1.1 Our company is Labrador Ltd of 8 Greencoat Place London SW1P 1PL (“we”, “us”, “our company”). For the purpose of the Data Protection Act 1998 (the Act), our nominated representative for the purpose of the Act is Jane Lucy.
1.2 We collect personal data from your energy smart meter(s). This data is likely to relate to you as well as any other occupant in your household. We collect this at intervals more frequently than half hourly, in order to provide our service. By signing up to our service, you are opting in to this data collection.
1.3 We also invite you to add extra information about yourself on our website at www.thelabrador.co.uk. This can be referred to as “meta data” and may include your email address, property address, how many occupants are in your household, number of bedrooms, type of heating system etc.
1.4 We may also be provided with some of your personal data via our partners, industry participants and industry data flows. We will only use and retain this data in order to deliver our service. Our terms include you appointing us as your agent in relation to accessing some of this data, including industry data flows. Examples of that data include (but are not limited to) your MPAN (Meter Point Registration Number), type of smart meter you have (including firmware version), and if you have recently switched, what stage you are at in the industry Change of Supply.
1.5 We do not share your data other than as explained here. This policy may be updated from time to time but our fundamental approach to privacy is to require your consent to sharing any data that contains personally identifiable information. This means that we won’t share anything that identifies you without your permission. But we may share aggregated and anonymized data (for example, to show market wide trends) without alerting you. Our approach to anonymization is to use differential privacy.
2. What we collect
2.1 We collect data from gas and electric smart meters. What we physically collect is dependent on whether you have both of these meters installed, the type of meters (manufacturer, model), the firmware versions, and potentially what Communications Hub and Smart Meter System Operator (SMSO) is being used by your energy supplier. Given firmware upgrades may take place with your meters and Communications Hub, activated by third parties with whom we may not have a relationship with, the data we collect may change. If you would like to see an example dataset for your meter(s), please ask us by emailing firstname.lastname@example.org.
2.2 We have the potential to collect 2 second data from electricity smart meters and 10 second data from gas smart meters. We may vary the speed, frequency, and granularity of data depending on what service(s) you decide to use and our operational decisions. Those variations will be at our discretion, in order to ensure we provide you with a useful and cost-effective service. We do not propose to contact you about any variation and recommend that for privacy considerations, you assume we will be capturing 2 second electricity data and 10 second gas data at all times.
2.3 We do not collect any data from non-smart meters. Our definition of a “smart meter” is one that meets the Department for Business, Energy and Industrial Strategy’s SMETS Technical Specification.
2.4 In addition to the meta data described in our Summary above, we may also collect the usual data about when you visit our website – for example, which IP address you visit from, which web pages you visit, duration of visit etc. We may also from time to time ask you to participate in surveys in order we can get user feedback on our service(s) and we may retain your responses to such surveys. We will also record not just which of our services(s) you opt to use, but the activity around how you use them i.e. dates of service, any switching in tariffs etc.
3. Where we store your data
3.1 The data that we collect from you may be transferred to, and stored by a third party service provider.
3.2 All our data storage is within the European Economic Area (“EEA”) and processed by staff operating inside the EEA who work for us or for one of our suppliers. From time to time there may be exceptions to this when we use a third party service which does not yet offer EEA storage. Currently, they include:
3.2.2 Google (we use Google Analytics and Google Drive, we do not have a professional relationship with Google);
3.2.3 Squarespace; and
All of the above participate and are certified in their compliance with the EU-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. A list of Privacy Shield participants is maintained by the Department of Commerce and is available at: https://www.privacyshield.gov/list.
3.3 All information you provide to us is stored on our secure servers in AWS (and their data storage centre in Ireland). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
3.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot give an absolute guarantee of the security of your data transmitted to our site; any transmission is ultimately at your own risk.
3.5 We are in the process of obtaining ISO27001 certification for our security. Any delay to us obtaining this certification may relate to our service(s) being novel and that this certification does not yet have a quick precedent to reapply.
4. How we use your data
4.1 We may use information held about you in the following ways:
4.1.1 To ensure that content from our site is presented in the most effective manner for you and for your computer;
4.1.2 To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
4.1.3 To carry out our obligations arising from any contracts entered into between you and us;
4.1.4 To allow you to participate in interactive features of our service, when you choose to do so;
4.1.5 To enable us to further develop our service and products;
4.1.6 To notify you about changes to our service;
4.1.7 We may share information with credit reference and fraud prevention agencies for use in credit decisions, and for fraud detection and prevention purposes;
4.1.8 To enable us to comply with any legal or regulatory requirements;
4.1.9 We may disclose your information to any successors of our business for them to use for the purposes set out in this Privacy Notice; and
4.1.10 You may opt out of marketing emails by contacting us on our contact details at the bottom of this policy although please note that certain changes to your use of our service(s) may effect whether or not there is a fee for our service(s) and how much that fee may be.
4.2 We may share your data with our partners (such as our Price Comparison Partner) and relevant industry participants (such as we will need to share your Retriever codes with your meter installer and Smart Meter System Operator). Again this sharing is for the purposes of delivering our service and understanding how we may improve it.
4.3 We may also share your data with a product or service provider when you sign up to their product or service (for example, if you choose to switch to a new energy tariff, as part of that switch process, some of your personal data will be shared with them so that they can set you up as a new customer and ensure you’re billed off your smart meter usage data rather than estimates).
5.1 You will retain ownership of your usage data and any content that you submit, or otherwise make publicly available on or through our site (“User Content”). You grant us a perpetual, irrevocable, transferable, worldwide, royalty free and unlimited licence to use User Content in any manner and for any purpose, and a perpetual, irrevocable, transferable, worldwide, royalty free and unlimited licence to use your usage data (which will include at intervals more frequently than half hourly) for the purposes of:
5.1.1 determining which energy tariff product is most suited to your usage (which may include analysis of your usage according to time of day for the purposes of time of use tariffs);
5.1.2 providing bespoke savings advice;
5.1.3 providing bespoke energy efficiency advice;
5.1.4 providing bespoke smart home advice;
5.1.5 understanding load profiles;
5.1.6 understanding energy trends;
5.1.7 disaggregating usage to understand appliance usage and preferences (for purposes including to provide advice as how to optimise potential savings on time of use tariffs);
5.1.8 to support additional products and services that you may sign up to; and
5.1.9 to enable us to research, develop and deliver additional products and services, which may be in conjunction with a partner.
5.2 Any assets that Labrador Ltd create out of your data (such as by data analysis) shall be owned by Labrador Ltd. Those assets will use differential privacy in order to protect your identity from any third party. Labrador Ltd will never share your personal identifiable data with anyone without your permission and as covered by this policy and our terms.
6. Disclosure of your information
6.1 We do not have any subsidiaries nor a holding company but reserve the right to update this policy in order to share your data with such entities if they are formed in the future.
6.2 We also reserve the right to disclose your personal information to any external entity if that entity becomes a buyer or acquirer of our company or part of our assets.
6.3 We may also disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Labrador Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.2 Our cookies help us:
7.2.1 Make our website work as you’d expect;
7.2.2 Save you having to login every time you visit the site;
7.2.3 Remember your settings during and between visits;
7.2.4 Improve the speed/security of the site;
7.2.5 Continuously improve our website for you; and
7.2.6 Make our service(s) more efficient.
7.3.1 Collect any personally identifiable information (without your permission);
7.3.2 Collect any sensitive information (without your permission);
7.3.3 Pass data to advertising networks; nor
7.3.4 Pay sales commissions.
7.5 Turning cookies off: You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites. It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.
8. Your rights
8.1 You have the right to change your privacy consents at any time. To do so, please email us at email@example.com. However, please note that changes may mean we cannot continue to offer our service (either for free or at all).
8.2 You can request a copy of your data at any time by emailing us at firstname.lastname@example.org or by writing to us at: Attention Jane Lucy, Labrador Ltd, 8 Greencoat Place London SW1P 1PL. We may charge a fee for processing the data request.
8.3 Please note that our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
9. Changes to this policy
Last updated 18.04.17