Welcome to the privacy policy for SmartGen Technology. This policy outlines how we
collect, use, and protect your personal data when you interact with our websites,
[www.smartgentechnology.com], and the SmartGen app, as well as your rights regarding
your data under UK law.
By using our app, websites, or services, you agree to the practices described in this policy.
1. Introduction
At SmartGen Technology, we are committed to respecting your privacy and safeguarding
your personal data. This privacy policy aims to provide clear information about how we
handle your personal data, your rights concerning that data, and how you can exercise
those rights.
SmartGen Limited, registered in England and Wales under company number 14816415,
operates and owns SmartGen Technology. Our registered office is located at Direct Save
House, Tolpits Lane, Watford, England, WD18 9RS. SmartGen Limited serves as the data
controller responsible for the processing of your personal data.
2. How to Contact Us
If you have any questions or concerns about this privacy policy or your personal data, please
feel free to contact us:
Full name of legal entity: SmartGen Limited
Email address: contact@smartgentechnology.com
Postal address: Direct Save House, Tolpits Lane, Watford, England, WD18 9RS
3. The Personal Data We Collect from You
Personal data, or personal information, refers to any data about an individual from which
that person can be identified. This does not include data where the identity has been
removed (anonymous data). SmartGen Technology may collect, use, store, and transfer
various kinds of personal data about you. We have categorized these as follows:
• Contact Data: This includes your email address and telephone numbers that you
provide us during the registration process or when communicating with us.
• Log-in Details: This refers to your username and password, which are used to access
your account on the SmartGen app and websites.
• Identity Data: This includes your name, physical address, and any credit or bank card
details that you provide us for transactional purposes.
• Household Information: This includes details about your household, such as the
number of occupants, information about the size of your home, and specific features
like roof details that might be relevant to our services.2
• Energy Usage Data: This pertains to information retrieved from your smart meter,
including your energy consumption patterns, the energy supplier you have selected,
the cost of your energy usage, and your property’s supply point reference number
(MPAN).
• Technical Data: This includes your 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 our websites and app.
• Usage Data: This refers to information about how you interact with our websites and
the SmartGen app, such as the pages you visit, features you use, and other
engagement metrics.
• Marketing and Communications Data: This includes your preferences in receiving
marketing communications from us and your communication preferences, such as
how you prefer to be contacted.
We use this personal data to enhance your experience with our services, provide tailored
recommendations, and ensure we meet our legal obligations. The types of data we collect
may vary depending on your interaction with our services, but we are committed to
collecting only the data necessary to achieve our stated purposes.
4. Social Media Interaction and User Conduct
Our platform includes social media features that allow users to communicate directly with
one another. While we encourage positive and constructive interaction, we have
established the following guidelines to maintain a respectful environment:
• Respectful Communication: Users must engage with others respectfully and
constructively. Harassment, bullying, or any form of abusive behaviour will not be
tolerated.
• Prohibited Content: Users must refrain from sharing illegal, offensive, or
inappropriate content. This includes content that is defamatory, obscene, or
promotes illegal activities.
• Privacy Protection: Users must not share personal information of others without
consent, including names, addresses, or contact details.
• Content Removal and Account Suspension: SmartGen reserves the right to remove
content that violates these guidelines and suspend or terminate accounts
responsible for such violations.
If you experience or witness abuse on our platform, please report it to us immediately at
contact@smartgentechnology.com.
5. Legal Basis for Processing Personal Data
We will only process your personal data when we have a legal basis to do so. This includes:
• Consent: When you have given us clear consent to process your personal data for a
specific purpose.3
• Contractual Necessity: When processing your data is necessary for the performance
of a contract with you or to take steps at your request before entering into such a
contract.
• Legal Obligation: When we need to process your data to comply with a legal
obligation.
• Legitimate Interests: When processing is necessary for our legitimate interests (or
those of a third party), and your interests and fundamental rights do not override
those interests.
We will only use your personal data for the purposes for which it was collected unless we
reasonably consider that we need to use it for another reason that is compatible with the
original purpose. If a different purpose arises, we will notify you and explain the legal basis
for processing your data.
6. Data Minimisation
SmartGen Technology is committed to data minimisation. This means we only collect the
personal data that is necessary to provide our services effectively. We regularly review our
data collection practices to ensure they are in line with this principle.
7. Data Security and Retention
We have implemented robust security measures to protect your personal data from
unauthorised access, use, or disclosure. Access to your data is limited to employees, agents,
and contractors who have a legitimate business need to know.
Your personal data is retained only as long as necessary to fulfil the purposes for which it
was collected, including legal, accounting, or reporting requirements. If your account
remains inactive for 24 months, we may terminate your account and delete your data unless
legally required to retain it.
8. Profiling and Automated Decision-Making
In some cases, we may use your personal data for profiling or automated decision-making.
This helps us to better understand your preferences and provide tailored services. However,
if these processes have a legal or significant impact on you, you have the right to object or
request human intervention. Please contact us if you wish to learn more about how we use
profiling and automated decisions.
9. Data Breach Notification
In the unlikely event of a data breach, we have procedures in place to notify you and any
relevant supervisory authority, such as the Information Commissioner’s Office (ICO), where
we are legally required to do so. If a breach poses a high risk to your rights and freedoms,
we will notify you directly without undue delay.
10. Your Rights Regarding Direct Marketing4
You have control over how we use your personal data for marketing purposes:
• Opting In: You can choose to receive marketing communications from us when you
sign up for our services or subscribe to our newsletter.
• Opting Out: You can opt out of marketing communications at any time by contacting
us at contact@smartgentechnology.com.
• Third-Party Marketing: We will only share your data with third parties for marketing
purposes with your explicit consent.
11. Your Rights Under Data Protection Laws
You have several rights concerning your personal data, including:
• Access: You can request access to the personal data we hold about you. We aim to
respond to all legitimate requests within one month.
• Correction: You can request that we correct any inaccurate or incomplete data.
• Erasure: You can request the deletion of your personal data, subject to certain legal
obligations.
• Restriction: You can request that we limit the processing of your data in specific
circumstances.
• Data Portability: You can request that your data be transferred to another party.
To exercise any of these rights, please contact us at contact@smartgentechnology.com. We
may need to verify your identity before fulfilling your request.
12. Third Parties We Share Your Data With
We work with selected third parties to deliver our services. These third parties act as data
processors on our behalf and are contractually obligated to protect your data. We may
share your data with:
• Service Providers: Hosting providers, IT service providers, and other entities that
support our services.
• Payment Processors: Third parties that facilitate payments and verify your identity.
• Smart Meter Data Providers: Third parties that help us collect and process data from
your smart meter, with your consent.
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 data for specified purposes in accordance
with our instructions.
13. Cookies and Automated Data Collection
Our websites use cookies and similar technologies to improve your experience. Cookies help
us understand how you interact with our services and allow us to enhance your user
experience. You can manage your cookie preferences through your browser settings. For
more details, please refer to our Cookies Policy.
14. International Data Transfers
Your data is stored within the European Economic Area (EEA). If we need to transfer your
personal data outside the EEA, we will ensure appropriate safeguards are in place to protect
your data, such as European Commission-approved contracts or, where applicable, the EU
US Privacy Shield framework.
15. Compliance with GDPR
SmartGen Technology is fully compliant with the General Data Protection Regulation
(GDPR). We are committed to upholding your rights under this regulation and ensuring that
your personal data is processed in accordance with the highest standards of security and
transparency.
16. Glossary of Terms
• Data Controller: The entity that determines the purposes and means of processing
personal data.
• Data Processor: The entity that processes personal data on behalf of the data
controller.
• Personal Data: Any information relating to an identified or identifiable natural
person.
17. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy from time to time. If significant changes are made, we
will notify you via email or through a notice on our websites and app. Please review this
policy periodically to stay informed about how we are protecting your data.
Last updated: 12th August 2024.
