Outfox The Market, a subsidiary of Bastian plc, is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This policy sets out the following:
What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
Where we obtain the data from;
What we do with that data;
How we store the data;
Who we transfer/disclose that data to;
How we deal with your data protection rights;
And how we comply with the data protection rules.
All personal data is collected and processed in accordance with English and EU data protection laws.
Bastian Plc Group (also referred to as ’we’, ’us’, ’our’ or ’Bastian Plc’) in this policy primarily refers to the operating corporate group to which at the time of this policy includes the companies Foxglove Energy Supply Ltd [trading as Outfox the Market], Fischer Future Heat and Ekorad. Bastian Plc Group is the “data controller” of all personal information that is collected and used by the above group companies and brands for the purposes of the UK Data Protection Bill and the EU General Data Protection Regulation (GDPR). Bastian Plc is registered as 10972150 at address Northbridge Place, Frog Island, Leicester, Leicestershire, United Kingdom, LE3 5DH.
Personal data: means any information relating to you which allows us to identify you, such as your name, contact details, customer account/reference number, payment details and information about your access to our website.
We will collect personal data from you when you sign up with us (either directly or indirectly through our trusted third party partners), create an Online Account, use our website and/or other websites accessible through our website, participate in a survey or competition, or when you contact us or register interest.
Specifically, we may collect the following categories of information:
Contact data (your name, email address, postal address, phone number, date of birth, gender and any other relevant information we need in order to contact or identify you);
Financial data (your bank account and payment details relating to products and services you receive from us);
Technical data (internet protocol (IP) address, your login data (including your Online Account username and password), browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We track technical data by cookies, please see the section below for more information.
Usage data (information about how you use our website, products and services) including information about your purchase of our trusted partners’ products and services;
Marketing and communications data (your preferences in receiving marketing from us and our third parties and your communication preferences);
Energy supply data (this is your supply start date, meter technical details, tariff and when you have a smart meter installed at your property we’ll also capture your energy consumption data; and
Special categories of data (health and financial vulnerability data, if applicable, to include you on the Priority Services Register).
We also use aggregated data, in order to improve our operations and ensure we are providing you with the best service possible. It’s really important that the personal data we hold about you is up to date so please let us know if your personal data changes at any time.
When will we collect it?
We and our agents collect certain personal information from and about you during your sign up journey and when you get in contact with us or use our website or as part of providing our services to you. This could be though us directly or through another Bastian Plc Group company.
We may also monitor and record any communications we have with you, including phone calls, emails, web chats, letters and social media exchanges to make sure we are providing an excellent service to our customers. We may contact you by telephone, web chat, email, post or in person as necessary.
Your data may be used for the following purposes:
Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your contract and account. These communications are not made for marketing purposes and cannot be opted-out of;
Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your contract with us and to personalise the services we offer to you, such as special offers or deals;
When you first provide your personal information to us, we will use Legitimate Interest as the legal basis to process your data. We may use your identity, contact, usage and profiled data to tell you about exciting new products and services from us and our related businesses in the wider Bastian Plc Group (or they may contact you directly). We collect data through our websites (own brand and third party), direct marketing, contact centres and national advertising. You may be contacted by email, post or telephone.
If you decide you want to opt-out of receiving marketing communications or want to change how you receive them, you can always change your preferences by contacting us at any time. This won’t affect any marketing information we sent to you before you let us know.
Processing your Data
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for. In most cases we will need to process your personal data so we can enter into our contract with you.
We may also process your personal data for one or more of the following:
To comply with a legal obligation;
You have consented to us using your personal data (e.g. for marketing related uses);
To protect your vital interests or those of another person;
It is in our legitimate interests in operating as a company (e.g. for administrative purposes and marketing related uses).
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Who do we share your data with?
Government authorities and regulators for compliance with legal requirements;
Complaints bodies such as the Energy Ombudsman, Citizens Advice Bureau, Extra Help Unit, Trading Standards and other mediatory bodies which you may use, in order to for your complaint to be handled.
Trusted service providers we are using to run our business such as metering operators, engineering services, industry data collection and aggregation, IT and system administration, price comparison sites and cloud service and e-mail marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns;
Credit and debit card companies and debt collection agencies, which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction;
Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
Disclosing information outside the EU
Sometimes the organisations listed above may be outside the EU, so we may pass your personal information to countries that do not have the same standards or protection for personal information as the UK. If we, our agents or our service providers do this, we will try and ensure that these organisations adequately secure your personal information.
We may also ask your previous energy supplier for personal information about you that will allow us to take over your supply (for example, information about your meter readings, meter technical details etc.). Similarly, if you switch away from us, we may provide similar information to your new supplier so they can begin supplying your energy.
Energy Priority Services Register or special needs
If we believe that you (or a member of your household) need extra care (for example, because of your age, health, disability or financial circumstances) and we have your explicit consent to do so, we may record and share this information with the following people to ensure your supply isn’t interrupted:
other energy suppliers if we believe you are considering changing supplier;
an outsourced service company that manages a wide range of energy industry data interactions on our behalf;
the electricity distributor; and the relevant gas transporter, metering agents or network operator.
Your personal data will be shared with the Department for Business, Energy and Industrial Strategy (BEIS) to support administration of the Energy Bills Support Scheme (EBSS). These data consist of your meter point number, whether you have received and redeemed each EBSS payment and data about your meter point including your billing cycle and how you pay your bill.
BEIS is collecting and processing this information under the ‘Public Task’ (UK GDPR, Article 6(1)(e)) legal basis. Processing is necessary for monitoring, assurance, fraud prevention and evaluation purposes of HM Government’s Energy Bills Support Scheme. This task is carried out in the public interest and in the exercise of official authority vested in the Secretary of State for BEIS.
For further information, please find below the link to the gov.uk website for the Notice on Use of electricity meter data collected through the Energy Bills Support Scheme: privacy notice.
Protecting your personal information
We follow strict security procedures to protect your personal information. This includes following certain guidelines (for example, checking your identity when you phone us).
We strongly recommend that you do not disclose any Online Account login details to anyone. Please always remember to logout of your account when you have finished using any of our websites.
From time to time, our website may provide hypertext links to sites which are created by individuals and companies outside of Bastian Plc Group. We do this if the site is relevant to the topic you’re reading about. Whilst we always try to check that the content of these sites is suitable, we cannot take any responsibility for the practices of the companies who publish the sites that we link to, or the accuracy or relevance of the content on them.
We understand the importance of taking extra precautions to protect the privacy and safety of children. You must be over 18 to sign up and have a contract with us, therefore anyone under this age should not have access to any Online Account operated by us. We will delete any Online Account created by a person under the age of 18, as soon as are made aware of it.
When our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time by contacting us and requesting this.
We keep your personal information contained in your Online Account until such time you request it is erased. Please note that general retention periods apply to any personal data we collected to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.