Victory Energy will keep your data secure and treat it with respect at all times, we are transparent about what we do and aim to handle your data fairly and lawfully at all times. This statement explains how we will collect, use, transfer and store your personal data.
It is likely that we will update this notice from time to time in order to reflect changes in the law and/or to our privacy practices, but we will notify you of any significant changes. Our website will always show the most up to date version.
WHO IS RESPONSIBLE FOR YOUR DATA?
We refer to 'Victory' in this statement, which is the brand name of Victory Energy Supply Limited. Victory is the 'data controller' for your personal data. This means that we have legal responsibility for how we collect and handle your data.
HOW YOU CAN CONTACT US:
We can be contacted by any of the following methods:
Address: Victory Energy Supply Limited, 1 Guildhall Square, Portsmouth PO1 2GJ
WHO DOES THIS STATEMENT APPLY TO?
- Customers and prospective customers
- Individuals, sold traders, partnerships and companies (to the extent that the relevant company provides us with any personal data- for example employee names and email addresses)
- People who we wish to market to
- People who contact us on social media
- People who visit our website
THIRD PARTY LINKS
WHAT PERSONAL DATA DO WE COLLECT?
DATA WE COLLECT FROM YOU INCLUDES:
This may include name, date of birth and contact details such as your address email address and telephone number. We need this information in order to enter a contract with you.
This may include any health or disability issues. We collect this data as part of our Licence Obligations and record it in a Priority Services Register so that we can tailor our service to meet your needs and ensure your safety. We will only add your details to the Priority Services Register with your consent, which can be removed at any time. The Priority Services Register is shared with key industry partners, such as the network providers, to ensure that they are aware that there is a special need, for example in the event of a power cut.
We will need your bank details if you want to pay by direct debit. If you are having trouble paying our bills, information about your personal financial circumstances can help us work with you to develop a payment plan that works for you.
We will need to have information about your supply such as the meter reference numbers and meter type. This helps us make sure you are billed correctly and keeps industry databases up to date.
If you have a SMART meter it will transmit data that lets us know it is working correctly.
We will record the amount of energy you use and when you use it so that we can bill you accurately. You have a contractual obligation to provide us with details of your energy usage. If you have a SMART meter we will take usage information directly from your meter.
We will collect information relating to internet protocol (IP) address, your account login data, 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 this website.
PROFILE AND USEAGE DATA
We will collect information relating to your account including account number, username, and password. We will also collect information relating to your usage of our website and services and we may collect geographical and location data or information about property types.
MARKETING AND COMMUNICATIONS DATA
We will collect information relating to your preferences in receiving marketing from us and your communication preferences.
WHAT DATA MAY WE COLLECT FROM OTHER PEOPLE OR ORGANISATIONS?
Data such as your name and contact details (such as your home address, email address and telephone numbers) may be provided to us by people moving in or out of a property you're occupying, or the landlord or estate agent managing the property.
METERING AND DEBT INFORMATION
We may obtain metering and debt information from other organisations involved in supplying or managing your energy, such as your previous energy supplier or meter operators who act as agents for us and other suppliers in reading your meter.
PUBLICLY AVAILABLE DATA
Publicly available data is available from sources such as the Land Registry, who can provide up to date information about properties we supply. Information such as additional contact details, home moving status and other information about your circumstances is provided by councils, postal services and data brokers.
WHAT DO WE USE YOUR PERSONAL DATA FOR?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data unless we process special categories of personal data (includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your health and genetic and biometric data). We only use this data where we are required to do so for legal or regulatory purposes or where it is necessary for a specific service we are providing to you and will obtain your explicit consent to process this data. You have the right to withdraw consent at any time by contacting us.
MANAGING YOUR CONTRACT
We will process your data for the following purposes necessary to manage our contract with you, or in readiness for such contracts:
- To provide you with a quotation and agree a contract with you
- To set up your account with us, secure energy supply, apply the correct pricing, process consumption data, calculate charges and send invoices
- To manage discrepancies in supplier identity or meter readings with previous or subsequent suppliers
- To process payments, refunds and set up payment plans
- To communicate with you and anyone you authorise to speak to us
- To organise and conduct visits to you to read or inspect your meter, ensure it is working correctly, change your meter, survey your property and commission installations
- To investigate and manage disputes with you are recover unpaid bills
- To fulfil incentives that we have offered
ENSURING YOUR SAFETY
We will process your data with your explicit consent, if you have vulnerabilities. We will ask for your explicit consent to add your details to our Priority Services Register, which enables us to take extra steps to ensure your safety. You have the right to withdraw consent at any time by contacting us. If we believe that someone is at imminent risk of harm, we may alert the Police or Social Services to check everyone's safety.
MEETING OUR LEGAL OBLIGATIONS
Our Licence Conditions and OFGEM directions and codes require us to manage your account in certain ways. We have a legal obligation to comply with these conditions. Examples of these include the information that we include on our bills, information that we provide to you and management of disputes. We may be ordered by a Court for example to disclose information to law enforcement agencies.
WHERE WE HAVE A LEGITIMATE INTEREST
In deciding what is a legitimate interest, we will ensure that our interest has been balanced against your rights and freedoms as an individual.
These may include:
- For good governance, accounting, managing and auditing our business operations so that our business is effective and performs well
- Keeping records of our dealings with you, so that we have an accurate history of our relationship with you in case of disputes
- Monitoring and recording our conversations with you, for example to prove you've agreed a contract with us, to help train our staff or to help us give better service.
- To manage our bad debt risk, including taking legal action against you if you do not pay our bills, because we are entitled to try and enforce our rights
- Analysing your energy consumption so that we can offer you tariffs that suit your circumstances and give you tailored energy efficiency advice to help you save money
- To develop, test and improve the products and services we provide
- For research and insight purposes, to enable us to provide good customer service.
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
There are various circumstances where we may need to share your data with other people or organisations. These are:
- Energy market administrators: These include Xoserve for gas, ECOES for electricity and the Meter Point Administration Service. We use these services to check that your meter is correctly registered against your address.
- Network Distribution Companies: These are the companies that own and operate the network. They need your information so that they keep you informed about reconnecting your energy supply if there is a loss of supply or an emergency
- Meter agents and sub-contractors: These are the companies that we use to install and maintain your meters, and to periodically read your meters.
- SMART DCC Ltd who manage the data and communications network connecting smart meters to ourselves and other industry suppliers to ensure consistency between suppliers
- Energy Suppliers and other organisations to deal with a switch between suppliers
- Other energy suppliers, landlords or housing associations if we or another organisation suspect the property is associated with fraud or theft. We also contribute to the Theft Risk Assessment service operated by Experian.
- Agents appointed by OFGEM to test meters suspected of being faulty.
- Other people authorised by you such as family members, solicitors, and debt management companies so that we can fulfil your requirements
- Debt collection agencies and other organisations assisting us with debt recovery (e.g. bailiffs, courts, private investigators and our solicitors)
- Social services, the Police, distribution services or other similar agencies if we believe you need extra emergency help
- Market regulators such as OFGEM and the Energy Ombudsman, where we are obliged to do so under regulations
- Law enforcement organisations working on the detection, investigation and prevention of crime and enforcement of legislation
- Energy Services contractors for installations and maintenance of such as boilers and solar panels
- Financial organisations for purposes such as payment processing and refunds
- The Department of Business Energy and Industrial Strategy and OFGEM to register your FIT installation (where applicable) and other FIT licensees if you want to transfer your generation unit under the FIT scheme.
- Credit Reference Agencies (CRAs): When you join us, buy an additional product or service or set up a direct debit for the first time, we will ask you for your consent to share your details with our preferred credit reference agency to check your identity and see if you may have any problems paying your bills. This means that we will share your personal data with them and they will give us information about you in order that we can be sure about who we have a contract with and see if you may have problems paying your bills. More information is set out in a Credit Reference Agency Information Notice which describes how call credit share and use personal data. The notice can be accessed here. We also share your data with service partners we engage to assist us with things like IT, telephony, bulk mailing, print and mobile application platforms.
COMMUNICATING WITH YOU
With your consent, we would like to communicate with you in person, by email, text, letter, telephone, social media and via our website. This may be about products and services, promotions, special offers and discounts that we think you may be interested in (we call this marketing). We will respect your choices in how you wish us to communicate with you in relation to marketing and you may withdraw your consent at any time.
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. Please note that where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service you have engaged us with.
We may send you letters or call you without your prior agreement when we have a legitimate interest in doing this. Our legitimate interest might be:
- Understanding our customer and getting to know their preferences
- Telling our customers about products that might meet their needs and desires
- Ensuring our customers are aware when they can save money
We have accounts on certain major social media channels and use their public platforms to manage our social media interactions. We don't have any control over how these companies use any data shared with us through their services, and we recommend you review their privacy notices yourself. We'd also remind you that any information you post publicly is visible to anyone. If we know you are a Victory Energy customer and you send us personal data using a private or direct message via social media that data will be stored along with your other account records in line with our standard data retention period as detailed below.
VISITORS TO OUR WEBSITE
By using our website, you are allowing us to collect and use the information you gave us for the purposes of your visit or as explained to you.
RIGHTS OF ACCESS TO YOUR PERSONAL DATA
You can find out if we hold any personal data about you, and access that data, by making a 'subject access request' under the Data Protection Act 2018. If we do hold your personal data, we will provide you with a copy and information about what we do with it. Unless you ask us to provide it in a different way, we will email this to you where you have given us an email address. You can request access to the data we have about you by contacing us on email@example.com.
If you only want to see certain items and you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone or email.
If you have given us consent to process your personal data, you have the right to withdraw that consent at any time by contacting us. If you have an online account with us, you can also make changes to that preference in your account. You can request that we correct any mistakes, restrict or stop processing your data, or delete it. It is worth noting that in some cases if you do ask us to correct, delete or stop processing it, we won't always be required to do so. For example, we may need to continue in order to service your account in line with our contract. If this is the case we will explain why.
If you are unhappy with any aspect of how we handle your personal data you also have the right to contact the Information Commissioner's Office (ICO), the supervisory authority that regulates handling of personal data in the UK. You can contact them by going to their website (here) or by phoning them on 0303 123 1113 or writing to them at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please email us at firstname.lastname@example.org us using the contact details listed at the beginning of this policy.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
STORING YOUR DATA
If you have an account with us, we will retain your personal data for seven years following the end of our contractual relationship with you (which might be when we issue your final bill or when your account closes). There may be circumstances when we need to keep it for longer, for instance, if you are on a long-term payment-plan or to meet our legal obligations, but we will delete it as soon as we have no need to keep it for any longer.
If we hold your data for any other reason, we will delete it as soon as we no longer have a valid reason to retain it. 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, regulatory, tax, accounting or other requirements.
KEEPING YOUR DATA SAFE
When you log into your online account or ask us for a quote, our website pages are secure, which means that all personal details that you type in are encrypted before they're sent to us. We store and use all personal information securely, so it can't be read by anyone who doesn't need to see it.
When we ask other organisations to help us provide services and manage your account, we have appropriate contracts in place, which limits their use of your data to only what we have asked them to do. We provide only the information they need to perform their specific services and we work closely with them to ensure that your privacy is respected and protected at all times. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
All of your data is hosted and stored in the UK and it not transferred outside of the European Economic Area (EEA).