
based in the United Kingdom.
• Third party advertisers with whom you have given your consent to us sharing your personal data for
marketing and advertising purposes.
YOUR LEGAL RIGHTS
You have the right to:
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.
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, though we may need to verify the accuracy
of the new data you provide to us.
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.
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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. 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.
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
Version 1
7th April 2022
