WEBSITE PRIVACY POLICY (Updated July 2020)
About SMAP Energy Limited
SMAP Energy Limited (‘We’) are a company incorporated in England and Wales under Company Number 09986974 with a registered office at 9 Quy Court, Colliers Lane, Stow-Cum-Quy, Cambridge, CB25 9AU. We are committed to protecting your privacy while you use this website and or engage with our services via this website. We are registered as Data Controllers with the Information Commissioners Office in the UK under registration ZA218526.
This website policy was drafted in accordance with the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and Privacy in Communication regulations (PECR) as amended (Applicable law).
Why we collect personal data
The reasons why we may collect personal data depends on how, where and why you engage with the company or services on this website. Where we collect personal data we comply with applicable law to ensure your privacy.
We may collect personal data during the course of our business or for operational purposes. We will respond to enquiries submitted on this website or collect personal data where submitted for a job application. You might ask to connect with us about our services or on social media platforms. We are permitted to process your data where you have provided your consent, where we enter into a contract with you or there is a legitimate expectation from communications or circumstances that we will make contact with you or where we are required to do so by law. We may use any of these lawful grounds to process your data.
Using this website
We do not collect digital information from users and do not store your IP or digital usage of the website when browsing or using this website. We expressly prohibit any unknown party use of this website to collect any personal data about the users of our website or business services.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. In order to protect your privacy we advise that the ‘cookies setting’ be managed on your device privacy settings.
How we collect personal data
We collect personal data during the course of our normal business activity. The types of personal data we collect include, name, email, address, CV and HR data and also Right to Work Information which we are obliged to collect by UK law. HR data submitted to us in the UK may be processed by our group principal in Japan. CVs submitted by electronic means either via this website or through an external website (LinkedIn, etc.) are not retained by us for the period longer than it takes to assess the candidate or for legal purposes. We retain some HR data for a period of 6 years or longer where it is required for legal purposes.
We (or third parties on our behalf) automatically collect data about your equipment, browsing actions and patterns as you use our website. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
How long we keep data
We are obliged to retain Right to Work data necessary for compliance with immigration law for the statutory period of 2 years or longer from a data of application where necessary. Employment records and financial records are retained in accordance with statutory retention periods.
Who we share data with
We only share data for the purposes of conducting our business where it is needed by service support providers (listed below) to support our operations. We do not process any personal data for the purposes of marketing and do not knowingly share or permit personal data with any of our business support providers for this purpose. We ask all of our business support providers who may, store, access, or process personal data on our behalf to sign a processing and data privacy agreement to direct how we want them to process personal data on our behalf. Where data is processed outside the EU we follow best practice to ensure we meet adequacy standards for transferred data.
| These groups from time to time may hold, interact with, or enable access to data collected under this policy: |
| Enechange Inc./SMAP Energy (Japan incorporated entity)
KPMG (or other auditors, investors, etc.) |
International data transfers
SMAP Energy is registered and incorporated in the UK. It is an international subsidiary of ENECHANGE Limited with a Corporate registration number: 0106-01-047805 and registered address of 2-6-2 Otemachi, Chiyoda-ku, Tokyo. Some personal data is transferred and processed by our parent company in Japan. Japan for the purposes of European data protection and privacy has robust privacy protections for EU personal data and meets the adequacy test of set by the EU and European Data Protection Agencies. This means any personal data transferred to Japan will be protected by the same standards and security as data processed in the European Union.
Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows:
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.