Privacy Policy

WEBSITE PRIVACY POLICY

 

About SMAP Energy

 

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 committed to the protection your privacy and 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 directions of 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 do not prohibit any use or collection, by any entity of this website data or digital traffic information. 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

Our website does not have cookies and we do not knowingly permit the use of cookies on our website. In order to protect your privacy we advise that cookies setting be manage 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 principles in Japan. CV’s 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 but longer where it is required for legal purposes.

 

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 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 of the EU we follow the recommendations of the Applicable law 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 include::
Enechange Inc./SMAP Energy (Japan incorporated entity)

CKLG Accountants

Harper James Solicitors

KPMG (or other auditors, investors, etc.)

Google

 

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.

 

Information Security

The security of your personal data is our priority. We ensure personal data encryption standards and information protection protocol is following for the storage and or transfers of personal data.

 

Personal Data Rights

Those who submit personal data are entitled to rights about that data. These are called ‘subject access rights’ and entitle the subject of personal data to have access, a copy of, amend, delete (within the scope of law permitting) and transfer personal data. They are within reason permitted to do so free of charge. The formal process to access your personal data is formatted as subject access request and will be accepted in writing to the details below. In order to establish your right to this your own data we will ask for proof of identity and accept a digital or paper copy of a driving license or passport before furnishing the request. We will respond to these requests within 30 days. Where we no longer hold personal information or are unable to comply with any subject access request we will respond informing you of the grounds where we are unable to comply with the full or any part of requests we receive.

Subjects are entitled to make complaint in the UK to the Information Commissioners Office (ICO) with respect to any mismanagement of their personal data. Further details can be found at the Information Commissioners website https://ico.org.uk/

 

Contact Information

You may contact us about the details of this Privacy Policy or for a copy of our Data Protection policy by sending us an email to info@smapenergy.com or by writing to our postal address on this website and addressing the letter to the Data Protection Officer.

 

This Policy

This policy was last update on October 4th, 2018 and will be reviewed and may be updated from time to time.