1. Introduction and General Terms
PassivSystems Limited (“we” or “us”) is committed to protecting personal information collected from you when you are using our products and services or PassivLiving™, our secure online monitoring and management dashboard (www.passivliving.com). We want our services to help you better manage your home energy systems.
- What information we may collect about you;
- How we will use information we collect about you;
- When we may use your details to contact you;
- Whether we will disclose your details to anyone else;
- Your choices regarding the personal information you have provided to us, or that we have generated about you and your household’s energy use;
As set out above, we are committed to safeguarding your personal information. Whenever you provide such personal information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the data protection laws.
PassivLiving™ may from time to time contain links to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information that you submit or is collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
2. What information will we collect about you?
Use Data: We collect data either via an in-home hub (the PassivHub), which is connected to your router and uses a broadband connection, or via a GSM meter/SIM data packet. This data is used by us to monitor and manage the systems (for example heating/hot water/Solar PV) within the home and is stored on our systems and those of any subcontracted parties. This may include your occupancy schedule, the times you use energy, how you use your household appliances, your lighting and heating, the energy efficiency of your home and the amount of energy generated from Solar PV installations.
If you open an account with us, this data is also analysed and presented back to you on PassivLiving™, our online secure monitoring portal. In addition, if your PassivSystems’ product is provided to you by a third party service provider, the data is analysed and presented to this third party through PassivLiving™ in the form of a monitoring dashboard. This “use” data is kept strictly private and confidential by PassivSystems, and held and processed in accordance with the data protection laws.
Personal Information: When you sign up to participate in or receive a service from PassivSystems or register with PassivLiving™ we may ask for personal information about you. This can consist of information such as your name, e-mail address, postal address, telephone or mobile number. Different webpages may ask for different personal information. By entering your details in the fields requested, you enable us and our service providers to provide you with the services you select.
- Information that you provide – When you sign up for a PassivLiving™ Account we ask you for personal information. We may combine the information that you submit under your account with information from other PassivSystems’ services or third parties in order to provide you with a better experience, and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of such processing of information.
- Log information – When you access PassivSystems’ services via a browser, application or other client, our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a service, Internet Protocol Address (IP Address – a number that can uniquely identify a specific computer or other network device on the internet), browser type, browser language, the date and time of your request and one or more cookies (see section 13a) that may uniquely identify your browser or your account.
- Location data – PassivSystems’ services relate to your home, and as such if you use those services, PassivSystems will receive information about your actual location i.e. post code so that we may obtain local weather information.
- Unique application number – Certain services include a unique application number that is not associated with your account or with you. This number and information about your installation (e.g. operating system type, version number) may be sent to PassivSystems when you install or uninstall that service or when that service periodically contacts our servers (for example, to request automatic updates to the software).
Sensitive Personal Data: Please note that sometimes on particular webpages we will require you to provide additional personal information, which may include sensitive personal information. When we do this we will specify further on those webpages why we are collecting your information and how we will use it.
IP Address: We use the IP address of systems connecting to our system to assist with prevention of data security breaches. We may also use your IP address to determine where you are and adapt the service for you to access the services from the UK or otherwise.
3. How will we use the information we collect about you?
We will use your personal information for a number of purposes including the following:
- To analyse your household’s energy use, to monitor elected systems for underperformance that could lead to a triggering of a service call, advise you how you might use your household appliances, heating and lighting more efficiently, and changes you may need to make to your home to reduce your energy consumption;
- For service administration purposes, which means that we may contact you for reasons related to the service you have signed up for (e.g. to provide you with password reminders, or to notify you that a particular service has been suspended for maintenance);
- To personalise the way our content is presented to you;
- IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and
- To analyse and improve our products and services and the service offered on PassivLiving™, e.g. to provide you with the most user-friendly experience.
Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above. PassivSystems processes personal information on our servers in the United Kingdom.
4. When will we contact you?
We may contact you:
- In relation to the functioning of any service you have signed up for in order to ensure that we can deliver the services to you;
- Where you have opted to receive further correspondence;
- In relation to any contribution you have made to PassivLiving™, or any information provided to you, PassivSystems or a third party you have contracted with through a PassivSystems product
- To invite you to participate in surveys about our services; and
- For marketing purposes where you have specifically agreed to this (see paragraph 5)
Local pages will give you detailed information about how we will contact you in relation to specific services.
5. Will I be contacted for marketing purposes?
We may contact you (by phone, mail or email), for marketing purposes or to promote new services to you. By providing your details to PassivSystems you are consenting to the receipt of such communications. If you wish to stop such communications, please contact PassivSystems at the address given at the end of this document.
6. Will we share your personal information with anyone else?
In order to use the PassivSystems products and services you have purchased you will have provided the reseller or supplier who supplied that product to you with your consent to provide PassivSystems with your personal information. We only share this personal information with other companies or individuals outside PassivSystems if we have your consent. We require opt-in consent for the sharing of any sensitive personal information. Otherwise we will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies).
Generally, we will only use your information within our company. However, sometimes we use third parties to analyse and process your information. We will require these third parties to comply strictly with our instructions and we will require that they do not use your personal information for their own business purposes.
We may share ‘anonymised’ information (such as statistical data which does not refer to any individual specifically), with other parties for example for the purposes of product enhancement.
7. Offensive or inappropriate behaviour
If you post or send offensive, inappropriate or objectionable content anywhere on or to PassivLiving™, or otherwise engage in any disruptive behaviour on PassivLiving™, we may use your personal information to stop such behaviour. Where we reasonably believe that you are or may be in breach of any of the laws of England or Wales, we may use
your personal information to inform relevant third parties such as your employer, school, e-mail/Internet provider or law enforcement agencies about the content and your behaviour.
8. What if I am a user aged 16 or under?
If you are aged 16 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our website. Users without this consent are not allowed to provide us with personal information.
9. How long will we keep your personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with us or our corporate retention schedule (this is a database that defines which documents should be kept and for how long). In the case that you wish to cancel your registration as a PassivLiving™ subscriber, once an account is deleted a flag goes on the database and, while people cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted.
Where Personal Data relating to your household is sent to PassivLiving™ we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. Some projects may have a longer, or even permanent, duration such as collating statistical data about product and energy use.
To keep your system working we monitor local weather along with the heating system of your home and its performance. This data will allow us to also notify you if we spot a fault with your system, and if we do, we will endeavour to contact you. If you don’t wish to continue this system functionality after your service agreement with PassivSystems ends, please contact us and let us know.
10. Can I find out what personal information you hold about me?
Under the Data Protection Act you have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. We charge £10 for information requests and will require you to prove your identity with 2 pieces of approved photographic identification. We will use reasonable efforts to supply, correct or delete personal information about you on our files.
11. What if I am accessing the website outside the UK?
passivsystems.com and www.passivliving.com are published in the UK by PassivSystems Limited.
Data Protection Officer, PassivSystems Limited, Benyon House, Newbury Business Park, Berkshire RG14 2PZ