SWSM understands the importance of protecting the personal information you provide to us or we receive on your behalf from third parties. This policy sets out what personal information we hold, the appropriate safeguards we put in place to protect your information and the rights available to you in relation to this information.
Who are we
SAVE WATER SAVE MONEY LIMITED is a limited company incorporated and registered in England with the company number 06106360.
Where identified, SWSM manages the Site on behalf of your supply Water Company. Your Water Company and SWSM will be Joint Controllers of your Personal Data (data controller and joint controllers having the meaning set out in the Data Protection Act 2018 and the General Data Protection Regulation) in respect of any personal data you may provide to SWSM through the Site or in connection with it.
Where there is no Water Company identified, then SWSM is the data controller. We have notified the Information Commissioner's Office of our processing activities and registered as a data controller (Registration number: Z2258879).
By 'Personal Data' or 'Personal Information' we refer to information collected or held by SWSM, that identifies and relates to you as an individual.
Extent of cover
Data Protection Officer
SWSM appoints a data protection officer who coordinates Data Protection management across the entire company and can be contacted by writing to:
The Data Protection Officer
Save Water Save Money
Or emailing: email@example.com
We collect the following information from visitors to the Site:
Information you provide SWSM with, i.e. information you enter on the Site, when you place an order or book a home visit;
When you communicate with us for customer service or other purposes (e.g. by emails, phone calls, tweets, etc.), we retain such information and our responses to you in the records of your account;
Information collected automatically, i.e. what kind of browser you are using, which device you are accessing the Site, your IP address, purchase history, Savings EngineTM data, cookies, session information.
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests, needs and behaviour. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the questionnaire or survey.
Use of personal information
We process personal information collected via the Site for the purposes of:
- Responding to your requests and communicating with you;
- Sending you the products you have ordered;
- Identifying customers who have completed the Savings EngineTM;
- Identifying subscribers;
- Carrying out customer and marketing research;
- Improving the Site;
- Providing you with information about products and services offered by or on behalf of SWSM or your Water Company if you request it;
- If you have requested a free home visit, we shall forward your contact details and address to third party engineers who shall carry out the visit and also to your Water Company for their own reporting purposes;
- Where you have agreed to, create a link between your information and your Water Company records. Applies to participating Water Companies only;
- Including into SWSM's own database anonymised data on your water usage;
- We will disclose your personal information to your Water Company for the purposes of them reporting to their regulator, OFWAT (the Water Services Regulation Authority), and where you agree to be contacted directly by your Water Company;
- We compare our customer list with lists from your Water Company in order to limit the number of messages sent to our customers.
You are not under any obligation to provide us with your Personal Information for marketing purposes.
When we send you marketing emails, we rely on your consent to contact you for marketing purposes. Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them. You can withdraw your consent to process Personal Data at any time by emailing firstname.lastname@example.org.
We do not sell personal information collected or use your personal information for any other purposes than those stated above.
Lawful basis of processing
We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the services you have requested from SWSM via the Savings EngineTM platform and unless stated, all of the above processing is conducted under the legal basis of performance of a contract.
We will only use your Personal Information 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 we consider the new purpose to be incompatible with the original purpose of collection, we will conduct a Privacy Impact Assessment or contact you to request your consent for further processing. 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 at email@example.com
Sharing your personal information
We may use carefully selected sub-processors to help us collect, store or manage your information.
Where you've have agreed to receive marketing information, we may use a third party to provide you with these updates and promotions.
If you have requested an item to be despatched to you from our depots, we will share your details with courier companies solely for the purposes of guaranteeing your requested delivery.
We may share information with your Water Company in order to provide you with the correct service relevant to your specific area of the country and water usage needs.
If you have requested a service that requires the use of a professional to administer the service, we will provide them with the details they need to attend your residence and carry out the work.
We may also provide information to a statutory body when under a legal obligation to disclose your personal data to them.
If SWSM is acquired by a third party, Personal Data held by it about its customers will be one of the transferred assets. We process your Personal Data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Data in this way, the relevant seller or buyer of our business may not be able to provide services to you.
We do not transfer any of your information outside of the EU (please see 'Security')
Retaining your personal data
We will only retain your personal data for as long as is necessary to perform the purpose for which it was collected. 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.
As standard we erase all customer data after 6 years from the point of our last transaction unless required by statute to retain for a longer period.
Personal data and your rights
You have rights in relation to any information we hold about you. If you wish to access your personal information you may make a formal subject access request by contacting SWSM.
The information you request must relate to you or another person that you have authority to act on their behalf. SWSM will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, SWSM reserves the right to refuse your request for access to personal information.
The rights you have in relation to the personal data we hold regarding you are:
The Right to Object
You have the right to object to us handling your Personal Information when:
- we are handling your Personal Information based on our legitimate interests. If you ask us to stop handling your Personal Information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Information should continue; and
- where we use your Personal Information for marketing purposes. If you ask us to stop handling your Personal Information on this basis, we will stop.
Right to Rectification
You have the right to require us to rectify any inaccurate Personal Information we hold about you. You also have the right to have incomplete Personal Information we hold about you completed, by providing a supplementary statement to us.
Right to Restriction
You can restrict our processing of your Personal Information where:
- you think we hold inaccurate Personal Information about you;
- our handling of your Personal Information breaks the law, but you do not want us to delete it;
- we no longer need to process your Personal Information, but you want us to keep it for legal reasons; or
- we are handling your Personal Information because we have a legitimate interest you and are in the process of objecting to this use of your Personal Information.
Where you exercise your right to restrict us from using your Personal Information, we will then only process your Personal Information when you agree, except for storage purposes and to handle legal claims.
Right to Data Portability
You have the right to receive the Personal Information we hold about you in a structured, standard machine readable format and to send this to another organisation controlling your Personal Information.
Right to Erasure
You have the right to require us to erase your Personal Information which we are handling in the following circumstances:
- we no longer need to use your Personal Information for the reasons we told you we collected it for;
- where we needed your consent to use your Personal Information and you have withdrawn your consent;
- you object to our use of your Personal Information and we have no compelling reason to carry on handling your Personal Information;
- our handling of your Personal Information has broken the law; or
- we must erase your Personal Information to comply with a law we are subject to.
Right To Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Please send your request to SWSM (please email: firstname.lastname@example.org). We will respond to your request within one month.
Right to Complain
You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).
SWSM’s newsIf at any time you no longer wish to receive any of our e-bulletins, newsletters or other information for which you have subscribed via the Site, some of which is intended to ensure you keep the information we hold about you on the Site maintained and up to date, then please contact at us at email@example.com
If you have any questions or complaint regarding how SWSM has handled your personal information, please don't hesitate to contact us at firstname.lastname@example.org
Last updated: July 2019