Why this Policy exists
DNP needs to gather and use certain information and data about its customers, i.e. end-users of LiAGE’s smart battery system and its cloud platform.
We also collect and process personal data when individuals visit our websites, including any data provided through the websites (e.g. when an individual requests a survey or submits an email via our websites).
This policy describes how this personal information must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
DNP’s approach to Data Protection
The law that describes how organisations — including DNP — must collect, handle and store personal information has changed.
However, DNP’s approach to the handling of your personal information is still rigorous and is underpinned by the key principles set out below. These are that personal information must:
· Be processed lawfully, fairly and in a transparent manner
· Be obtained only for specified, explicit and legitimate purposes
· Be adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed
· Be accurate and, where necessary, kept up to date
· Be kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the personal information is processed
· Be processed in a manner ensuring the appropriate security of the personal information using appropriate technical or organisational measures
These principles apply regardless of whether personal information is stored electronically, on paper or on other materials.
Information that DNP collects and why
DNP collects information that directly or indirectly identifies you and is therefore considered ‘personal’ information or data. Personal information does not include data where your identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
Identity Information includes your title, first name and surname
Contact Information includes your telephone number, residential address, your company name (if relevant) and email address
Profile Information includes your username and password and purchases you have made from us
Usage Information includes information generated when you access our services and information relating to energy consumption and the charge and discharge of your battery system
Personal Information provided by other companies, including our partner organisations, who have obtained your permission to share information about you
Technical Information that identifies:
· the geographical location of your battery system (including latitude, longitude and geocode status) and time zone
· the type and size of your residence including the number of bedrooms
· whether you have a solar PV installation
· your EPC status
· whether you have internet or broadband
· your energy tariff
· your historical energy consumption and generation data (which we use to calculate your forecast energy consumption and generation)
We may also ask you in our surveys to provide photos of the proposed location of a LiAGE smart battery system in order for us to assess the suitability of that location.
· Financial Information includes bank account and payment card details
· Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us
· Marketing and Communications includes your preferences in receiving marketing from us and our third parties and your communication preferences
How DNP collects your personal information
We use different methods to collect information from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
· apply for our products or services including requesting a call-back;
· create an account on our websites;
· subscribe to our services or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us some feedback.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
Technical Information from the following parties:
· analytics providers;
· advertising networks; and
· search information providers.
o Contact, Financial and Transaction Information from providers of technical, payment and delivery services.
o Identity and Contact Information from data brokers or aggregators.
o Identity and Contact Information from publicly availably sources.
How DNP uses your personal information
We need to collect your information so that we can continue to provide services to you, improve these services and manage the accounts of all our customers. This includes creating statistics and carrying out data analysis.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information 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 or regulatory obligation.
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside DNP for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your Personal Information
We may have to share your personal information with the parties set out below.
External third parties – these include:
· Electrical and engineering contractors who install and maintain energy storage systems on our behalf.
· Sales agencies to whom you have consented to contact you in relation to the purchase of a product or service.
· Service providers acting as processors who provide IT and system administration services.
· Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
· Government agencies, regulators and other authorities who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
How does DNP keep your Personal Information secure?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long does DNP retain Personal Information?
We will only retain your personal information for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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 requirements.
By law we have to keep basic information about our customers after they cease being customers, for example for tax purposes.
Information about you that is no longer necessary and relevant to provide our services may be de-identified and aggregated with other non-personal data (without further notice to you) to provide insights which are commercially valuable to DNP, such as statistics around the use of the services. For example, we may retain anonymised energy consumption data to continue to improve our services. Your name and other identifiers will be removed from this information.
Enforcing your Rights
Please note the following:
· You may correct, update, restrict or limit your account information at any time by adjusting that information via your account settings in the DNP online portal.
· You may request that your account, together with the personal information within your account, is deleted by contacting DNP Customer Support (please see below).
· You can object to our processing of your personal information and we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
· Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority. We would, however, appreciate the chance to deal with your concerns, so please contact us in the first instance.
No fee usually required
You will not have to pay a fee to access your personal information (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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
You may contact us at any time by sending an email to firstname.lastname@example.org or by telephoning +86 769 3892 9188. Our support team are available between 8.30am and 5.30pm on weekdays (excluding Bank Holidays). DNP aims to respond any request within 2-5 business days.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.